Remedial Action Plan - planning.nsw.gov.au

Remedial Action Planfor

COPYRIGHT: The concepts, information and design ideas contained in this document are the property of Sydney Environmental & SoilLaboratory Pty Ltd (ABN 70106 810 708). Use or copying of this document in whole or in part without the written permission of SydneyEnvironmental & Soil Laboratory constitutes an infringement of copyright.

Richards Road, RiverstoneNSW 2765Lot 11 DP 816720Prepared for:

Mastergroup Lot 11 Pty Ltd

December 2013

(Report: C6868.Q3450.B28321 FB RAP)

Document Title:

Authored by:

Reviewed by:

COPYRIGHT: The concepts, information and design ideas contained in this document are the property of Sydney Environmental & SoilLaboratory Pty Ltd (ABN 70106 810 708). Use or copying of this document in whole or in part without the written permission of SydneyEnvironmental & Soil Laboratory constitutes an infringement of copyright.

Ryan Jacka

Date: 17/12/2013

Date: 17/12/2013

Revision Date Changes From Previous Revision Prepared By Reviewed ByDA Ryan JackaKelly LeeFirst Draft Report Released

SESL Document Control

Remedial Action PlanRIchards Road, Riverstone NSW 2765C6868.Q3450.B28321 FB RAP

Kelly Lee

Senior Environmental Scientist

Environmental Scientist

08/11/2013

DB Ryan JackaKelly LeeAdditional Validation QA/QC28/11/2013FA Ryan JackaKelly Lee Final Report Released 13/12/2013FB Ryan JackaKelly LeeRevised Final Report Released 17/12/2013

Remedial Action Plan

Richards Road, Riverstone NSW 2765 (Lot 11 DP 816720)

Job No. C6868.Q3450.B28321 FB RAP.docx

SESL Australia – December 2013

Mastergroup Lot 11 Pty Ltd Page 1 of 71

EXECUTIVE SUMMARY

SESL Australia (SESL) was engaged by Mastergroup Lot 11 Pty Ltd (the client) to prepare this Remedial Action Plan (RAP) for the property located at the Richards Road, Riverstone NSW 2765 (the site). SESL understands that the site is intended to be developed for residential purposes and may include features such as public open space and commercial areas, however no design plans were available at the time this RAP. The site was formerly used for activities associated with the former operation of an abattoir to the east of the site, with the site still containing residual elements of this land use, including the foundations of former structures and the large ponds in the southwest of the site. Previous investigations on the site identified a degree of contamination exists, both physical and chemical, that will require remediation before the Site can be considered suitable for the intended residential development. The remediation works prescribed in this RAP shall be undertaken by a remediation contractor selected and engaged by the developer for the intended residential development and will require validation by an appropriately qualified Environmental Consultant following completion of works. Remediation works at the site will involve Excavation and Disposal of identified asbestos, heavy metal and physical contaminants on the site, with ash materials that is currently used as an access road remediated through On-Site Treatment. It is the conclusion of SESL that the implementation of the remediation strategy developed in this RAP will achieve the objectives of the RAP and render the site suitable for the intended residential development. Documentation of the success of remediation is required in a subsequent Site Remediation and Validation Report (SRVR). Reference should be made to Section 13 of the report that sets out details of the limitations of the assessment. SESL AUSTRALIA

Kelly Lee Ryan Jacka Environmental Scientist Senior Environmental Scientist






TABLE OF CONTENTS 1 INTRODUCTION..................................................................................................................6

1.1 BACKGROUND......................................................................................................................... 6 1.2 OBJECTIVES ........................................................................................................................... 6 1.3 STAKEHOLDERS ...................................................................................................................... 7 1.4 OUTLINE OF THE RAP ............................................................................................................. 7

2 SITE DESCRIPTION............................................................................................................8 2.1 SITE IDENTIFICATION ............................................................................................................... 8 2.2 SURROUNDING LAND USE........................................................................................................ 9 2.3 SITE LAYOUT AND INFRASTRUCTURE ........................................................................................ 9 2.4 PHYSICAL SITE CHARACTERISTICS ......................................................................................... 10 2.5 SITE HISTORY ....................................................................................................................... 12 2.6 SITE ZONING AND PLANNING ISSUES ...................................................................................... 15 2.7 EPA CONTAMINATED SITES DATABASE .................................................................................. 15 2.8 DANGEROUS GOODS LICENSE SEARCH .................................................................................. 16 2.9 SUMMARY OF PREVIOUS INVESTIGATIONS............................................................................... 16 2.10 EXTENT OF REMEDIATION ...................................................................................................... 22 2.11 INTEGRITY ASSESSMENT ....................................................................................................... 22

3 CONCEPTUAL SITE MODEL ...........................................................................................23 3.1 SOURCES OF IMPACT............................................................................................................. 23 3.2 CONTAMINANTS OF CONCERN................................................................................................ 23 3.3 FATE AND TRANSPORT .......................................................................................................... 23 3.4 POTENTIAL SURROUNDING RECEPTORS ................................................................................. 24

4 REMEDIATION DESIGN ...................................................................................................25 4.1 REMEDIATION AREA .............................................................................................................. 25 4.2 REMEDIATION GOAL AND PURPOSE OF RAP........................................................................... 25 4.3 REMEDIATION ACCEPTANCE CRITERIA.................................................................................... 26 4.4 SELECTION OF REMEDIATION STRATEGY ................................................................................ 29 4.5 PREFERRED REMEDIAL OPTION ............................................................................................. 32 4.6 COMPLIANCE WITH REGULATORY REQUIREMENTS................................................................... 32

5 REMEDIATION METHODOLOGY.....................................................................................34 5.1 OVERVIEW............................................................................................................................ 34 5.2 REMEDIATION METHODOLOGY ............................................................................................... 34

6 VALIDATION .....................................................................................................................40 6.1 ENVIRONMENTAL CERTIFICATION ........................................................................................... 40 6.2 VALIDATION SAMPLING REGIME.............................................................................................. 40 6.3 VALIDATION OF IMPORTED AND ON-SITE BACKFILL MATERIALS .................................................. 42 6.4 WASTE CLASSIFICATION AND DISPOSAL CERTIFICATATION......................................................... 44 6.5 SITE REMEDIATION AND VALIDATION REPORT ......................................................................... 45

7 QUALITY ASSURANCE & QUALITY CONTROL PLAN..................................................47 7.1 DATA QUALITY OBJECTIVES................................................................................................... 47 7.2 DATA QUALITY INDICATORS AND DATA EVALUATION ................................................................ 48






7.3 FIELD AND LABORATORY QUALITY ASSURANCE PROGRAM....................................................... 50 7.4 QA/QC REQUIRED ACTION.................................................................................................... 53 7.5 MINIMUM QUALITY SAMPLE REQUIREMENTS ........................................................................... 54

8 SITE ENVIRONMENTAL CONTROLS..............................................................................56 8.1 OVERVIEW............................................................................................................................ 56 8.2 WORK PROCEDURES............................................................................................................. 56 8.3 EROSION, SEDIMENT AND SURFACE WATER MANAGEMENT ..................................................... 60 8.4 NOISE AND VIBRATION CONTROL MEASURES.......................................................................... 62 8.5 EQUIPMENT CLEANING AND OPERATION ................................................................................. 62 8.6 STOCKPILES ......................................................................................................................... 63 8.7 REMEDIATION SCHEDULE ...................................................................................................... 63

9 CONTINGENCY PLANNING .............................................................................................65 9.1 OVERVIEW............................................................................................................................ 65 9.2 INCREASED VOLUMES OF MATERIAL ....................................................................................... 65 9.3 UNKNOWN TYPES OF MATERIALS / UNEXPECTED FINDS .......................................................... 65 9.4 EXCESSIVE ODOUR OR VAPOURS........................................................................................... 66

10 WORK HEALTH & SAFETY............................................................................................67 11 COMMUNITY CONSULTATION & LIAISON ..................................................................68 12 CONCLUSION .................................................................................................................69 13 LIMITATIONS ..................................................................................................................70 14 REFERENCES.................................................................................................................71 DOCUMENT TABLES

Table 1 – Stakeholders ......................................................................................................................7 Table 2 – Site Identification................................................................................................................8 Table 3 – Summary of owners for Lot 11 DP 816720......................................................................13 Table 4 – Summary of Areas of Environmental Concern.................................................................18 Table 5 – Summary of Contamination from CSI ..............................................................................20 Table 6 – Remediation Acceptance Criteria ....................................................................................28 Table 7 – Remediation Acceptance Criteria for TRH as per Table 1(A)3 of Schedule B1 NEPM

2013.........................................................................................................................................29 Table 8 – Assessment of Potential Remediation Options................................................................30 Table 9 – Data Quality Objectives ...................................................................................................47 Table 10 – Minimum Quality Samples Requirements......................................................................55 DOCUMENT FIGURES

Figure 1 – Locality Map: Richards Road, Riverstone NSW 2765 ......................................................9 Figure 2 – Site Layout – Richards Road, Riverstone NSW 2765 ....................................................10






APPENDICES Appendix A Map 1 – Remediation Region 1 Map 2 – Remediation Region 2 Map 3 – Remediation Region 3 Map 4 – Remediation Region 4

Map 5 – Remediation Region 5






ABBREVIATIONS AC Asbestos Containing ACM Asbestos Containing Material AEC Areas of Environmental Concern AHD Australian Height Datum ANZECC Australian and New Zealand Environment and Conservation Council BTEX Benzene, Toluene, Ethylbenzene, and Xylenes COC Chain of Custody DEC Department of Environment and Conservation DECCW Department of Environment, Climate Change and Water NSW DQO Data Quality Objectives DQI Data Quality Indicators DSI Detailed Site Investigation EILs Ecological Investigation Levels ENM Excavated Natural Material EPA Environmental Protection Authority ESLs Ecological Screening Levels HILs Health Investigation Levels HSLs Health Screening Levels NATA The National Association of Testing Authorities NEHF National Environment and Health Forum NEPC National Environment Protection Council NEPM National Environment Protection Measure OCP Organochlorine Pesticides OEH Office of Environment and Heritage NSW OPP Organophosphorus Pesticides PAH Polycyclic Aromatic Hydrocarbons PCB Polychorinated Biphenyls PQL Practical Quantitation Limits PPE Personal Protective Equipment PSI Preliminary Site Investigation RAC Remediation Acceptance Criteria RAP Remedial Action Plan SESL SESL Australia SMP Site Management Plan SWMS Safe Work Method Statement SRVR Site Remediation and Validation Report TRH Total Recoverable Hydrocarbons UCL Upper confidence Limit VENM Virgin Excavated Natural Material WHS Work, Health and Safety






1 INTRODUCTION 1.1 BACKGROUND SESL Australia (SESL) was engaged by Mastergroup Lot 11 Pty Ltd (the client) to prepare this Remedial Action Plan (RAP) for the property located at Richards Road, Riverstone NSW 2765 (the site). SESL understands that the site is intended to be developed for residential purposes and may include features such as public open space and commercial areas, however no concept drawings were available when this RAP was prepared. The site was formerly used for activities associated with the former operation of an abattoir to the east of the site, with the site still containing residual elements of this land use, including the foundations of former structures and the large ponds in the southwest of the site. Previous investigations on the site identified a degree of contamination exists, both physical and chemical, that will require remediation before the site can be considered suitable for the intended residential development. The remediation works prescribed in this RAP shall be undertaken by a remediation contractor selected and engaged by the developer for the intended residential development and will require validation by an appropriately qualified Environmental Consultant following completion of works.

1.2 OBJECTIVES

The overall objective for the remedial works is to render the site suitable for future residential development. To achieve this objective, the RAP has been designed to:

• Provide a plan of remediation for the site to reduce unacceptable risk of contamination to impact on human and ecological health;

• Establish remediation acceptance criteria that are appropriate for low density residential use of the site in the context of identified contamination; and

• Demonstrate that the proposed remediation strategy is compliant with state and local government and planning statutes and compliant with NSW EPA endorsed guidelines under Section 105 of the Contaminated Land Management Act 1997 and properly addresses issues relating to site environmental management, community relations and contingency planning.






1.3 STAKEHOLDERS The key stakeholders involved in the implementation of the RAP are provided in Table 1.

Table 1 – Stakeholders

Stakeholder Property Owner/Developer

Remediation Contractor

Civil Works Contractor

Environmental Consultant

Site Auditor – Contamination

Blacktown City Council

Local Council and Neighbours

1.4 OUTLINE OF THE RAP The RAP has been developed under the guidance of the appropriate regulatory framework endorsed by the NSW Office of Environment and Heritage (OEH) and complies with the provisions of the NSW Contaminated Land Management Act 1997 and associated guidelines and regulations. The RAP will discuss the following:

• Site description; • Summary of previous investigations; • Conceptual Site Model; • Remediation Acceptance Criteria; • Remediation design; • Remediation methodology; • Validation; • Quality assurance and quality control plan; • Site environmental controls; • Contingency planning; • Work health and safety; and • Community consultation and liaison.






2 SITE DESCRIPTION 2.1 SITE IDENTIFICATION The property is approximately 153.8Ha and encompasses Lot 11 DP 816720. The proposed area (investigation area) to be developed is approximately 66.2Ha (see Figure 2). Details of site identification and ownership are presented in Table 2.

Table 2 – Site Identification

Site Owner Mastergroup Lot 11 Pty Ltd

Site Address Richards Road, Riverstone NSW 2765

Lot and DP Number Lot 11 DP 816720

Local Government Area Blacktown City Council

Current Zoning 1(a) General Rural

Distance from Sydney CBD Approximately 52.5km West of the CBD

Geographical Coordinates 33o40’13.52”S 150o50’42.58”E

Property Area Approximately 153.8Ha in total

Investigation/Audit Area Approximately 66.2Ha (Figure 2)

Site Elevation Approximately 6m to 24m AHD from North to South of the Site.

Locality Map Figure 1

Site Layout Figure 2 and Appendix A






Figure 1 – Locality Map: Richards Road, Riverstone NSW 2765

(Courtesy Department of Lands, 2011)

2.2 SURROUNDING LAND USE

The site is located within a general rural area with agricultural land bordering to the north and west of the site. A commercial building (Roadmaster Pty Ltd) is located to the immediate east of the property, followed by a railway line. To the far east is high-density mixed residential and commercial area. To the south of the site lies a rural residential land with agricultural activities. Eastern creek runs from the north-west border of the property to south east border with a gully flowing through the centre property from north to south.

2.3 SITE LAYOUT AND INFRASTRUCTURE

The site layout can be viewed in Figure 2. The site is mainly general rural land utilised for cattle farming and crop grazing. Four ponds (2 larger evaporation ponds and 2 smaller anaerobic ponds) occupy the south-west corner of the site, which was part of the effluent






irrigation system for the former meatworks facility on site. There is a shed located to the east of the effluent ponds and a small pumphouse located to the north of the western pond. Several farm dams are located on site. Three high voltage electricity transmission towers are located to the north west of the site, with one located near the western boundary of the investigation area. No mains supply of electricity is connected to the site, however a power tower is located to the western border of the site. Water infrastructures are expected to be on site for irrigation purposes. Figure 2 – Site Layout – Richards Road, Riverstone NSW 2765

(Courtesy Department of Lands, 2011)

2.4 PHYSICAL SITE CHARACTERISTICS

2.4.1 Topography and Drainage

The elevation across the site is approximately 6 meters (m) to 24m Australian Height Datum (AHD) from north to south of the site. The topography of the area in the vicinity of the site is an alluvial valley defined by both South Creek and Eastern Creek. Relief is about 10 metres, with a gentle downward slope to the north and east towards Eastern Creek and to the west towards South Creek.






The site is generally undulating down towards Eastern Creek (north east). Based on the site observation, soil material excavated from creating the two larger settling ponds were potentially used to raise the level of third and fourth smaller settling ponds (anaerobic ponds). As the site is fairly flat with a slope to the north-west, it is assumed that the site surface water would discharge in a north-western direction.

2.4.2 Geology, Hydrology and Hydrogeology

Soil Landscapes of the Penrith 1:100 000 Sheet 9030 (Bannerman et al. 1989) indicates the site to be within the Blacktown landscape group for majority of the property, with friable brownish black loam topsoil, overlying strongly pedal, mottled brown light clay subsoil with gently undulating rises on Wianamatta Group shales. Most typically cleared eucalypt woodland and tall open-forest (dry sclerophyll forest). The Geological Map of Penrith (series 9030) (Department of Mineral Resources 1991) indicates the local geology for this soil landscape group is the Wianamatta Group-Ashfield Shale consisting of laminite and dark grey siltstone, Bringelly Shale that consists of shale with occasional calcareous claystone, laminite and infrequent coal, and Minchinbury Sandstone consisting of fine to medium-grained quartz lithic sandstone. An associated soil landscape for Blacktown is South Creek, which occurs along drainage depressions. The eastern border of the property bordering Eastern Creek is within the South Creek landscape group, with brown apedal single-grained loam topsoil, overlying bright brown clay subsoil with floodplains, valley flats and drainage depressions of the channels on the Cumberland Plain. Most typically flat and cleared land with incised channels. The local geology for the South Creek landscape group is of quaternary alluvium derived from Wianamatta Group shales and Hawkesbury Sandstone. There are four settlement ponds located at the south-west corner of the site; two large ponds and two smaller ponds that are fenced. These ponds are not connected to the natural drainage lines on site, therefore are not expected to receive runoff or pose a flood risk. Tributaries of Eastern Creek and farm dams are located across the site. Seven groundwater bores are located within 1km radius of the site. Preliminary groundwater assessment was conducted as part of the CSI to determine if the setting ponds pose potential impact to the groundwater quality on site. Seven groundwater monitoring wells were installed surrounding the settling ponds area. Groundwater RLs ranged from 18.6m AHD to 20.8m AHD. The RL data indicates the






presence of two mounds in the vicinity of monitoring wells MW1 and MW6. Groundwater from these mounds appears to flow to the south, east and west. 2.4.2.1 Acid Sulfate Soil The presence of potential acid sulfate soil (PASS) material was identified in the NSW Natural Resource Atlas Maps for the area. The maps indicated that the site posed a Class 5 risk because of its proximity (within 500m) of a Class 1 to Class 4 risk area (see Appendix C). However due to the elevation and geological land unit of the area, it is not expected that acid sulfate soils are present in the investigation area.

2.4.3 Proximity to Local Sensitive Environments

A gully runs through the centre of the site from north to south. Eastern Creek borders the site from the north-western to south eastern direction. There are two identifiable farm dams present to the south of the site, with another farm dam located in the centre of the site development area. Other dams appear in some of the historical photographs but were not identifiable in the site walkover. The central dam appears to be intermittent between wet and dry and is present as a result of the road construction. The gully and farm dams located within the proposed development area may be potentially impacted during the bulk earthworks as the receiving environment for any runoff.

2.5 SITE HISTORY

A review of the site history was undertaken to assess historical use of the site, and in particular to identify activities with potential to contaminate soil or groundwater at the site. The historical review included:

• Historical Certificates of Title; • Historical Aerial Photographs; and • Other available historical site information.

2.5.1 Historical Title Search

The current and historical Certificates of Title were obtained from the Department of Lands and reviewed to assess the history of ownership and therefore possible landuse of the site. The site is currently described as Lot 11 DP 816720. The registered proprietor (owner) is Mastergroup Lot 11 Pty Ltd. The historical title search exposes 5 owners since 1902 (see Table 3).






Table 3 – Summary of owners for Lot 11 DP 816720

Duration Owner(s) Occupation(s) Suspected Landuse activities

11.03.1902 – 16.05.1904

Robert Richards and his Estate Unknown Residential

16.05.1904 – 01.03.1921 B. Richards and Sons Limited Unknown Residential

01.03.1921 – 21.05.1993 Riverstone Meat Company

Limited later Riverstone Meat

Company Proprietary Limited

Commercial/

Agricultural

Abattoir & Cattle

Farming

21.05.1993 – 10.10.1994 Riverstone Meat Company Pty

Ltd (formerly Timereef Pty Ltd)

Commercial/

Agricultural

Abattoir & Cattle

Farming

10.10.1994 – to date Mastergroup Lot 11 Pty Ltd

(formerly Roadmaster Haulage

Pty Ltd)

Agricultural Cattle Farming

2.5.2 Historical Aerial Photographs

Aerial photographs taken in 1947, 1951, 1955, 1961, 1965, 1970, 1975, 1982, 1986, 1991, 1998 and 2002 were obtained from the Department of Lands and reviewed to assess the history of the development of the Site. The review of the aerial photographs included the following: 1947 The site appears to be mainly rural land with several structures located to the south of

the site. These buildings appear to be sheds and are accompanied by a number of smaller farm sheds scattered around the area. The buildings and sheds on site appear to be part of the former Riverstone Meatworks facility. Neighbouring properties in the surrounding area are comprised of undeveloped land. A residential building is located to the east of these sheds. A large dam is observed to the further east of these sheds with a smaller dam at the far east border of the site. Neighbouring properties in the surrounding area are comprised of undeveloped land.

1956 The few main larger sheds remained on site, however the scattered sheds surrounding

the abattoirs buildings have reduced significantly. No other significant changes on site or in neighbouring properties in the surrounding area.

1961 No significant changes on site. Two sheds are located near the dam at the far east

border of the site. Neighbouring properties in the surrounding area to the immediate east show a commercial/industrial development, which forms the main Riverstone Meatworks facility (currently Roadmaster Pty Ltd.)






1965 The south-east area of the site (two lots of property; next to the large dam and to the north of the dam) appears to be cultivated for agricultural purposes. An additional dam is observed near the larger sheds and it is apparent that fewer sheds are observed in the property. A power tower is located to the north-western area of the site. No other significant changes are evident in neighbouring properties in the surrounding area.

1970 The large dam on site appears to be have been significantly filled and now appears to

be considerably smaller. In the surrounding area, Riverstone Parade is located to the east of the site and beyond that urban development is observed.

1975 Site shows significant changes, the south-west corner of the site is occupied by 4

settling ponds and a small dam to the north. All structural buildings of the abattoir facility are no longer on site with one new building located to the north-east of the new settling ponds. An additional small dam is also visible to the southern border of the site. The property located to the south of the site appears to be a mixed agricultural and residential area. In the surrounding area, significant residential and commercial development is observed to the far east beyond Riverstone Parade.

1982 No significant changes on site. The small dam near the former abattoir buildings

appears to be filled and is no longer on site. The area between the building and the two settling ponds appears to show soil disturbance indicating potential groundwork. An additional dam is observed in the centre of the property. Sheds to the far east corner near the dams are also no longer on site. In the surrounding area, the area between the eastern border and Roadmaster shows two dams and the ground has been cleared for development.

1986 No significant changes on site. A dam is observed to the north-east of the shed near

the settling ponds. A small shed is also visible to the north of the small dam, north of the settling ponds. No other significant changes are evident in neighbouring properties in the surrounding area.

1991 The building to the north-east of the settling ponds is no longer on site and the area

shows potential soil disturbance. A new shed located to the east of the settling pond is observed. No other significant changes are evident in neighbouring properties in the surrounding area.

1998 An area south to the power tower on site shows groundwork with the surrounding

property appears to be cultivated. No other significant changes on site. Minor changes in a neighbouring property including an irregular shape of land surrounding a dam occupies the area in between the eastern border of the site and Roadmaster Pty Ltd. No other major changes are evident in neighbouring properties in the surrounding area.






2002 No significant changes on site with the exception of the area to the south of the shed

show two stripes of disturbed soil, indicating potential groundwork. No other significant changes are evident in neighbouring properties in the surrounding area.

2.5.3 Other Available Historical Site Information

The investigation area forms a portion of the site that was first purchased in 1874 where the Riverstone Meatworks was founded in 1878. The two (2) aerobic and 2 anaerobic ponds on site were constructed in 1974 for the new effluent irrigation system for the meatworks facility. The meatworks permanently closed in 1994 and subsequently structural buildings on site were demolished, with the exception for the settling ponds that remained on site1.

2.6 SITE ZONING AND PLANNING ISSUES

Blacktown City Council Local Environmental Plan 1998 is the principle-planning instrument regulating landuse and development in the area. The site is zoned 1(a) General Rural and the objectives for this zone is as follow:

• To ensure that actual or potential agriculturally productive land is not withdrawn unnecessarily from production;

• To ensure that development in rural areas is carried out in a manner that minimises risks from natural hazards and does not unreasonably increase demand for public services;

• To provide urban support functions; and • To ensure that development within the rural zones does not hinder the proper and

orderly development of any future urban lands.

2.7 EPA CONTAMINATED SITES DATABASE A search of the NSW Environmental Protection Authority (EPA, now incorporated into the Office of Environment and Heritage) public register of Notices issued under the Contaminated Land Management Act 1997 on 04/12/12 indicated that the EPA had not issued any notices relating to contamination at the site. This search concludes that the site is not affected by the following notices:

• Preliminary Investigation Order • Declaration of Significantly Contaminated Land • Approved Voluntary Management Proposal • Management Order

1 Rosemary Phillis (2004) The Riverstone Meatworks, The Hawkesbury City Council






• Ongoing Maintenance Order • Repeal, Revocation or Variation Notice • Site Audit Statement

An additional search for Environmental Protection Licences (EPL), applications, notices, audits or pollution studies and reduction programs was undertaken with the NSW EPA on the 20/02/13 indicated that the EPA does not hold any information regarding these searches for this site.

2.8 DANGEROUS GOODS LICENSE SEARCH

A search of the Stored Chemical Information Database and the microfiche records held by WorkCover NSW conducted in previous investigations did not located any records on licenses to keep dangerous goods for the site.

2.9 SUMMARY OF PREVIOUS INVESTIGATIONS

2.9.1 Preliminary Site Investigation: Lot 11 DP 816720 – SESL August 2012, C7185.Q3041.B23331 FA PSI Riverstone

A Preliminary Site Investigation (PSI) was conducted by SESL Australia for the site in August 2012 to assess the site’s suitability for the proposed residential development. The scope of works for the PSI involved:

! Comprehensive desktop review on the historical activity on site based on selected aerial photographs and Certificates of Title;

! Searches for information held by relevant State Authorities in relation to contaminated land;

! Obtaining information pertaining to the site’s environmental setting including the proximity of the site to sensitive receptors and information on site geology;

! Review of previous environmental assessment done on site; ! Identify the potential contamination caused by past or present activities on site; ! Site inspection to identify site characteristics that may indicate contamination to

support findings of historical data review. ! Preliminary sampling conducted at effluent ponds to determine if there is potential

contamination caused by the ponds system and provide additional environmental data to previous investigations conducted for pre and post Treated Grease Trap Waste assessment on site;






! Laboratory chemical analysis by NATA accredited laboratories in accordance with chain of custody procedures;

! Assessment of field and laboratory analytical results limited to the adopted criteria for the site;

! Preparation of a PSI report detailing findings in accordance with Office of Environment and Heritage (OEH) guidelines for reporting contaminated sites;

! Identify the need to conduct further assessment; ! Determine if site is suitable for proposed development; and ! Proposed suitable remedial and validation strategies if required

The site was used historically for cattle grazing, waste water treatment and sheds possibly used as a dairy or feed lot associated with the former abattoir to the east. Effluent ponds comprising two smaller anaerobic ponds and two larger settling ponds are located in the southwest corner of the site. Preliminary sampling of soil from the base of the settling ponds did not indicate potential contamination that could pose potential harm to human health. In summary the site investigation identified the following potential environmental concern:

! The potential weathering of lead and/or zinc from building materials used in former sheds on site;

! The potential use of asbestos containing materials (ACM) within eaves, roofs and insulation of the former historic structures and drainage pipes on site;

! The identification of bonded ACM at isolated locations on site (top levy bank of the settling pond furthest to the west);

! The use of cinders (likely bottom ash from coal fired boilers at the former abattoir) as a road surface layer; and

! Potential heavy metals and nutrient contamination due to former agricultural activites and current cattle farming activities on site.

Based on the findings of this investigation, SESL considered that a detailed environmental investigation was required to representatively characterise the site.

2.9.2 Consolidated Site Investigation: Lot 11 DP 816720 – SESL December 2031, C6868.Q3222.B25854 FA CSI Riverstone

Previous investigations conducted for the site in relation to land and groundwater contamination were consolidated and reported in a Consolidated Site Investigation (CSI) report. The scope of works for the CSI included:

! Review of the previous investigations conducted on site; ! Detailed review of historical information of the site provided in previous reports, in

addition to currently available historical information; ! Incorporate findings of previous site investigations into a consolidated report;






! Inspection of the site and immediate surrounds to support the results of the data review and to identify site characteristics that may indicate land contamination

! Identification of Areas of Environmental Concern (AEC’s) and applicable contaminants and chemicals of concern;

! Development of Conceptual Site Model; ! Site walkover and inspection by SESL; ! Development of a Sampling, Analysis and Quality Plan (SAQP) in accordance with the

size and scale of proposed residential development; ! Soil sampling and analysis as outlined in the SAQP and a preliminary groundwater

investigation; and ! Reporting the CSI findings in accordance with Office of Environment and Heritage

(OEH) guidelines for reporting contaminated sites. The CSI identified that historical landuse on site, predominantly associated with the former meatworks facility on site, abattoir to the east as well the former and current agricultural activity on site have potential to contaminate soil on site. 13 Areas of Environmental Concern (AEC) were identified and a list of chemicals potentially associated with the historical activities onsite is shown in Table 4.

Table 4 – Summary of Areas of Environmental Concern

No. AEC Description Associated Contaminants

1 Settling Ponds The settling ponds were constructed as part of the

wastewater and irrigation system for the meatworks facility

in 1974. After the meatworks operation ceased, the settling

ponds remained.

Nutrients (Nitrogen & Phosphorus)

pH & Electrical Conductivity

Sodium Sulfate Calcium Carbonate

2 Anaerobic Ponds The anaerobic ponds were constructed as part of the

wastewater and irrigation system for the meatworks facility

in 1974. After the meatworks operation ceased, the

anaerobic ponds remained. Effluent treated in the

anaerobic ponds was released to the settling ponds.



Sodium Sulfate Calcium Carbonate

3 Agricultural Land Paddocks that have been used for livestock grazing since

the late 1800’s and biosolids were applied in a few

paddocks to improve the soil quality in recent years.

Heavy Metals Organochlorine Pesticide

4 Asbestos Pipes Former piping associated with the anaerobic and

settlement ponds is suspected to be asbestos containing

Asbestos






material. 5 Access Roads Access roads across the site to paddocks included a

surface layer of cinders to improve trafficability in wet

weather.

Heavy Metals Polycyclic Aromatic Hydrocarbon

Alkalinity 6 Farm Dams

(Paddocks A and

C)

Potential for contaminated sediment mobilized in runoff

from agricultural or animal waste to accumulate in farm

dams on site.

Heavy Metals

Nutrients (Nitrogen & Phosphorus) Polycyclic Aromatic Hydrocarbon pH & Electrical Conductivity

7 Potential filling in

Paddock Site observation and historical photos shows soil

disturbance in Paddock C in the southwest part of the site

indicating potential for burial of waste materials using

shallow landfills.

Heavy Metals Polycyclic Aromatic Hydrocarbon Total Recoverable Hydrocarbon Organochlorine Pesticide Polychlorinated Biphenyls

Asbestos 8 Former dumping

site A potential former dumping (stockpile) site located to the

east of the anaerobic ponds was identified from previous

investigation and historical aerial photographs.

Polycyclic Aromatic Hydrocarbon Total Recoverable Hydrocarbon Organochlorine Pesticide Polychlorinated Biphenyls

Asbestos 9 Former dumping

site Another potential former dumping (stockpile) site located to

the north of the farm shed was identified from previous

investigation and historical aerial photographs.

Polycyclic Aromatic Hydrocarbon

Total Recoverable Hydrocarbon

Organochlorine Pesticide

Polychlorinated Biphenyls

Asbestos 10 Former shed A former shed located close to the roads between

paddocks was demolished when the meatworks operation

closed at 1994.

Polycyclic Aromatic Hydrocarbon

Total Recoverable






Hydrocarbon

Organochlorine Pesticide

Polychlorinated Biphenyls

Asbestos 11 Former meatworks

facility and

associated

buildings

The former dairy or feed lot facility on site consists of

multiple structural buildings and sheds. Almost all of the

buildings with the exception of two sheds were demolished

when the operation closed at 1994.

Heavy Metals

Sodium Sulfate

Calcium Carbonate

Asbestos 12 Potential filling of

former dam

Historical aerial photos showed three former dams were

partially or completely filled and leveled.

Heavy Metals



Sodium Sulfate

13 Groundwater at

settling ponds

The settling ponds were part of the waste irrigation system

when the abattoir was in operation. This poses concerns if

the former wastewater within the pond could potentially

impact groundwater beneath the settling ponds.

Heavy Metals



The CSI assessed the 13 AEC and analytical results are summarised in Appendix E – Results Summary Table of the CSI report. Based on the previous investigations conducted and the findings of the CSI, the following AEC require remediation to render the site suitable for the intended residential land use.

Table 5 – Summary of Contamination from CSI

AEC Contamination Description AEC 4 Asbestos cement piping at the eastern evaporation pond and both anaerobic

ponds had weathered to an extent where free fibres were detected within soil material in the surrounding area (see Map 2: Remediation Region 2 – AEC4 / Map 6 of CSI report). These areas contaminated with asbestos (including piping infrastructure in western evaporation pond) must be remediated by a Class A licensed Asbestos Removalist and validated by an Occupational Hygienist prior to other remediation work.

AEC 8 Assessment of the site condition identified the presence of fill material and disturbed ground at various locations on the site. These areas were located to the immediate east of the anaerobic ponds and progressed further east until






Testpit JE23 as well as further south to the edge of the Eastern Settling Pond. Buried waste (drums, ACM etc) was identified in the area located to the east of anaerobic ponds (location JE: see Map 4: Remediation Region 4 – AEC8 and Map 7 and 9 of the CSI report). The buried waste must be removed during the bulk earthworks in preparing the site for proposed development. Asbestos containing waste must be removed by a Class A licensed Asbestos Removalist and validated by an Occupational Hygienist prior to other remediation work.

AEC 11 - BA

Former structure BA had concentration of lead above the adopted HIL – Residential A with 6 locations exceeding the HIL by more than 250% and therefore is considered a hotspot (BA3, BA10, BA11, BA22, BA32 and BA36). Asbestos containing fragments were identified in the vicinity of BA and a hotspot between BA9, BA22, BA25 and BA30 was identified (see Map 1: Remediation Region 1 – AEC 11 and Map 10 of the CSI report). These areas require remediation through offsite disposal during site development. The asbestos impacted material must be removed by a Class A licensed asbestos removal contractor and validated by an Occupational Hygienist prior to other remediation work.

AEC 11 - BA, BB, BC, BE, BF & BH

Concentration of Zinc above the calculated EIL was identified at the majority of the former structure areas, with higher frequency located around BA, BB, BC, BE, BF and BH. The proposed redevelopment for the site will involve the removal of the slabs, which will remove a significant portion of the impacted soils (see Map 10, 12 and 13 of the CSI report). Following the removal of the slabs, the site soils surrounding the former structures may be removed offsite during remediation.

AEC 5 AEC 8 AEC 9 AEC 11

Aesthetically unacceptable material (i.e. ash deposits, brick, concrete etc) identified in fill layers in AEC 8, AEC 9 and AEC 11 must be removed (see Appendix A – Remediation Map 5) if the material presents an unacceptable human health risk, or removed with other unacceptable material or mixed with surrounding soil if aesthetically unsuitable. The ash layer, identified on the surface of the access road (AEC 5), did not pose an unacceptable health risk and may be mixed with surrounding soil during earthworks to prevent ash material being concentrated in one location.

The groundwater table was raised beneath the ponds in the southwest part of the site, indicating some recharge by infiltration from the ponds. Groundwater quality did not appear to be impacted by the infiltration and no further investigation appears warranted.






2.10 EXTENT OF REMEDIATION The contaminated materials being managed under this RAP can be separated into the following types:

1. Asbestos fragments in soil – Pieces of broken fibre cement sheeting identifiable in the disturbed topsoil in the following areas:

o Region BA (AEC 11) o Region JE (AEC 8)

2. Asbestos pipe and surrounding impacted soil – Pipes used in the forme water infrastructure adjacent to the aerobic and anaerobic ponds plus the surrounding soil impacted by fibre release. This affected the following areas:

o Adjacent Ponds (AEC 4) 3. Soil contaminated with heavy metal – Soil is chemically contaminated due to the

former building materials and activities adjacent the following areas: o Region of Former Structures (AEC 11)

4. Soil contaminated with foreign materials – A minor level of foreign materials was observed in the topsoils around the former structures and in a deeper fill area adjacent the anaerobic ponds. These material include ash and other inert materials and affects the following areas:

o Region of Former Structures (AEC 11) o Fill Area of JE (AEC 8)

5. Soil contaminated with ash materials – The presence of ash materials in high quantities in the access roads (AEC 5) presents an aesthetic condition that requires remediation.

2.11 INTEGRITY ASSESSMENT The integrity of information provided in the previous investigations, published reports and from the site walkover was considered reliable. Details regarding the site history and present status of the site have been largely obtained from official records sourced from Blacktown City Council, OEH and NSW Land and Property Information Department. Additional information was obtained from previous environmental investigations, published records and newspaper articles to identify the historical information related to this site. These documents are considered accurate and credible. All information provided as part of this report was believed to be true, accurate and representative of the past and present status of the site at the time of this investigation.






3 CONCEPTUAL SITE MODEL

A conceptual site model (CSM) was developed based on the information obtained during the investigation process to allow assessment of potential sources of impact, chemicals of concern, transport mechanism and receptors.

3.1 SOURCES OF IMPACT

In summary, the sources of impact identified in the assessment area include: • Asbestos containing material within former water infrastructures within vicinity of the

effluent ponds; • Former dumping site located to the east of the anaerobic ponds with buried waste

such as drums and ACM; • Filled material in the surrounding area of the former meatworks facility such as ash

material and buried ACM; and • The former wastewater within the settling ponds impacting the groundwater within the

vicinity of the ponds.

3.2 CONTAMINANTS OF CONCERN

Based on the potential sources and the findings of the current investigation, the contaminants of concerns include the following:

• Lead; • Zinc; • Asbestos; • Buried waste (i.e. concrete slabs, large rocks, drums and general waste); and • Nutrients.

3.3 FATE AND TRANSPORT

3.3.1 Transport Medium

The anticipated primary transport media for the migration of contaminants of concern were: • Migration of contaminated material through air-borne asbestos fibres and dust; • Inhalation of respirable asbestos fibres; • Surface runoff from farm dams during flood events; • Airborne contaminants such as asbestos fibres may leave site based on the prevailing

air currents and temperature; and • Leaching of wastewater within the effluent ponds to the groundwater table.






3.3.2 Potential Migration Pathways

There are a number of mechanisms by which identified receptors may come into contact with contaminated sources, including the following:

• Inhalation of respirable asbestos fibres from loose fibres detected in soil material; • Incidental dermal contact or ingestion of impacted soils and surface water; • Generation of impacted dusts, aerosols or sediments from impacted soils; • Groundwater migration; • Migration of light non-aqueous phase liquids (LNAPLS) to soil or water, although they

have not been identified within the assessment area; • Consumption of vegetables grown in home gardens; and • Surface runoff and stormwater drainage system in the event of surface spillages.

Of the potential migration pathways identified above, fibres inhalation during construction works exposing soil contaminated with asbestos fibres is the greatest mechanism for sensitive receptors. These asbestos contaminated soil must be safely removed by a Class A licensed contractors prior to any bulk earthwork on site.

3.4 POTENTIAL SURROUNDING RECEPTORS The potential human receptors are as follow:

• Remediation workers or construction workers during construction or bulk earthwork activities due to exposure to air-borne asbestos fibres;

• Community members living within vicinity of the site; • Farmers working on the current cattle grazing land; • Visitors to the site; and • Future occupants of the developed site.

The most significant environmental receptors are considered likely to be:

• Underlying groundwater beneath the site, however majority of the vertical extent of the contamination are identified to be less than 300mm;

• Surface water of the farm dams within the site; and • Eastern Creek.






4 REMEDIATION DESIGN 4.1 REMEDIATION AREA

Interpretation of results from contamination investigation identified five (5) separate areas which warrant remediation. These areas are in the southwest part of the site and are determined by both the type of contaminant and the method of remediation proposed based on the contaminants of concern or other unacceptable condition:

o Remediation Region 1 – ACM contamination (as friable asbestos and asbestos fines) and Lead and Zinc in soil exceeding the HILs around the BA former structure in AEC 11.

o Remediation Region 2 – Locations of asbestos cement pipes (Bonded ACM) around the perimeter of the ponds and one location to the north of the ponds where the AC pipe has been removed. The locations are identified as AEC 4.

o Remediation Region 3 – Region of foreign materials and Zinc levels exceeding the EILs in the vicinity of the BB, BC, BE, BF and BH former structures in AEC 11. This region also includes areas of foreign materials within AEC 8 and AEC9.

o Remediation Region 4 – Deeper filling, generally between 1m and 2m depth, in an area immediately to the northeast of the ponds in AEC 8. Fill materials include foreign materials and asbestos (as Bonded ACM and friable asbestos).

o Remediation Region 5 – The main access roads within the site where ash materials have been used as a surface layer that presents an unacceptable aesthetic issue for the proposed residential development. This region is identified as AEC 5. Ash materials detected in AEC 8, 9 and 11 may also require similar treatment if found to be aesthetically unsuitable.

4.2 REMEDIATION GOAL AND PURPOSE OF RAP The goal for the remediation of the site is to render the site suitable for future residential development. The purpose of this RAP is to:

• Provide a plan of remediation for the site to reduce unacceptable risk to human health and/or ecosystems and remove aesthetically unacceptable conditions;

• Establish remediation acceptance criteria that are appropriate for low density residential use of the site in the context of identified contamination; and

• Demonstrate that the proposed remediation strategy is compliant with state and local government and planning statutes and compliant with NSW EPA endorsed guidelines under Section 105 of the Contaminated Land Management Act 1997 and properly addresses issues relating to site environmental management, community relations and contingency planning.






4.3 REMEDIATION ACCEPTANCE CRITERIA

4.3.1 Health and Ecological Investigation Levels (HILs and EILs)

Remediation Acceptance Criteria (RAC) have been derived from Schedule B(1): Guideline on Investigation Levels for Soil and Groundwater (NEPM, 2013). The guideline provides both Health Based Investigation Levels (HILs) and Ecological Investigation Levels (EILs). HILs are given in the NEPM for four (4) general exposure settings:

A Residential with garden/accessible soil (home grown produce contributing less than 10% of vegetable and fruit intake; no poultry) this category includes children’s day-care centres, preschools and primary schools.

B Residential with minimal opportunities for soil access, including dwellings with fully and permanently paved yard space such as high-rise apartments and flats.

C Public open space such as parks, playgrounds, playing fields (e.g. ovals), secondary schools and footpaths. It does not include undeveloped public open space (such as urban bushland and reserves), which should be subject to a site-specific assessment where appropriate.

D Commercial/industrial includes shops and offices as well as factories and industrial sites.

The HILs that are appropriate for the site correspond to the NEPM HIL – A criteria for residential landuses, together with the calculated EILs derived in the CSI. The adopted RAC are presented in Section 4.3.3.

4.3.2 Aesthetic Guidelines

The NEPM 2013 ‘Schedule B(1) Guideline on Investigation Levels for Soil and Groundwater, advise that aesthetic issues generally relate to the presence of low-concern or non-hazardous inert foreign material (refuse) in soil or fill resulting from human activity. These may be present on sites that have been assessed as being acceptable from a human health and environmental perspective, and should still be considered in regards to suitability for the proposed landuse. Specifically, Section 3.6.3 of Schedule B1 outlines that a higher expectation of soil quality would apply to residential properties with gardens compared with industrial settings. For the purpose of developing RAC for the site, SESL consider that remediation must include areas of observed foreign materials such as ash (including the access roads) and former foundations; with bulk earthworks subject to an incidental finds protocol to capture any foreign






material that may be discovered on the site. The aesthetic RAC is also presented in Section 4.3.3.

4.3.3 Adopted Remediation Acceptance Criteria

Derived from the NEPM 2013 the adopted remediation acceptance criteria (RAC) for the contaminants identified on the site are discussed below and presented in Table 6 and Table 7. Asbestos: Asbestos has been identified as Bonded ACM in existing water pipes, and as fibrous asbestos buried in fill material, as well as asbestos fines, including free fibres, around weathered AC pipes in some locations. For the purposes of developing a RAC for the intended residential development, SESL consider that asbestos as Bonded ACM or Fibrous Asbestos are not acceptable and will require removal where identified. No visible asbestos can remain on the site surface (upper 100mm of the soil profile) in accordance with the NEPM 2013 and Asbestos Fines must be below the Health Screening Level (HSL) as prescribed in Table 7 of Schedule B1, NEPM 2013. Any free asbestos fibres must be non-respirable and confirmed by laboratory testing as per AS4964 – 2004: Method for the Qualitative Identification of Asbestos in Bulk Samples conducted by NATA accredited laboratory. SESL assumes that the AC pipes can be removed intact and portion of surrounding soil material removed concurrently with validation ensuring no visible bonded ACM or Fibrous Asbestos remains with laboratory testing validating the residual soils meet the RAC. Heavy metals: Lead, Copper and Zinc have been identified at concentrations warranting remediation in soils surrounding the former structures on the site. Lead requires remediation to reduce human health risk while Copper and Zinc require remediation to reduce ecological risk. Although the HILs are not derived to be explicitly used as a remediation criteria, SESL has adopted a conservative approach to ensure that each potential residential allotment of the intended residential development contains site material suitable for the intended use. To meet this objective, the HIL for Lead has been adopted as the RAC, with an acceptance of 95% upper confidence level (UCL) average, provided no individual sample exceeds 2.5 times the RAC. The RAC for Copper and Zinc has also been developed from the calculated EIL determined in the CSI with an acceptance of 95% upper confidence level (UCL) average, provided no individual sample exceeds 2.5 times the RAC. The lesser of the HIL or EIL has been adopted for this investigation, i.e. no EIL has been adopted for Lead due to the HIL being lower than the EIL. Conversely, no HIL has been adopted for Copper and Zinc due to the EIL being lower than the HIL. Other heavy metals identified on site, although not at levels that warrant remediation, have been included in the event that they are required through the course of remediation. Consideration is given of an acceptance of 95% upper confidence level (UCL) average, provided no individual sample exceeds 2.5 times the RAC. Foreign Material: The physical contamination relating to this site is the presence of foreign materials that are not considered suitable to be present in soils on residential land. These materials do not have any direct human or ecological health risk, however were aesthetically






unacceptable and required removal. Because a concept for future residential development has not been defined, it is assumed that all areas of the site could potentially be used for residential purposes and would therefore need remediation of physical contaminants prior to being considered suitable. Based on this conclusion, SESL has adopted a zero tolerance for potentially dangerous materials such as glass and metal, however low levels of ash or gravel through the soil profile is acceptable. No gross contamination with ash or gravel is considered appropriate. Laboratory validation is not necessary for visual contamination as a visual appraisal will be sufficient to ensure an acceptable level of remediation is attained (i.e. acceptable for residential landuse).

Table 6 – Remediation Acceptance Criteria

Contaminant RAC Guideline Reference

Asbestos

0.001% w/w Asbestos

Fines

0.01% Bonded ACM

No visible asbestos on

surface

No respirable fibres present

NEPM 2013 – Schedule B1 Table 7

Copper (Cu) 140 mg/kg NEPM 2013 – Schedule B1 Table

1B(2):Calculated EIL from CSI Lead (Pb) 300 mg/kg NEPM 2013 – Schedule B1 Table 1A(1) HIL A

Zinc (Zn) 340 mg/kg NEPM 2013 – Schedule B1 Table

1B(1):Calculated EIL from CSI Arsenic (As) 100 mg/kg NEPM 2013 – Schedule B1 Table 1A(1) HIL A

Cadmium (Cd) 20 mg/kg NEPM 2013 – Schedule B1 Table 1A(1) HIL A

Chromium VI (CrVI) 100 mg/kg NEPM 2013 – Schedule B1 Table 1A(1) HIL A

Nickel (Ni) 170 mg/kg NEPM 2013 – Schedule B1 Table

1B(3):Calculated EIL from CSI

Mercury (Hg) 40 mg/kg NEPM 2013 – Schedule B1 Table 1A(1) HIL A

Total PAHs 300 mg/kg NEPM 2013 – Schedule B1 Table 1A(1) HIL A

BaP TEQ 3 mg/kg NEPM 2013 – Schedule B1 Table 1A(1) HIL A

Foreign Material

No dangerous materials

present.

Low levels of ash/gravel

blended in soil is

acceptable.

NEPM 2013 – Schedule B1 Section 3.6






Table 7 – Remediation Acceptance Criteria for TRH as per Table 1(A)3 of Schedule B1 NEPM 2013

Toluene (mg/kg)

Ethylbenzene (mg/kg)

Xylenes (mg/kg)

Napthalene (mg/kg)

Benzene (mg/kg)

F1 (mg/kg)

F2 (mg/kg)

Sand

0-<1m 160 55 40 3 0.5 45 110

1-<2m 220 NL 60 NL 0.5 70 240

2-<4m 310 NL 95 NL 0.5 110 440

4m+ 540 NL 170 NL 0.5 200 NL

Clay

0-<1m 480 NL 110 5 0.7 50 280

4.4 SELECTION OF REMEDIATION STRATEGY The selection of a remediation strategy for the site was undertaken in consideration of the contaminants being remediated, the extent of the remediation area and the intended landuse. Other considerations include the time required to achieve remediation, other impacts of remediation such as ecological or aesthetic values and overall cost.

4.4.1 Evaluation of Remediation Options

The preferred order of options for site remediation and management is given by the ANZECC/ NHMRC (1992) guidelines as:

• On site treatment of the soil so that the contaminant is either destroyed or the associated hazard is reduced to an acceptable level; and

• Off site treatment of excavated soil so that the contaminant is either destroyed or the associated hazard is reduced to an acceptable level, after which the soil is returned to the site.

If these options cannot be implemented other options can be considered including:

• Removal of contaminated soil to an approved site or facility, followed where necessary by replacement of clean fill; or

• Consolidation and isolation of the soil on site by containment within a properly designed barrier.

The above guidance can be summarised as the following potential remediation options for the site:

• On-Site Treatment; • Excavation and Disposal;






• On-Site Management; and • Do Nothing.

The assessment of the suitability of potential remediation options as discussed was made based on environmental impacts, time constraints, site logistics and cost. A description of each option is provided below with the assessment of each option summarised in Table 8.

4.4.1.1 On-Site Treatment On-site treatment methods include both in-situ and ex-situ treatments of soils. Treatment may be chemical, mechanical or biological. On-site treatments have the advantage of sometimes being relatively cheaper than off site landfilling. For the contaminants driving remediation on this site, biological treatment is not practical. Chemical and mechanical treatments falls under the category of solidification and stabilisation. This type of treatment retains immobilised contaminants on the site, but usual results in constraints to development of the affected portion of the land also requires implementation of an on-going Environmental Management Plan.

4.4.1.2 Excavation and Disposal Excavation of the contaminated fill material would be required for off site disposal. This option removes the contaminated materials through bulk excavation into trucks that then transfer the contaminated materials to a waste facility with appropriate licenses to receive the waste.

4.4.1.3 On-Ste Management On-site management would primarily involve constructing a containment cell by placing the contaminated materials within an engineered area lined with impermeable materials (such as geo-fabric material). The site would then require a site-specific ongoing Environmental Management Plan (EMP, also known as Site Management Plan - SMP) to control the exposure of the contamination to future owners, workers and visitors to the site and potential future users of the site.

4.4.1.4 Do Nothing The “Do Nothing” involves leaving hazardous materials, contaminated soil and aesthetically unacceptable materials in their current locations and proposes the development without concern for the remediation of contaminated soils.

Table 8 – Assessment of Potential Remediation Options

Remediation Option Discussion Conclusion On-Site Treatment • SESL considers that the contaminated

materials such as ACM or heavy metals identified in this investigation may be

This option is considered partially suitable for ACM and heavy metal






suitable for on-site treatment such as solidification and stabilisation.

• Treatment by mixing is considered acceptable for physical contaminants such as ash from the access road that do not pose a health concern and can be easily incorporated into surrounding soils to reduce its visual presence.

contamination, but suitable for treatment of ash materials such as the access road.

Excavation and Disposal

• This approach has the advantage of removing the contaminated soils from the site and potentially reducing development restrictions associated with contaminated soils. It also has the advantage of being relatively fast and may not further impact other areas of the site. The main disadvantage of excavation and disposal is the expense associated with off site disposal to an appropriately licensed landfill.

This option is considered suitable for the main contaminants identified on site (ACM, heavy metals and foreign materials) but is not recommended for some aesthetic issues that do not pose a health or ecological risk such as the access road.

On-Site Management • The disadvantages of such a strategy would be the imposing of an ongoing EMP, associated notification obligations on the land title and ongoing monitoring and inspection of the site for compliance with the EMP. This would not be considered acceptable for the intended residential landuse.

This option is considered unsuitable in the context of future development of the site for residential use.

Do Nothing • Areas requiring remediation are at the ground surface and exposed. The future use of the site would be affected by the presence of uncovered contaminated materials and would not be suitable for sensitive land use.

• The areas of concern could pose a potential health risk to workers during development of the site. The workers on the site could be potentially exposed to air-borne asbestos fibres and contaminated dust during development.

• The areas of concern at the surface exceed the adopted landuse criteria and are not

This option is considered inappropriate.






considered acceptable for ongoing use without remediation or management being undertaken.

• The identified contaminants are known to be persistent in the environment and will pose a long-term health and environment hazard if left on the site in their current state.

4.5 PREFERRED REMEDIAL OPTION

Following the assessment of options discussed above, SESL recommends that the most appropriate remedial option is ‘Excavation and Disposal’ for Regions 1 to 4, with Region 5 remediated through On-Site Treatment. These options satisfies the goals of remediation, can be delivered rapidly, is protective of human health and the environment.

4.6 COMPLIANCE WITH REGULATORY REQUIREMENTS

4.6.1 Environmental Planning and Assessment Act and Regulations

Remedial works at the site are not considered to present a designated development under Schedule 3 of the Environmental Planning and Assessment Act 1979. Furthermore, the program of rehabilitation works described in this RAP has been designed so that works shall not adversely affect the environment and will be an improvement to the environment. For these reasons the remediation works should not require the preparation of an Environmental Impact Statement (EIS).

4.6.2 State Environmental Planning Policy (SEPP No.55 – Remediation of Land)

The objective of this planning policy is to provide a state-wide planning approach to the remediation of contaminated land. In particular the policy aims to promote the remediation of contaminated land for the purpose of reducing risk of harm to human health or any other aspect of the environment. The planning policy applies to this site because the site is categorised as Category 2 Remediation Work and Blacktown City Council requires 30 days notice in writing before the commencement of remediation works and also must be notified at the completion of remediation works.

4.6.3 Blacktown City Council Development Control Plan, Part Q 2008 – Contaminated Land Guidelines

The objective of this development control plan (DCP) is to enable and land contamination issues to be identified and dealt with at an early stage in the planning process, for consideration of the implications of contamination with a preference for the remediation of contamination to not require ongoing monitoring of capping. This RAP meets the objectives of






the DCP with the aligned goal of remediating the site in a socially acceptable and cost effective manner which mitigates threats to, and provides protection for, public health, welfare and the environment while allowing flexibility in future use of the site.

4.6.4 NSW Protection of the Environment Operations Act 1997

The objective of the Act relevant to this RAP is to protect, restore and enhance the quality of he environment in NSW, having regard to the need to maintain ecologically sustainable development and to increase opportunities or public involvement and participation in environmental protection. The Act prohibits the contamination of land through any means including the improper application of waste and prescribe the requirements for triggering which sites require an environmental protection license to operate The objectives of the RAP align with the Act by focusing on an improved human and environmental amenity of the site and providing details of community consultation requirements.






5 REMEDIATION METHODOLOGY 5.1 OVERVIEW Remediation works at the site will involve Excavation and Disposal of forms of asbestos (bonded ACM, Fibrous asbestos and Asbestos fines), soil impacted by lead, zinc and copper and physical contaminants on the site, with the ash materials in the access road remediated through On-Site Treatment. A suitably qualified environmental consultant must be engaged to direct the remediation works and undertake validation of remediation works as required. SESL’s preferred methodology for the remediation works is discussed in the following sections.

5.2 REMEDIATION METHODOLOGY

5.2.1 Remediation Region 1 – Former Structure BA Remediation Methodology

Excavation and offsite disposal of contaminated materials is the preferred option for Remediation Region 1 of the site. The region contains broken fibre cement sheeting (friable asbestos) in an area of 5m by 10m and Lead contamination over a greater region of 50m by 30m. The northwest of region 1 contains residual foundations of the former buildings (aesthetic issue) in an area of 15m by 30m that require removal during the remediation program. All areas are impacted to a depth of approximately 400-500mm from the ground surface where natural clays are encountered. See Appendix A, Map 1 for the extent of Remediation Region 1. The Remediation Contractor who undertakes the remediation work must prepare a work method statement incorporating relevant sections of this RAP into a work methodology, and be licensed (Class A) to undertake asbestos removal at the site. The indicative work methodology can be summarised as follows:

1. Establishment: a. Locate the effected region using GPS coordinates provided in Appendix A:

Map 1. b. Works must be supervised by a Class A licensed contractor under direction by

an appropriately qualified environmental consultant to direct excavation and validate when removal of suspected contamination is completed.

2. Removal of Asbestos Impacted Materials: a. Contaminated materials from the asbestos impacted area shall be excavated

and stockpiled on site. Excavated materials may be stockpiled on an impermeable stockpile area, ensuring no direct contact between contaminated soil and the underlying materials (i.e. on plastic sheeting). Alternatively, material may be placed directly into a plastic lined skip bin.






b. Any stockpiled contaminated materials must be covered to prevent fugitive dust emissions.

c. Excavation shall continue until the underlying natural soil is observed. d. Materials in the generated stockpile (or skip bin) will require waste

classification in accordance with Section 6.4 of the RAP. e. Contaminated materials from this Region requiring remediation must be

removed offsite. f. After removal of ACM and asbestos impacted soil, the asbestos work area

requires clearance by a qualified Occupational Hygienist and also requires validation to certify that Asbestos fines are within the RAC and that no respirable asbestos fibres remain on the site.

3. Removal of Other Contaminants: a. Soil materials in the remainder of the Remediation Region 1 may then be

stockpiled separately and assessed as per step 2(d). Remediation in this area should take into account the remediation protocol outlined for Remediation Region 3 regarding the presence of foreign materials.

b. The remediation region will require validation to be conducted to certify that the Lead levels of residual soils do not exceed the RAC (including 95% UCL average as appropriate) and the validation consider the presence of ash materials and duly certify that the PAH and BaP TEQ do not exceed the RAC (including 95% UCL average as appropriate).

c. All contaminated materials must be removed offsite. 4. Restoration and Waste Disposal:

a. Backfilling (if required) can only be done using imported, certified VENM materials, or validated soils present on the site.

b. Waste disposal receipts must be included by the environmental consultant in the validation report.

5.2.2 Remediation Region 2 – Asbestos Pipes and Surrounding Soils Remediation Methodology

Excavation and offsite disposal of ACM and asbestos impacted materials is the preferred option for Remediation Region 2. Asbestos cement pipes, in the form of Bonded ACM, are present in the pond walls. Results from sampling and analysis around these AC pipes identified some asbestos fibre release has occurred. Appendix A: Map 2 indicates the extent of the Remediation Region. The selected contractor who undertakes the remediation work must prepare a work method statement incorporating relevant parts of this RAP into a work plan, and be suitably licensed (Class A) to undertake asbestos removal. The methodology below is provided as a guide for the contractor to develop a works plan.






AC pipes located beneath a road adjacent to location ASB S1 have been removed by a licensed contractor. Further validation of this area is required as prescribed in this RAP. The indicative work methodology can be summarised as follows:

1. Establishment: a. Locate the effected regions indicated in Appendix A: Map 2. b. Works must be supervised by a Class A licensed contractor under direction by


2. Removal of Bonded Materials: a. Remove the AC pipes in a manner to reduce the potential for further fibre

release. b. Place pipes immediately into a skip bin or truck to be removed offsite as

Bonded ACM. 3. Removal of Potentially Impacted Soil:

a. Excavation of surrounding soils is required to a depth of 50 to 100mm as directed by the environmental consultant. These materials are considered to be asbestos impacted due to weathering of the pipes as indicated by results in the CSI Report. These materials will be placed in controlled stockpiles pending removal, or alternatively, material may be placed directly into a plastic lined skip bin.

b. Contaminated materials from this Region requiring remediation must be removed offsite.

c. After removal of ACM and asbestos impacted soil, the asbestos work area requires clearance by a qualified Occupational Hygienist and also requires validation to certify that Asbestos fines are within the RAC and that no respirable asbestos fibres remain on the site

4. Restoration and Waste Disposal: a. Backfilling (if required) can only be done using imported, certified VENM

materials, or validated soils present on the site. b. Waste disposal receipts must be included by the environmental consultant in

the validation report.

5.2.3 Remediation Region 3 – Foreign Material and EIL Remediation Methodology

Excavation and offsite disposal of contaminated materials is the preferred option for Remediation Region 3. The region contains foreign materials associated with the former structures on the site, including concrete foundations and some ash fill materials. Contamination is present in two main areas; the northern area of 40mx75m and the southern area of 55mx90m. Both areas are impacted in the surface soils by heavy metals and foreign materials, extending to a depth of approximately 400-500mm from the ground surface where subsoil clays are encountered. All former structures have been included in this area (included the existing shed) to ensure the building rubble from the foundations is remediated






appropriately. Included in this region is the existing shed located to the north of the western evaporation pond and covers an area approximately 10mx10m. See Appendix A: Map 3 for the extent of the Remediation Region. The selected contractor who undertakes the remediation work must prepare a work method statement incorporating relevant parts of this RAP into a work methodology. The methodology below is provided as a guide for the contractor to develop a works plan. The indicative work methodology can be summarised as follows:

1. Establishment: a. Locate the effected regions using GPS coordinates provided in the Map of the

Remediation Region. 2. Removal of Impacted Materials:

a. All former foundations (and the structure to the north of the western evaporation pond) shall be removed from the site, and excavation of surrounding soils indicated on the remediation map to be undertaken with materials placed in stockpile.

b. Excavation shall continue until the underlying natural soil is reached, and will continue to the extent of the remediation region, or until no foreign materials are observed.

c. Works should be directed by an appropriately qualified environmental consultant to confirm that the extent of foreign material impact is reached.

d. Materials in the generated stockpile will require waste classification in accordance with Section 6.4 of this report.

e. Contaminated materials from this Region requiring remediation must be removed offsite.

f. The remediation region will require validation to be conducted to certify that the Copper and Zinc levels of residual soils satisfy the RAC (including 95% UCL average as appropriate) and the validation consider the presence of ash materials and duly certify that the PAH and BaP TEQ do not exceed the RAC (including 95% UCL average as appropriate).




5.2.4 Remediation Region 4 – Area JE Filling Remediation Methodology

Excavation and offsite disposal of contaminated materials is the preferred option for Remediation Region 4. The region contains buried foreign materials, including asbestos containing materials in the middle of the region. The region contains Bonded ACM as fibre cement sheeting in two impacted areas each set at 10mx10m for remediation purposes, an






area of fill likely impacted by ACM of approximately 35mx65m and foreign material contamination over a greater region of 90mx100m with a second region of foreign material to the southeast of approximately 80mx25m. Impact extends to a depth of approximately 1.5-1.7m for the asbestos contamination and to 2.5m for the foreign materials from the ground surface down to natural subsoil clays. See Appendix A: Map 4 for the extent of the Remediation Region. The selected contractor who undertakes the remediation work must prepare a work method statement incorporating this RAP into a work methodology, and be licensed (Class A) to undertake the asbestos removal at the site. The indicative work methodology can be summarised as follows:


Map 4. b. Works must be supervised by a Class A licensed contractor under direction by


2. Removal of Asbestos Impacted Materials: a. Contaminated materials from the asbestos impacted area shall be excavated

and stockpiled on site. Excavated materials may be stockpiled on an impermeable stockpile area, ensuring no direct contact between contaminated soil and the underlying materials (i.e. on plastic sheeting). Alternatively, material may be placed directly into a plastic lined skip bin.

b. Any stockpiled contaminated materials must be covered to prevent fugitive dust emissions.

c. Excavation shall continue until the underlying natural soil is reached. d. Materials in the generated stockpile (or skip bin) will require waste

classification in accordance with Section 6.4 of this report. e. Contaminated materials from this Region requiring remediation must be

removed offsite. f. After removal of ACM and asbestos impacted soil, the asbestos work area

requires clearance by a qualified Occupational Hygienist and also requires validation to certify that Asbestos fines are within the RAC and that no respirable asbestos fibres remain on the site.

3. Removal of Other Contaminants: a. Soil materials in the remainder of the Remediation Region 4 may then be

stockpiled separately and assessed as per step 2(d). Remediation in this area should take into account the remediation protocol outlined for Remediation Region 3 regarding the presence of foreign materials.

b. The remediation region will require validation to be conducted to certify that the foreign materials have been remediated to a level specified in the RAC.









5.2.5 Remediation Region 5 – Access Road Remediation Methodology

On-site treatment of the ash used as a surface layer on site access roads is the preferred option for Remediation Region 5. The region contains a high quantity of ash materials in the road surface that require remediation. The access road totals approximately 1700m in length and varies in width around 10m. The depth requiring remediation is approximately 300-400mm and is expected to vary along the length of the road. See Appendix A: Map 5 for the extent of the region. The selected contractor who undertakes the remediation work must prepare a work method statement incorporating this RAP into a work methodology. The methodology below is provided as a guide for the contractor to develop a works plan. The indicative work methodology can be summarised as follows:


Map 5. b. Works should be supervised by an appropriately qualified environmental

consultant to observe and document that ash materials are incorporated adequately into site soils.

2. Treatment of Ash Impacted Materials: a. Ash materials from the access road shall be incorporated into surrounding sit

soils, either adjacent to or below the road, by an excavator, dozer, grader or similar earthmoving equipment to dilute the ash to a level where the ash is not visually recognisable. Alternatively, the contractor may nominate the remove the ash materials offsite, in which case the ash must have a waste classification assigned in accordance with Section 6.4 of this report.

b. The effected region will require validation in the form of a visual inspection to confirm that materials are adequately blended with soils so that the ash is not visually identifiable as a separate layer, or that ash materials are removed from site.

c. Details of the strategy implemented, evidence of adequate blending (visual notes and photographs) and results of the waste classification and disposal receipts (if undertaken) must be made available to the validation consultant.






6 VALIDATION 6.1 ENVIRONMENTAL CERTIFICATION A qualified professional shall undertake validation sampling. All soil analysis shall be reported in the form of a validation report for the site to be reported in accordance with the relevant NSW EPA guidelines and AS4482.1. Sufficient validation works should be conducted so that the validation report will be able to conclude that the remediated site will meet the NSW EPA standards and will be suitable for residential (with accessible soil) landuse.

6.2 VALIDATION SAMPLING REGIME

6.2.1 Remediation Region 1 Validation

Region 1 must first be validated following the removal of the asbestos contaminated material off-site and issue of an asbestos clearance certificate by an Occupational Hygienist. Validation of the asbestos removal area must occur before further remediation works are conducted in this area. Based on the size of the remediation area, it is expected that validation will involve a visual observation that no visible asbestos remains, and a soil sampling program at a rate of 1 sample per 10m2 (i.e. 10 samples for the 100m2 area). Sampling of the walls of the excavated region at a rate of 1 sample per 10m of excavation wall and at least one sample in each wall (6 samples). Laboratory analysis must be in accordance with AS4964 – 2004: Method for the Qualitative Identification of Asbestos in Bulk Samples as stated in Section 4.10 of Schedule B1, NEPM 2013 for all types of asbestos and compared to the RAC. Validation for Lead contamination will be at a rate of 1 sample per 100m2 (i.e. 15 samples for the 1500m2 area), with the sampling of the walls of the excavated region at a rate of 1 sample per 10m of excavation wall (expected 16 samples). Validation analysis will include Zinc and Copper as well as these metals are commonly occurring contaminants with Lead in fill material. Results of validation samples shall be compared to the RAC, with consideration given to the 95% UCL average for the region. Should validation be required for isolated occurrence of ash materials (i.e. analysis for PAHs), this will be required at a rate of 1 sample per 10m2 for ash material in the base of the excavation, with the sampling of ash material in the walls of the excavation at a rate of 1 sample per 10m wall length. Results of validation samples shall be compared to the RAC with consideration given to the 95% UCL average for the region.






Sampling must include an inspection of the top 30cm of the soil surface (15cm in walls of excavation) to ensure the extent of contamination is reached. Validation of Region 1 must also include a visual inspection for the presence of foreign materials, including the northwestern area indicated on Map 1 as Region 3. Aesthetic condition of the soil must meet the requirements stated in the RAC.


Region 2 must be validated following the removal of the asbestos contaminated material off-site and issue of an asbestos clearance certificate by an Occupational Hygienist. Validation of Region 2 must include a observation of removal of Bonded ACM pipes, soil materials removed from around the pipe and must include a minimum of 5 surface soil samples per pipe (expected 60 samples total) analysed for asbestos fibres at each of the removed sections of pipe in accordance with AS4964 – 2004: Method for the Qualitative Identification of Asbestos in Bulk Samples as stated in Section 4.10 of Schedule B1, NEPM 2013. Downslope validation from each pipe is required at a density of 1 surface sample per 10m2. It is noted that sections of asbestos pipe were removed from the drainage line to the northwest of the western evaporation pond by a licensed contractor. Validation of the surface of this area is included as part of the validation for this region at a density of 1 surface sample per 10m2. Sampling must include an inspection of the top 30cm of the soil surface to ensure the extent of contamination is reached.


Region 3 must be validated following the removal of the contaminated material off-site. Validation for Zinc contamination will be at a rate of 1 sample per 350m2 (23 samples), with the sampling of the walls of the excavated region at a rate of 1 sample per 20m of excavation wall (25 samples). Validation analysis will include Lead and Copper as well as these metals are commonly occurring contaminants with Zinc in fill material. Results of validation samples shall be compared to the RAC, with consideration given to the 95% UCL average for the region. Should validation be required for isolated occurrence of ash materials (i.e. analysis for PAHs), this will be required at a rate of 1 sample per 10m2 for ash material in the base of the excavation, with the sampling of ash material in the walls of the excavation at a rate of 1 sample per 10m wall length. Results of validation samples shall be compared to the RAC with consideration given to the 95% UCL average for the region. Sampling must include an inspection of the top 30cm of the soil surface (15cm in walls of excavation) to ensure the extent of contamination is reached.






Validation of Region 3 must also include a visual inspection for the presence of foreign materials. No foreign materials can remain in the site soils as the prescribed RAC.


Region 4 must first be validated following the removal of the asbestos contaminated material off-site and issue of an asbestos clearance certificate by an Occupational Hygienist. Validation of the asbestos impacted soils must occur before further remediation works are conducted in this area. Based on the size of the remediation area, it is expected that validation will involve a visual observation that no visible asbestos remains, and a soil sampling program at a rate of 1 sample per 10m2 (expected 20 samples over two areas) for the identified hotspots containing ACM, and a rate of 1 sample per 50m2 (expected 38 samples over the larger area) for the surrounding potentially ACM impacted fill materials. Sampling of the walls of the excavated region at a rate of 1 sample per 10m of excavation wall per 1m depth (16 samples in the hotspots, 54 samples for the larger area). Laboratory analysis must be in accordance with AS4964 – 2004: Method for the Qualitative Identification of Asbestos in Bulk Samples as stated in Section 4.10 of Schedule B1, NEPM 2013 for all types of asbestos and compared to the RAC. Sampling must include an inspection of the top 30cm of the soil surface (15cm in walls of excavation) to ensure the extent of contamination is reached. Validation of Region 4 must also include a visual inspection for the presence of foreign materials. Aesthetic condition of the soil must meet the requirements stated in Table 6 - RAC. Validation analysis will include Lead, Zinc and Copper as well as these metals are commonly occurring contaminants in fill material.


Validation of Region 5 must include a visual inspection to validate that the ash materials have been incorporated to a degree to which they are no longer an identifiable layer. Documentation on the validation must include a plan to scale of the area where the ash was mixed with soil on the site and photographs illustrating the condition of the soil and ash after mixing.

6.3 VALIDATION OF IMPORTED AND ON-SITE BACKFILL MATERIALS The following procedure must be adopted to validate fill material identified for importation to the site, or identified on-site for use in the backfilling of remediated regions.

6.3.1 Imported Materials:

• Any materials to be used for backfilling should ideally be sourced from certified Virgin Excavated Natural Material (VENM).






• Other imported materials may also include Excavated Natural Material (ENM) as defined by the NSW Office of Environment and Heritage (OEH) in ‘the excavated natural material exemption 2012’, provided the ENM is also aesthetically acceptable.

• A qualified environmental consultant is to visit the source site and confirm that the site history indicates that the site is uncontaminated, and can visually identify the source of materials proposed for importation. This must include a documented site inspection, additional sampling confirmation, and a review of any available reports.

• The soil identified for importation must be free of foreign materials and undisturbed, not have any odours or discolouration and not be an acid sulfate soil.

• Imported material must be certified as VENM (or ENM) and supported by the appropriate certification documents as well as laboratory sampling of a minimum of three (3) samples per source site undertaken or 1 sample per 100m3, whichever is the greater number of samples.

• Analysis should account for the potential contaminants of concern from the source site, but at a minimum include:

o Asbestos o TRH + BTEX o PAH o OCP o PCB o Heavy Metals (As, Cd, Cr, Cu, Pb, Hg, Ni, Zn)

• Analytical results of the imported fill must demonstrate that each sample result is within the RAC limits and that the 95% upper confidence limit (UCL) of the average concentration of backfill material is below the acceptable limits.

• An inspection and documentation of each load imported to the site for consistency with source site is required.

• Any analytical results collected to support the assessment of VENM must reflect background concentrations and be indicative of VENM. Consideration must be given to the consistency of results and published background levels. This must be undertaken by a suitably qualified environmental professional and confirmed by the validation consultant.

• Details of the validation of imported backfill materials must be presented in the validation report prepared by the validation consultant.

6.3.2 Materials Sourced On-site

• A qualified environmental consultant is to inspect the on-site location and confirm that the site is uncontaminated, and can visually identify the source of materials proposed for importation. This must include a documented site inspection, additional sampling confirmation, and a review of any available reports.

• The soil identified for use must be free of foreign materials and undisturbed, not have any odours or discolouration and not be an acid sulfate soil.






• Imported material must be certified as VENM (or ENM) and supported by the appropriate certification documents as well as laboratory sampling of a minimum of three (3) samples per area or 1 sample per 100m3, whichever is the greater number of samples.

• Analysis must at a minimum include: o Asbestos o TRH + BTEX o PAH o OCP o PCB o Heavy Metals (As, Cd, Cr, Cu, Pb, Hg, Ni, Zn)

• Analytical results of the material must demonstrate that each sample result is within the RAC limits and that the 95% upper confidence limit (UCL) of the average concentration of backfill material is below the acceptable limits.

• An inspection and documentation of each load for consistency is required. • Any analytical results collected to support the assessment of VENM must reflect

background concentrations and be indicative of VENM. Consideration must be given to the consistency of results and published background levels. This must be undertaken by a suitably qualified environmental professional and confirmed by the validation consultant.

• Details of the validation of on-site sourced backfill materials must be presented in the validation report prepared by the validation consultant.

6.4 WASTE CLASSIFICATION AND DISPOSAL CERTIFICATATION No waste classification has been derived from the information completed in the CSI in accordance with the Waste Classification Guidelines Part 1: Classifying Waste (DECCW, Revised 2009), however it is expected that the results from soil characterisation will be utilised in supporting the classification assigned prior to disposal. The following procedure should be followed to classify the materials in each region:

1. Remedial works generate a stockpile of materials to be removed from the remediation region.

2. A qualified environmental consultant must undertake a visual inspection, including an inspection for the absence / presence of asbestos.

3. Sampling and analysis is undertaken on a ratio determined by the consultant based on the consistency and quantity of the material being classified.

4. The visual and analytical results shall be used to assign a waste classification in accordance with the Waste Classification Guidelines Part 1: Classifying Waste (DECCW, Revised 2009).

5. The materials must be removed from site to a facility licensed to receive waste of the classification assigned.






6. The validation report for the site must review the methodology, classification and disposal receipts to demonstrate that appropriate classification was undertaken.

6.5 SITE REMEDIATION AND VALIDATION REPORT The environmental consultant shall prepare a Site Remediation and Validation Report (SRVR) detailing the methodologies used in the remediation of the site to meet the remediation acceptance criteria prescribed in this RAP (Section 4.3.3). The SRVR shall include records of the disposal of contaminated soil materials and provide the findings of the validation assessment, a statement that the site meets the NSW EPA guidelines for the current/proposed landuse and provide details of any validation conditions or EMP requirements pertaining to the ongoing use of the site (if any). The SRVR should include all requirement of the Guidelines for Consultants Reporting on Contaminated Site (NSW OEH, 2011), including:

• Executive Summary: including background, objective of the validation, scope of works, and summary of conclusions and recommendation.

• Scope of works covered by the validation consultant. • Site Identification Information as per the CSI and RAP. • Summary of the available site history determined in the CSI. • Summary of the site condition and surrounding environment. • Summary of the geology and hydrogeology as determined in the CSI. • Sampling and analysis plan and sampling methodology. Must include a description

of the remediation methodology implemented by the contractor, and provide justification of any variation from the prescribed remediation method where applicable.

• Discuss the overall extent of remediation, and identify where remediation regions have been extended during remediation works either due to failed validation sampling, or by visual identification of contamination.

• Present field quality assurance and quality control measures implemented during validation.

• Provide and discuss laboratory QC/QC results and evaluate the QA/QC data. • Provide the RAC developed in the RAP. • Present findings of validation results and confirm statistically that the remediated

site complies with the RAC set for the site. The validation report must include details of all sampling location and sampling depths investigated to justify the conclusion.

• Where appropriate discuss any failure of results and works undertaken to further remediate areas and validate as may be necessary. US EPA’s Methods for Evaluating the Attainment of Cleanup Standards (1989) may also be applied.






• Include information confirming that all regulatory and legislative requirements have been met and all remediation, including offsite disposal has been undertaken in accordance wit this RAP.

• Present results of waste classification analysis in comparison to the Waste Classification Guidelines Part 1: Classifying Waste (DECCW, Revised 2009). Waste disposal receipts must be included that demonstrate appropriate disposal has been undertaken.

• Provide details that remediation works have been conducted in a social and environmental responsible manner and in compliance with relevant legislation.

• Provide a definitive conclusion that the remediation methodology and validation results have successfully met the objectives of the RAP and the site has been made suitable for the intended residential development.






7 QUALITY ASSURANCE & QUALITY CONTROL PLAN

7.1 DATA QUALITY OBJECTIVES

The purpose of establishing data quality objectives (DQOs) is to ensure the validation program is undertaken in a way that enables the collection and reporting of reliable data on which to base the validation. The DQOs and the procedures designed to achieve these objectives are listed below.

Table 9 – Data Quality Objectives

Process Response Step 1.

Define the problem

The Consolidated Site Investigation identified five regions that require

remediation. These regions are located in the southwestern corner of the site.

Remediation is required to render the site suitable for the intended future

residential development (see Sections 2.10 and 4.1).

Step 2.

Identify the goal of the

study

The goal is to demonstrate that proper implementation of the RAP has been

successful in meeting the goals identified in Section 4.2 to ensure the site is

suitable for the intended residential redevelopment.

Step 3.

Identify information inputs

Data inputs for the project:

- Results of soil analysis obtained through validation sampling.

- Health based and ecological investigation levels and screening levels for

soil and that are relevant to residential landuse.

- NSW EPA endorsed guidelines and Australian standards related to

sampling and analysis for validation.

Step 4.

Define the boundaries of

the study

The area subject to the validation is located within the remediation areas

defined in Section 4.1 and presented in the remediation maps (Appendix A).

The extent of remediation for each region is described as:

Region 1 – Asbestos Region: 50m2. Lead Region: 1500m2. Foreign Materials

Region: 450m2. Depth of contamination 400-500mm.

Region 2 – 12 identified asbestos pipes, each requiring validation of 9m2 of

surrounding soil. Depth of contamination top 100mm of soil.

Region 3 – Northern Region: 3000m2. Southern Region: 4950m2. Depth of

contamination 400-500mm.

Region 4 – Asbestos Region: Two ACM areas each of 100m2. A larger

potentially ACM impacted fill area of 1900m2. Foreign Materials Region:

9000m2. A second area to southeast of 200m2. Depth of contamination 1.5-1.7m

for asbestos and 2.5m for foreign materials, 400mm for foreign materials to the

southeast.

Region 5 – Access Roadway: 1700m in length and 10m width. Depth of ash

material is 300-400mm, being aesthetically unsuitable.






The sample medium comprises of soil in all remediation areas.

Step 5.

Develop the analytical

approach

The main contaminants of concern for each remediation region include:

Region 1 – Asbestos in Fibrous asbestos and asbestos fines; Lead

contamination of surface soils; foreign materials; PAHs in ash materials.

Region 2 – Asbestos as Bonded ACM pipes; asbestos fines in surrounding

soils.

Region 3 – Zinc contamination of surface soils; foreign materials; PAHs in ash

materials.

Region 4 - Asbestos as Bonded ACM in sheets, fibrous asbestos and asbestos

fines; foreign materials.

Region 5 – No analysis required – visual validation only.

Step 6.

Specify performance or

acceptance criteria

Sampling density will need to meet or exceed the design, sampling procedures

need to conform to relevant guidelines/standards, field quality control meets or

exceeds design and sample integrity between field and laboratory is not

compromised.

All analysis must be conducted by a laboratory with NATA accreditation for the

analysis being performed, and include internal laboratory quality assurance and

quality control indicators.

Concentrations of contaminants will be compared to validation criteria set in

Section 4.3.3 to assess effectiveness of remediation. The performance criteria,

excluding asbestos and aesthetics, will involve a consideration of the 95% UCL

average for validation regions, as well as the significance of individual results.

No individual result can exceed 2.5 times the RAC and the 95% UCL average

for each heavy metal contaminant (Lead, Copper and Zinc) must nor exceed the

RAC.

Step 7.

Develop the plan for

obtaining data

The validation program developed is outlined in detail in Section 6.2 and

includes visual inspections to confirm absence of foreign materials and asbestos

(regions 1, 2, 3, 4 and 5), soil analysis for the presence of asbestos fibres

(regions 1, 2, and 4) and the collection of soil samples for laboratory analysis of

heavy metals and PAHs (where ash layers are identified in Regions 1 or 3).

Sampling must be undertaken by a suitably qualified Environmental

Professional.

Quality Assurance (QA) procedures will be used as described in Section 7.3 and

Quality Control (QC) samples collected to allow evaluation of DQIs.

7.2 DATA QUALITY INDICATORS AND DATA EVALUATION

SESL has selected the following Data Quality Indicators (DQIs) to ensure that the data obtained from the validation are of sufficient quality to be used to draw reliable and representative conclusion in suitability of the site for the proposed development.






7.2.1 Documentation and Data Completeness

The completeness of data is defined as the percentage of analytical results that are considered valid. Valid chemical data values that have been identified as acceptable or acceptable as qualified during the data validation process. The completeness is a comparison of the total number of samples accepted against the total number of samples, calculated as a percentage. The validation project goal for completeness is greater than 90%. QA/QC for completeness includes the following:

• All critical locations sampled; • All required samples collected (i.e. surface and in depth samples); • Sampling team are well informed, qualified and experienced; • Correct and complete documentation; • Appropriate analysis methods and PQLs; • Compliance of sample holding times; and • All data entry is correct, properly entered, checked and that any typographical errors

are corrected and the data re-entered if necessary. Review of the extent of completeness is required throughout the validation program and feedback into a revision of methods should the goal of 90% completeness not be met.

7.2.2 Data Comparability

Comparability expresses the confidence that the data may be considered to be equivalent for each sampling and analytical event and deemed suitable for comparison. In order to assess comparability, field procedures, laboratory sample preparation procedures, analytical procedures and reporting units must be known and similar to establish protocols. Qualitatively, data subject to strict QA/QC procedures will be deemed more reliable, therefore more comparable, than other data. Data comparability between events must be demonstrated in the validation report. The validation consultant should utilise the same primary laboratory using the same laboratory methods for each analyte across the validation regions. Sampling methods must be the same between sampling events and preferably sampling is conducted by the same person for all regions to allow laboratory data to be appropriately compared.

7.2.3 Data Representativeness

Representativeness expresses the degree to which sample data accurately and precisely represents a characteristic of parameter variations at sample points or environmental conditions and obtaining suitable samples from these sites. Sample selection and analysis must be conducted in order to meet the specific objectives of the validation. Analysis for the contaminants of concern will be selectively conducted based on the contaminant being validated.






7.2.4 Precision and Accuracy for Sampling and Analysis

Precision and accuracy for sampling and analysis expresses the quantitative measure of the variability and closeness of the data. This DQI is crucial to provide information to data users of the reliability, unreliability or qualitative value of the data representing each analyte in each environmental matrix. QA/QC includes:

• Correct and appropriate Standard Operating Procedures applied and complied with; • Analysis of duplicates, triplicates, blanks, spikes and rinsates are satisfactory; • Assessment of RPDs are satisfactory; and • Independent review of QA/QC data satisfactory.

The laboratory must be NATA accredited for the analysis being conducted.

7.3 FIELD AND LABORATORY QUALITY ASSURANCE PROGRAM

Quality Assurance (QA) and Quality Control (QC) practices must be applied to all stages of data gathering and subsequent sample handling. These are designed to provide control over both field and laboratory operations. Additionally, the analytical laboratories will complete their own internal QA during the analysis of samples, and laboratory QA information must be reviewed by the validation consultant. Details of the QA/QC program are described below.

7.3.1 Quality Assurance

All fieldwork must follow procedures to ensure that all environmental samples are collected by a set of uniform and systematic methods as required by the QA system. The field procedure must describe the following:

• Decontamination procedures; • Sample identification procedures; • Information requirements for soil bore logs; • Chain of custody information requirements; • Sample duplicate frequency; and • Field calibration requirements (if necessary).

The validation consultant must demonstrate compliance with the field procedure and ensure that the above information is clearly presented and any deviation or variation between sampling events is noted and discussed.

7.3.2 Quality Control Results

The results of the field and laboratory quality control samples are assessed to determine: • The quality of the data generated; • If the data meets the objectives of the study; and • If the data is acceptable for the intended use.






7.3.3 Field Quality Control

A minimum level of quality control is required throughout the validation program in accordance with AS4482.1 and Section 5.4 and Appendix C of Schedule B2 of the NEPM 2013. This refers to the additional samples taken with the primary samples to indicate the quality of the validation program. The following will be considered the minimum level of quality control to be implemented during validation. The following data quality indicators shall used for the validation program:

• All samples analysed are conducted using NATA registered methods in accordance with ANZECC (1996) and NEPM 2013;

• Maximum acceptable sample holding times is 14 days for organic and 6 months for metal analyses. Mercury (Hg) must be analysed within 28 days of sample collection;

• Samples are appropriately stored and handled; • Laboratory method blank analyses are required to be below the limits of reporting

PQL; • All compound concentrations are (if required) spiked at similar concentration to sample

results; • All PQLs must be less than the assessment criteria; • The relative percent difference of duplicates are determined and compared to the

following criteria for acceptability. The acceptance criteria are: ! Less than 50% for field duplicates; ! Less than 30% for inter laboratory duplicates; ! Less than 30% for laboratory duplicates where the detection is less than 10

times the PQL; and ! Less than 20% for laboratory duplicates where the detection is greater than

10 the PQL. • RPDs for control spike duplicates to be compared to an acceptable limit of 20%; • RPDs for Matrix Spike Duplicates to be compared to an acceptable limit of 20%; and • Percent recoveries of control spikes and matrix spikes to be compared to an

acceptable range of 70-130%. In addition, percent recoveries of surrogates are also compared to the USEPA surrogate recovery limits.

7.3.3.1 Blind Replicate Samples

A minimum of 1 blind replicate shall be taken for every 20 primary samples collected. The blind samples should be taken from a larger than normal quantity of soil collected from the same sampling point, mixed as thoroughly as practicable and separated for analysis. This process is to identify the variation in analyte concentration between samples collected from the same sampling point and/or also the repeatability of the laboratory’s analysis.






7.3.3.2 Split Samples A minimum of 1 split replicate shall be taken for every 20 primary samples collected. The split replicate samples should be taken from a larger than normal quantity of soil collected from the same sampling point, mixed as thoroughly as practicable and separated for analysis. One replicate sample should be submitted to a different laboratory for analysis. This process is to assess the analytical proficiency of the laboratory.

7.3.3.3 Rinsate Samples, field and Trip Blanks A minimum of 1 rinsate sample should be submitted per day, per matrix per piece of equipment used. This process is to ensure no cross-contamination of substances from the sampling equipment used. Because of the absence of volatile organic compounds at the site, field and trip blanks are considered not to be required for validation.

7.3.4 Laboratory Quality Control

Analysis for soil samples to be undertaken by an environmental laboratory under COC procedures. Appropriate methods and detection limits such implemented.

7.3.4.1 Laboratory Blanks Laboratory or control blanks consist of reagents specific to each individual method and are prepared and analysed by laboratories in the same manner as regular samples. The preparation and analysis of laboratory blanks enable the measurement of contamination within the laboratory. Ideally, no contamination should be present in blanks. However, in the event that contamination is detected, the following actions are taken:

• The organic test results are not to be corrected by subtracting any blank value; • If any analyte is found in blank but not a sample, no action is taken; • No absolute results are reported unless the analyte concentration within a sample

exceeds 10 times the amount in any blank for common contaminates, or five times the amount for any other analyte; and

• Professional judgment is used where little or not contamination is present in the associated blanks, but contamination is suspected in actual samples.

Laboratory blanks are typically analysed at a frequency of 1 in 20, with a minimum of one analysed for each batch.






7.3.4.2 Laboratory Duplicates Laboratory duplicate samples are prepared in the laboratory by splitting a field sample and analysing it as two independent samples. The analysis of laboratory duplicate samples provides an indication of analytical precision and may be influenced by sample heterogeneity. The laboratory duplicate RPDs are used to assess the laboratory precision. Laboratory duplicates are typically analysed at a frequency of 1 in 20, with a minimum of one analysed for each batch.

7.4 QA/QC REQUIRED ACTION The following actions shall be required in the event any QC data fail the adopted indicators:

7.4.1 Field QC Required Action

o To investigate data completeness: o Review the COC to ensure the appropriate sample was submitted for the required

analysis. o Contact the laboratory to determine if any requested analysis was not performed,

or not reported. o Order additional analysis of samples held at lab to complete the required analysis. o Further sampling may be required to obtain additional samples to complete the

analysis. o To investigate data comparability:

o Review the COC to ensure the appropriate sample was submitted for analysis. o Review the data to ensure comparable LORs were requested. o Contact the laboratory and request that the results or LORs be checked. o Confirm the field information for the sample location to identify any observations

that may explain the variability. o Request that the laboratory re-run the analysis of the primary and QC sample to

confirm or deny the original failed data. o If the results are confirmed, request a subsample be submitted in duplicate to a

third party laboratory for the same analysis to confirm the primary laboratory results.

o If the third party results confirm the original, the validation consultant must investigate the field sampling methodology and/or decontamination techniques and/or matrix type to attempt to identify any interference that may be causing the QA/QC failure.

o Further sampling may be required to obtain additional samples to repeat the analysis.






o To investigate precision: o Review the COC to ensure the appropriate sample was submitted for analysis. o Review the data to ensure comparable LORs were requested. o Contact the laboratory and request that the results or LORs be checked. o Confirm the field information for the sample location to identify any observations

that may explain the variability. o Review field protocols to ensure appropriate techniques were implemented. o Request that the laboratory re-run the analysis of the primary and QC sample to

confirm or deny the original failed data. o If the results are confirmed, request a subsample be submitted in duplicate to a

third party laboratory for the same analysis to confirm the primary laboratory results.

o If the third party results confirm the original, the validation consultant must investigate the field sampling methodology and/or decontamination techniques and/or matrix type to attempt to identify any interference that may be causing the QA/QC failure.

o Further sampling may be required to obtain additional samples to repeat the analysis.

7.4.2 Laboratory QC Required Action

On review of the laboratory QA/QC program, the validation consultant may be required to investigate any failure of the adopted DQI. Typically, the laboratory report includes a QA assessment. In the event of a QC failure that is not adequately explained in the laboratory report, the validation consultant must: o Contact the laboratory and request that the results or LORs be checked. o Request that the laboratory re-run the analysis of the primary and QA/QC sample to

confirm or deny the original failed data. o If the results are confirmed, request a subsample be submitted in duplicate to a third party

laboratory for the same analysis to confirm the primary laboratory results. o If the third party results confirm the original, the validation consultant must investigate the

field sampling methodology and matrix type to attempt to identify any interference that may be causing the QA/QC failure.

7.5 MINIMUM QUALITY SAMPLE REQUIREMENTS

Based on the size of the remediation areas, and the frequency of quality samples, Table 10 outlines the expected minimum number of QA samples expected for validation.






Table 10 – Minimum Quality Samples Requirements Remediation Region Analyte Primary Samples Quality Samples

Asbestos 16 N/A Lead, Copper & Zinc

31 2 Blind Replicate 2 Split Replicate 1 Rinsate sample / day / piece of equipment (may include auger, trowel, shovel etc) 1 Laboratory Blank / batch 1 Laboratory Duplicate / batch

1

PAH Unknown 1 Blind Replicate / 20 samples 1 Split Replicate / 20 samples 1 Rinsate Blank / day / piece of equipment (may include auger, trowel, shovel etc) 1 Laboratory Blank / batch 1 Laboratory Duplicate / batch

2 Asbestos 60 N/A Lead, Copper & Zinc

48 3 Blind Replicates 3 Split Replicates 1 Rinsate Blank / day / piece of equipment (may include auger, trowel, shovel etc) 1 Laboratory Blank / batch 1 Laboratory Duplicate / batch

3

PAH Unknown 1 Blind Replicate / 20 samples 1 Split Replicate / 20 samples 1 Rinsate Blank / day / piece of equipment (may include auger, trowel, shovel etc) 1 Laboratory Blank / batch 1 Laboratory Duplicate / batch

Asbestos 128 N/A 4 Lead, Copper & Zinc

128 7 Blind Replicates 7 Split Replicates 1 Rinsate Blank / day / piece of equipment (may include auger, trowel, shovel etc) 1 Laboratory Blank / batch 1 Laboratory Duplicate / batch

5 N/A N/A N/A






8 SITE ENVIRONMENTAL CONTROLS 8.1 OVERVIEW The remediation of the site must be carried out in a manner that does not harm or degrade the environment (both on-site and off-site). All people involved in the project must ensure the protection of the environment throughout the duration of the works with special consideration of the following:

• Work procedures; • Control of fugitive emissions; • Dust control measures; • Erosion, sediment and surface water management; • Noise and vibration measures; • Equipment cleaning and operation; and • Stockpiles.

Site controls specifically related to the management of asbestos remediation must be prepared by the asbestos removal contractor and have not been included below. The asbestos removal contractor must prepare an Asbestos Management Plan to address the requirements under work health and safety legislation,

8.2 WORK PROCEDURES

8.2.1 Establishment and Site Preparation

Prior to commencement of remediation activities, the remediation contractor shall prepare a site management plan. The objectives of the site management plans are:

1. To protect the health of site workers, adjacent landowners and the general public during remediation works; and

2. To ensure workers do not negatively impact on potential environmental receptors and comply with applicable environmental legislations.

A control strategy is proposed for the management of all possible sources of exposure or dust release on the site. It is recommended that remediation activities be co-ordinated amongst other trades to prevent unauthorised persons from being present in the remediation area. Conversely, the work of other contractors needs to be scheduled to preclude them working near to, or within the remediation area until validated. The following are the major points that need to be considered in the site management plan:

• Safety of personnel both on and off site.






• Responsibility for the supply and application of isolating materials (e.g. ropes, barriers, plastic screens, waste containers, warning signs, etc).

• Limiting access to remediation area. • Perimeter/security fencing and erosion control • Transport facilities. • Availability of water and drainage. • Staff amenities and decontamination areas. • Protection of adjacent residential structures. • Waste disposal responsibilities and clean-up requirements. • Notification to, and approval from, regulating authorities where necessary. • Cleanliness standards that must be achieved to fulfil the contract.

The site management plan must comply with Blacktown City Council Contaminated Land Guidelines 2006, development consent conditions and other applicable guidelines or legislations.

8.2.2 Site Boundaries and Fencing

Warning signs at the boundaries of the remediation areas (at least 10 metres from the removal areas) should be labeled “REMEDIATION AREA – NO UNAUTHORISED ENTRY”. Signs must conform to Australian Standard 1319-1994 – Safety Signs for the Occupational Environment. Entry to the remediation area shall be restricted to personnel directly engaged in the soil remediation. Other persons entering the area shall be required to observe the appropriate safety precautions for that area.

8.2.3 Supervisory Personnel

Supervisory personnel shall have a detailed knowledge of the precautions and procedures demanded by contaminated soil remediation and cleanup. In the light of this knowledge and personal experience, supervisors shall assume the following responsibilities:

• The total remediation procedure; the setting up, the actual remediation (i.e. removal) and final cleaning operation.

• Select the most appropriate technique for removal of asbestos. • Ensure that all necessary measures are taken to reduce the airborne dust, and

that in any case, workers are not exposed to levels exceeding the recommended exposure standard.

• Arrange for, and assess results of, air monitoring where appropriate. • Ensure that all workers under their supervision are adequately trained in the safe

working practices associated with working on constructions sites. • Ensure that the remediation of the contaminated soil is continually supervised and

that the operation is carried out in a safe and proper manner.






• Ensure that personal protective equipment is available to all workers and maintained in good condition.

• Ensure that the remediation site is maintained in a clean condition, that waste is quickly and properly disposed of, and that the personal hygiene procedures are continually observed.

8.2.4 Decontamination Facilities

For operations involving contact with contaminated soil, an arrangement shall be adopted to ensure that protective clothing used for contaminated soil work shall not be worn away from the immediate vicinity of the soil removal area. Where appropriate, special laundering services for contaminated clothing may be required. All dirty work clothing, tools, equipment and bagged waste materials should be properly decontaminated before being removed. Those items that cannot be decontaminated through an appropriate decontamination process should be plastic wrapped and sealed for disposal.

8.2.5 Emission Controls

All contaminated stockpiles, unless in use (i.e. loading out, etc.), shall be covered with an impermeable cover, or maintained in a manner to prevent (as far as practicable) the generation of dust. The covering must be weighted down so it does not blow away with wind. Physical barriers such as construction fencing must restrict access to these areas. Wetting of all work areas, where active soil disturbance shall occur that day, shall begin prior to the start of the disturbance activities. Wetting shall be conducted as appropriate, based on the visual observations of the Site Manager or other appointed supervisor. This may be done by hand or using mechanical sprayers. Specific dust control measures for asbestos contaminated soils must be defined in the Asbestos Management Plan developed by the asbestos removal contractor. Maintenance wetting shall occur at the close of each workday in preparation of the following day's work zones. If maintenance wetting from the previous workday appears adequate (in other words, preliminary movement of machinery to a work zone must not yield emissions), and passes inspection, additional initial wetting will not be required. Wetting shall occur to prevent the possible emission of material during the movement of equipment to another location. Care must be taken to assure that the application of water does not produce emissions from the ground surface and that there is not excessive over-watering. During the actual soil disturbance activity, water shall be applied to the site of the disturbance, as appropriate, to suppress any visible emission. In general, personnel tasked with wetting duties must be assigned to each soil disturbance area to complete this wetting activity. Wetting shall be undertaken using a hose with spreading head to ensure even wetting occurs.






8.2.6 Wind Speed Work Stoppage

The application of a wind speed work stoppage requirement is designed to control fugitive emissions due to increased air velocity. In the event of high wind speeds, work must be stopped at the site until wind speeds are reduced to a speed that shall not generate visible emissions from the site. For the purposes of this site, work must be stopped when:

• Wind speeds reach a sustained 40 km/h; or, • Any wind speed at which particulates are observed by site personnel to be

entrained in the air stream. If site-specific weather creates conditions that may result in fugitive emissions, work stoppage may occur at wind speeds less than specified above based on decisions of the Site Manager. The Site Manager shall make the decision as to when it is appropriate to restart. Due to the current site fencing and narrow lot size, it is unlikely that a wind speed stoppage shall occur during works.

8.2.7 Street Cleaning and Maintenance of Roadways

Streets and roadways must be cleaned by equipment that shall produce no visible emissions of dust, to an extent practicable. Mud and dirt carried out from the contaminated area onto paved surfaces shall be prevented by limiting access to all vehicles except those required to undertake the remedial works. Boot cleaning facilities must be provided. Any mud and dirt carried out onto paved surfaces must be wetted and cleaned up daily. All unpaved surfaces on the site shall be watered as necessary to prevent off-property transport of visible fugitive particulate emissions.

8.2.8 Dust Control Measures

Prior to any intrusive works or other disruptive activities carried out on site, consideration must be given to how the work or activity can be undertaken with minimal dust generation. All works should be undertaken with control of dust as a priority. The dust control or avoidance measures should be documented in a SWMS prepared for the proposed works. Secondary controls, such as the wearing of dust masks should also be considered during potential dust exposure. Should any unexpected hazards arise, the Client should be contacted immediately so that the risks (health or safety) can be re-evaluated and the appropriate level of management and/or protection can be implemented prior to the recommencement of any works. The following procedures and techniques will control dust generation:

• Erection of dust screens around the perimeter of the site;






• A tarpaulin will securely cover all loads of soil contaminated material entering or leaving the site;

• Water sprays will be used across the site over unsealed or bare surfaces; • Plastic sheeting will be used by the remediation contractor to cover excavation

faces and stockpiles where necessary; and • Materials at the site will be processed, handled, moved and stored in a proper and

efficient manner in order to minimise exposure. If the above procedures and techniques are not sufficient to control dust then further contingency measures may include:

• Reduce area of disturbed surfaces; • Installation of perimeter sprays on the site boundary fencing; • Conducting work in more favourable weather conditions; • Modifying the manner in which excavation work is conducted at the site; • Using different equipment which generates less dust; and • Using equipment in more favourable weather conditions.

8.2.9 Spills and Leaks

On site control measures must be in place throughout the remediation works to protect the surrounding environment from spills and leaks:

• Construction of stormwater retention basins or diversion drains; • Presence of an emergency supply spill control equipment, such as oil absorbent

materials; and • Containment of any storage tanks or drums within bunded areas, which have the

capacity of 110% of the largest tank contained, or 25% of the total volume of all drums, whichever is greater.

Works required within this RAP do not contain activities that will require any liquids to be stored on site, with the exception of fuels for machinery. These shall be kept to a minimum at all times.

8.3 EROSION, SEDIMENT AND SURFACE WATER MANAGEMENT

8.3.1 Approach

An important part of the remedial works shall be the management of erosion, sediment and surface water. The strategy to be adopted must aim to:

• Prevent soil erosion at the site; • Protect off site waters and sediment from being polluted by onsite sources; • Minimise impacts to on site-surface waters from remedial works during the project;

and facilitate the implementation of the remedial works program.






The strategy shall involve the installation and operation of a number of environmental control measures that shall be progressively implemented as work progresses across the site. The design approach adopted must satisfy the following principles:

• Minimise the area of disturbed soil exposure wherever possible by staging the works;

• Control water flow from the top of the site, through the works and out the bottom of the site;

• Runoff from clean or remediated areas must be diverted away from unremediated areas of the site;

• Runoff must not be allowed to enter or overflow the unremediated area; • In the case of an extreme rainfall event, overflow water from unremediated areas

shall be filtered through straw bales and silt fences prior to discharging from the site. Given the short duration of the rehabilitation program, the probability of an extreme event occurring is considered to be very low; and

• Rehabilitate disturbed lands as quickly as possible. Regular maintenance of all erosion, sedimentation and pollution control devices shall be undertaken to ensure their continuing effective and efficient operation.

8.3.2 Protection of Excavation

Surface waters must be prevented from entering excavations by the construction of bunds and diversion drains around the perimeter of excavation areas. Water excluded from entering the excavation shall be directed to individual retention basins if required. Rainfall entering excavations shall be allowed to evaporate / dissipate naturally or be pumped out of the excavation and either sent to the temporary water retention basins or used for dust irrigation/dust suppression purposes. The end use shall depend on the quality of the ponded water. Water must not be allowed to migrate off the site. Use of on-site dams may be suitable so long as these dams are returned to original condition at the conclusion of works. Other options for the disposal of excavation pump-out water include disposal to sewer with prior approval from Sydney Water, or off-site disposal by a liquid waste transporter for treatment/disposal to an appropriate waste treatment/processing facility.

8.3.3 Stormwater Control in Remediated Areas

Erosion protection in disturbed areas of the site shall be provided by: • Grassing and the establishment of other vegetation; • Grading and sealing of areas proposed for future development by compaction of

the upper soil layers; and






• The construction and maintenance of or erosion and sediment control measures such as contour drains, straw bales and silt fences.

8.4 NOISE AND VIBRATION CONTROL MEASURES Noise and vibration levels must be controlled throughout the project. Special precautions must be taken to avoid nuisance in neighbouring areas, particularly from machinery, vehicles and warning sirens. The control measures to be implemented shall include the following:

• All construction vehicles involved in the rehabilitation project must generally enter and leave the site in accordance with specified site entry controls;

• Use of suitable construction techniques and methodologies; • Selection of quieter equipment, use of acoustic enclosures, construction of suitably

placed acoustic barriers or earth mounds and the fitting of ‘residential class’ mufflers and noise reduction kits to earthmoving and excavation equipment must be fitted;

• All material processing equipment shall have noise attenuation measures that make the equipment suitable for use in urban areas and by which comply with regulatory requirements. The protection measures where necessary shall include:

- The encapsulation of engine chambers; - Fitting NSW EPA approved silencers to all powered operated plant; and - The use of reversing alarms shall be adjusted according to the prevailing

ambient noise level. All practical measures must be taken during the remediation works to minimise the generation of noise and vibration from within site so that it remains within acceptable levels. In the event that short-term noise operations are necessary, and where these are likely to affect residences, notification must be provided to residents, specifying the expected duration of the noisy work. Given the location of the site, it is not expected that noise and vibration will present as an issue, however the details above are provided in case of that eventuality.

8.5 EQUIPMENT CLEANING AND OPERATION Throughout the remediation, controls must be placed on the operation and movement of equipment. General procedures that shall be implemented include the following:

• Equipment working within an excavation area must be washed inside the area so that any wash water shall run into the excavation. Wash waters shall be allowed to naturally evaporate or be removed from the excavation area along with ponded surface water;

• Equipment washing facilities must be provided for the effective cleaning of equipment after they have been loaded with contaminated fill, and prior to their






leaving the site. The facilities shall also be used to clean other earthmoving plant and equipment used on site;

• All trucks transporting material off site shall be securely covered immediately after loading the fill to prevent wind blown emissions and spillage;

• All truck tailgates shall be securely fixed prior to loading and immediately after unloading fill material;

• No trucks or equipment carrying contaminated materials shall be allowed to move across remediated areas except across designated transportation corridors;

• All vehicles transporting materials on site shall be operated in a manner so as to prevent any loss of materials during loading, transport and unloading activities; and

• Any storage tanks or drums used for fuels or liquids shall be bunded and bund shall contain at least 110% of the largest tank contained or 25% or the total volume of all drums, whichever is the greater, and the bund shall not be penetrated by any services.

8.6 STOCKPILES • Exposed or excavated fill materials or soils containing or suspected of containing

significantly contaminated materials and/or potentially asbestos materials must not be left unattended.

• If it is necessary to leave the site unattended, the fill materials or soils must be dampened to prevent generation of dust and placed back in the excavation and the surface cover reinstated to prevent exposure to these materials from users of the site.

• No stockpiles of soil or other materials shall be placed on footpaths or nature strips unless prior Council approval has been obtained.

• All stockpiles of soil or other materials shall be placed away from drainage lines, gutters or stormwater pits or inlets.

• All stockpiles of soil or other materials likely to generate dust or odours shall be covered.

• All stockpiles of contaminated soil shall be stored in a secure area and be covered if remaining more than 24 hours.

8.7 REMEDIATION SCHEDULE It is recommended that site remediation activities be coordinated with other trades to prevent unauthorised personnel from being present in the remediation area. Remediation work needs to be completed before any other disturbance of soil is undertaken. Works are not considered complete until validation certificates are presented.






8.7.1 Hours of Operation

This remediation process must be conducted in normal site hours only. No machinery or trucks must operate on site outside of the following times: Monday to Friday: 7am to 6pm Saturday: 8am to 1pm Sundays: Not permitted Public Holidays: Not permitted Night Work: Not permitted

8.7.2 Potential Effects on Community and Environment

There is a potential for fugitive dust generated during the excavation and loading of trucks, however there are limited potential receptors to the remediation regions. The leading hand must arrange the following dust control measures:

• Hosing with fine spray of water on exposed surfaces particularly during hot windy days.

• Hosing vehicles and covering loads prior to movement on site and especially prior to leaving the site (if required).

• Ensure all public roadways are kept as clean as possible. All noise producing equipment should meet the requirements of the Protection of the Environment Operations Act 1997 (NSW) and Protection of the Environment Operations Act (Noise Control Regulations) 2008. All contractors must ensure work times are adhered to. The control of odours during excavations must be monitored during the remediation process. Should odours be detected beyond the site boundary suppressant equipment must be deployed immediately to control odours entering nearby properties. All work must cease upon the detection of odours outside the property boundary. Commencement of work may take place once odours are controlled and validated by a suitably qualified professional.

8.7.3 Personnel

The remediation contractor prior to commencement of the remediation works must prepare a complete list of remediation contacts including site personnel. Personnel must hold the required certificates to complete the works required, including relevant licensing for asbestos related work where necessary.






9 CONTINGENCY PLANNING 9.1 OVERVIEW The unexpected conditions that could feasibly occur at the site include:

• The uncovering of greater amounts of ground contamination than presently estimated;

• The uncovering of presently unknown types of contamination; • The generation of unacceptable dust; • The generation of unacceptable odours; • The generation of unacceptable noise and or vibration levels; and • Spills or leak of hazardous materials.

Procedures that shall be used to address these contingencies are provided in the following sections.

9.2 INCREASED VOLUMES OF MATERIAL Throughout the project, the quantity of materials encountered at the site must be monitored, if there is a significant increase in the estimated volume of contaminated material, a review of the remediation strategy should be undertaken by the remediation contractor in consultation with the suitably qualified environmental professional undertaking the validation. Any agreed change to the remediation strategy must be notified to Blacktown City Council, and if required, to the Auditor.

9.3 UNKNOWN TYPES OF MATERIALS / UNEXPECTED FINDS If any unknown materials are encountered during remedial works by the observation of any unusual physical/sensory characteristics of the material (i.e. odours, changes in colour), the following process must be implemented:

• Work must immediately stop and the unexpected find area isolate; • A suitable qualified environmental professional must inspect the area to identify

the chemical/condition that has been observed; • The extent of the unexpected find must be delineated; • Develop a plan to manage any identified unacceptable risk associated with the

unexpected find; • Consult with the Site Auditor, Council and any other stakeholder, as appropriate; • Amend the RAP as necessary to include the additional remediation and validation

of the unexpected find; and • Implementation of the amended RAP.






9.4 EXCESSIVE ODOUR OR VAPOURS Odour and vapour generated must be kept to a minimum by excavating and loading of materials directly for haulage where possible and therefore minimising the amount of material to be stockpiled and reloaded. Odour and vapour generation shall be controlled through the use of water sprays and mists. The area under direct excavation shall be wetted with sprays. If volatile contaminants or objectionable organic odours are detected, on site volatile vapour monitoring must be undertaken during all works with a photoinionisation detection unit (PID). A work area and site boundary trigger value of 50ppm is set for additional vapour monitoring at the site. If the odour and vapour generation becomes excessive the following procedures shall be implemented:

• Monitoring locations must be positioned at the site boundaries adjacent to the neighbouring residential properties.

• An absorbent tube system to collect air samples over a time-weighted average. Results will be compared with criteria set out in the Ground Level Concentration (GLC) criteria as provided in Technical Notes: Assessment and Management of Odour from Stationary Sources in NSW (DEC, 2006).

• Works may be altered to accommodate a greater number of misting points or smaller areas of excavation works to minimise potential vapours generated. If necessary, absorbent compounds can be added to the spray system, which increase the effectiveness of volatile odour removal.






10 WORK HEALTH & SAFETY

The remediation contractor must prepare a Work Health and Safety Plan to establish standard health and safety procedures for the personnel involved in the remedial works at the site. Areas to be addressed in the plan include but are not limited to:

• Identification and Management of hazards, including: o Exposure and possible absorption through skin of contaminants; o Inhalation of volatile contaminant vapours; o Slips, trips, bumps, falls, falling objects, crushing injuries typical of every

construction related job site; o Fire or explosion; and o Physical hazards, noise and hot weather.

• General work procedures for personal hygiene; • Personal Protective Equipment (PPE); and • Emergency management.






11 COMMUNITY CONSULTATION & LIAISON

Community engagement, consultation and liaison are essential to ensure the remediation does not impact on the public amenity of the local community. Blacktown City Council is a key stakeholder and the community consultation strategy developed by the remediation contractor should be prepared in conjunction with Blacktown City Council. The remediation and intended development of the site constitutes a significant development in the local area, and may be of interest and/or concern to some local residences. It is important that the remediation contractor understand the concerns that the local community may have in regards to the development, so that they can provide clear information in response to these concerns or make amendments to site management to account for these concerns. Examples of community consultation that may be adopted include:

• Identify relevant stakeholder, including: o Local residents; and o Local government.

• Hold initial stakeholder meetings; • Provide information on site management and work scheduling for consultation; • Review, amend and feedback to the stakeholders any changes made in

consideration of information provided by the stakeholders; • Letterbox drop with information on the progress of works, any changes to works, or

any upcoming potential disturbances; • Hold progress stakeholder meetings; • Provide an avenue for communication, contact names and phone numbers, or

websites and email addresses; and • Monitor and evaluate the effectiveness of the consultation strategy, establish

feedback processes and implement changes to the strategy accordingly. The fundamental focus of the community consultation strategy is to be open, receptive and honest to all concerned parties. A relationship of trust needs to be fostered for the community to be receptive to information and to actively participate in the process.






12 CONCLUSION

Based on the contamination identified in the previous site investigations, this RAP has been developed to define the remediation strategies that will be necessary to render the site suitable for the intended residential development. The Site Environmental Controls and Contingency Plan outlined in this report must be implemented to ensure good environmental practices are adopted and corrective actions are performed in a timely manner. A separate Work Health and Safety Plan must be prepared be the remediation contractor before commencing remediation works. It is the conclusion of SESL that the implementation of the remediation strategy developed in this RAP will achieve the objectives of the RAP and render the site suitable for the intended residential development. Documentation of the success of remediation is required in a subsequent Site Remediation and Validation Report (SRVR).






13 LIMITATIONS

This report only covers the site conditions at the time of CSI inspections. Should there be any variation in the site conditions beyond this date, such as imported fill, chemical spillage, illegal dumping, further assessment will be required. This report is for the use of the Client, Site Owner, Auditor or Remediation Contractor and any relevant authorities that rely on the information for development applications and approval processes. Any reliance on this report by third parties shall be at such parties’ sole risk. This report shall only be presented in full and may not be used to support any other objective other than those set out in the report. SESL’s assessment is necessarily based on the result of limited site investigations and upon the restricted program of visual assessment of the surface and consultation of available records. Neither SESL, nor any other reputable consultant, can provide unqualified warranties nor does SESL assume any liabilities for site conditions not observed, or accessible during the time of investigations. No site investigations can be thorough enough to provide absolute confirmation of the presence or absence of substances, which may be considered contaminating, hazardous or polluting. Similarly, the level of testing undertaken cannot be considered to unequivocally characterise the degree or extent of contamination on site. In addition, regulatory or guideline criteria for the evaluation of environmental soil and groundwater quality are frequently being reviewed and concentrations of contaminants which are considered acceptable at present may in the future be considered to exceed acceptance criteria. Similar conditions may prevail in regard to site remediation standards as different regulatory mechanisms are developed and implemented.






14 REFERENCES • ANZECC (1996) Guidelines for the Laboratory Analysis of Contaminated Soils – Australian and New Zealand

Environment and Conservation Council • ANZECC (2000) Australian and New Zealand Guidelines for Fresh and Marine Water Quality – Australian and

New Zealand Environment and Conservation Council • AS4482.1 (2005) Guide to the Sampling and Investigation of Potentially Contaminated Soil (Part 1 & 2) • Bannerman, S. M. and Hazelton, P.A (1990), Soil Landscapes of the Penrith 1:100 000 Sheet. Soil

Conservation Service of NSW, Sydney • Blacktown City Council Development Control Plan 2006 Part Q – Contaminated Land Guidelines July 2008 • Blacktown City Council • Local Environmental Plan 1988 • CRC CARE (2011). Part 2: Application document. Technical Report No 10. Health screening levels for

petroleum hydrocarbons in soil and groundwater. • Department of Environment and Conservation (2006) Technical Notes: Assessment and Management of Odour

from Stationary Sources in NSW • Department of Mineral Resources (1991) Geological Map of Penrith (series 9030) • Edwards Lock Alphen & Langley DHSA Adelaide (1999) Identification and Assessment of Contaminated Land –

Improving Site History Appraisal • EIS (2013) Preliminary Groundwater Screening for Part of Lot 11 DP 816720, off Riverstone Parade, Riverstone

NSW, Ref: E26522KBrpt). • Environmental & Earth Sciences Pty Ltd (June 2003) Site Investigation of Riverstone Meatworks Effluent

Treatment Ponds • Environmental Planning and Assessment Act 1979 • Managing Land Contamination: Planning Guidelines SEPP 55 – Remediation of Land – Department of Urban

Affairs and Planning NSW EPA 1998 • NEPC 1999, National Environmental Protection (Assessment of Site Contamination) Measures • NEPC 2013, National Environmental Protection (Assessment of Site Contamination) Amendment Measures • NSW DEC (2006) Contaminated Sites: Guidelines for the NSW Site Auditor Scheme (2nd Edition) • NSW DECCW (Revised, 2009) Waste Classification Guidelines Part 1: Classifying Waste • NSW EPA (1995) Contaminated Sites: Sampling Design Guidelines • NSW EPA (1999) Contaminated Sites: Guidelines of Significant Risk of Harm from Contaminated Land and the

Duty to Report • NSW OEH (2011) Contaminated Sites: Guidelines for Consultants Reporting on Contaminated Sites • Protection of the Environment Operations Act 1997 • Rosemary Phillis (2004) The Riverstone Meatworks, The Hawkesbury City Council • SESL Australia (August 2010) Review of Environmental Factors: Lot 11 DP 816720 • SESL Australia (April 2011) Post Application Assessment for Riverstone Paddock B: Lot 11 DP 816720 • SESL Australia (May 2011) Review of Environmental Factors: Lot 11 DP 816720 • SESL Australia (August 2011) Post Application Assessment for Riverstone Paddock C: Lot 11 DP 816720 • SESL Australia (December 2011) Contamination Assessment: Lot 11 DP 816720 • SESL Australia (January 2012) Post Application Assessment for Riverstone Paddock E: Lot 11 DP 816720 • SESL Australia (August 2012) Preliminary Site Investigation: Lot 11 DP 816720 • SESL Australia (May 2013) Sampling, Analysis and Quality Plan – Richards Rd, Riverstone – Lot 11 DP 816720 • SESL Australia (December 2013) Consolidated Site Investigation – Richards Rd, Riverstone – Lot 11 DP

816720 • Soil Series No. 1, 2nd Edition, 1998 and 3rd Edition, (1999) Health-Based Soil Investigation Levels, National

Environmental Health Forum monographs • Soil Series No. 2 2nd Edition, (1998) Exposure Scenarios and Exposure Settings, National Environmental Health

Forum monographs

Appendix A

Title: Appendix A - Map 1 - Remediation Region 1Report: Remedial Action PlanAddress: Lot 11, Richards Road, Riverstone Legend:

Date: December 2013 Revision: R01

BD

BE

BCBI

BI

BB

BH

BA

BB6

BB7

BB8

BB9

AEC 11 - F tr

Remediation Region 1 - Lead

50m

30m

Remediation Region 1 - Lead

Remediation Region 1 - ACM

Remediation Region 1 - ACM Remediation Region 3

5m x 20m

50m x 30mRemediation Region 3

30m x 15m

13

2

4

Approx. Co-ordinates(Decimal Degrees)

1

2

3

4

-33.673575150.843679

-33.673314150.843618

-33.673748150.843362

-33.673435150.843183



BB6

BB7

BB8

BB9

AEC 11 - F tr

Remediation Region 2



BD

BE

BCBI

BI

BB

BH

BA

BB6

BB7

BB8

BB9

AEC 11 - F tr



1

2

3

4

-33.673283150.842070

-33.673711150.842432

-33.674110150.842367

-33.674589150.841904


40m x 75m

90m

25m

55m

1

3

2

4

5

6

5-33.673985150.841827

6-33.673321150.841795

Remediation Region 310m x 10m

7-33.671446150.838998

7



BD

BE

BCBI

BI

BB

BH

BA

BB6

BB7

BB8

BB9

AEC 11 - F tr



1

2

3

4

-33.672856150.841419

-33.672411150.842221

-33.672137150.841088

-33.672468150.841522

Remediation Region 4 - ACM

5-33.672333150.841658

Remediation Region 4 - Fill


Remediation Region 4 - ACM10m x 10m

100m x 90m

1

32

100m

90m 5

4

Remediation Region 4 - ACM35m x 65m

85m x 25m

7

6

6-33.673074150.841886

7-33.672999150.842785

I




Remedial Action Plan - planning.nsw.gov.au

Documents

Transcript of Remedial Action Plan - planning.nsw.gov.au