Level 3, 100 Pacific Highway, PO Box 560, North Sydney, NSW 2060 Tel: +61 2 9954 8100 Fax: +61 2 9954 8150 www.environcorp.com

ENVIRON Australia Pty Ltd ACN 095 437 442 ABN 49 095 437 442

2 July 2009 Our Ref: AS120873

Sydney Ports Corporation Level 8, 207 Kent Street Sydney, NSW 2008 Attention: Bruce Royds

Dear Bruce

Re: Site Audit Report – Remedial Action Plan Intermodal Logistics Centre @ Enfield

I have pleasure in submitting the Site Audit Report for the subject site. The Section B Site Audit Statement, produced in accordance with the NSW Contaminated Land Management Act 1997 follows this letter. The Audit was commissioned by Sydney Ports Corporation to assess whether the site can be made suitable for its intended commercial/industrial use as the Enfield Intermodal Logistics Centre.

The proposal was declared a Major Project under section 75B(1)(a) of the EP&A Act and conditions of approval by the Minister for Planning were stated in ‘Project Approval Section 75J of the EP&A Act 1979’ File No: 9037344 dated 5 September 2007. The Audit was initiated to comply with a condition of this approval.

Thank you for giving me the opportunity to conduct this Audit. Please call me on 9954 8100 if you have any questions.

Yours faithfully, ENVIRON Australia Pty Ltd

Graeme Nyland EPA Accredited Site Auditor 9808

CC: DECC – Statement only Strathfield Council – Statement only

Sydney Ports Corporation July 2009

Remedial Action Plan Intermodal Logistics Centre @ Enfield

AS120873 Z:\Projects\Sydney Ports\873_ILC Enfield\SAR_873_Enfield RAP_2Jul09.doc

Contents 1 Introduction 1

2 Site Details 3 2.1 Location 3 2.2 Zoning 3 2.3 Adjacent Uses 3 2.4 Site Condition 3 2.5 Proposed Development 4

3 Site History 5

4 Contaminants Of Concern 7

5 Stratigraphy and Hydrogeology 10 5.1 Stratigraphy 10 5.2 Hydrogeology 10

6 Evaluation of Quality Assurance and Quality Control Plan 11

7 Environmental Quality Criteria 15

8 Evaluation of Soil Analytical Results 17 8.1 Wagon Repair Shed (SP2) 17 8.2 Suspected Asbestos Break Shoe Burial Area (SP3) 17 8.3 TPH (SP4) 18 8.4 Filled Areas (SP4) 19 8.5 Diesel AST Area (SP4) 19 8.6 Asbestos (SP4) 19

9 Evaluation of Groundwater Analytical Results 20

10 Evaluation of Remediation 21 10.1 Remediation Strategy and Methodology 21 10.2 Evaluation of Remedial Action Plan 23

11 Contamination Migration Potential 29

12 Assessment of Risk 30 12.1 Detailed review of Human Health Risk Assessment 30 12.1.1 Chemicals of Concern 30 12.1.2 Exposure Assessment 30 12.1.3 Toxicity Assessment 33 12.1.4 Acceptable Levels of Risk 33 12.1.5 Data and Calculations 33 12.1.6 Modelling Inputs and Assumptions 34

13 Compliance with Regulatory Guidelines And Directions 37

14 Conclusions and Recommendations 38

15 Other Relevant Information 39




List of Tables and Figures

Table 4.1: Contaminants of Concern Outside of Delec (GN-9) Table 4.2: Contaminants of Concern within Delec (Audit GN34) Table 6.1: QA/QC – Sampling and Analysis Methodology Assessment Table 6.2: QA/QC – Field and Lab Quality Assurance and Quality Control Table 7.1: Risk Based Levels (mg/kg) developed by Coffey for Petroleum Hydrocarbons Table 10.1: Evaluation of Remediation Table 10.2: Evaluation of Remedial Action Plan Table 12.1: Significant Exposure Parameters Used by Coffey and Auditor’s Comments Table 12.2: Model Inputs Coffey and Auditor Comments

List of Appendices

Appendix A Attachments Attachment 1: Site Location Attachment 2: Site Coordinates Attachment 3: Lot and DP Information Attachment 4: Site Features Attachment 5: Proposed Containment Area

Appendix B Soil Criteria Appendix C EPA Guidelines




List of Abbreviations ANZECC Australian and New Zealand Environment and Conservation Council BaP Benzo(a)pyrene BGL below ground level BTEX Benzene, Toluene, Ethylbenzene & Xylenes (Monocyclic aromatic Hydrocarbons) CEMP Construction Environmental Management Plan CT Certificate of Title DP Deposited Plan DQO Data Quality Objectives EMP Environmental Management Plan EPA Environment Protection Authority (NSW) ESA Environmental Site Assessment report ha Hectare km Kilometres LOR Limit of Reporting m Metres MAH Monocyclic Aromatic Hydrocarbons Mercury Inorganic mercury unless noted otherwise Metals As: Arsenic, Cd: Cadmium, Cr: Chromium, Cu: Copper, Fe: Iron, Ni: Nickel, Pb: Lead, Zn:

Zinc, Hg: Mercury, Se: Selenium mg/kg Milligrams per Kilogram mg/L Milligrams per Litre m BGL Metres below ground level μg/L Micrograms per Litre NATA National Association of Testing Authorities NC Not Calculated ND Not Detected ng/L Nanograms per Litre NEHF National Environmental Health Forum NEPM National Environment Protection Measure NHMRC National Health and Medical Research Council n Number of Samples OCPs Organochlorine Pesticides OH&S Occupational Health & Safety OPPs Organophosphorus Pesticides PAHs Polycyclic Aromatic Hydrocarbons PCBs Polychlorinated Biphenyls PID Photoionisation Detector PQL Practical Quantitation Limit pH a measure of acidity, hydrogen ion activity QA/QC Quality Assurance/Quality Control RBL Risk Based Levels RPD Relative Percent Difference SILs Soil Investigation Levels SVOCs Semi Volatile Organic Compounds TPHs Total Petroleum Hydrocarbons UCL Upper Confidence Limit VENM virgin excavated natural material VOCs Volatile Organic Compounds - On tables is "not calculated", "no criteria" or " not applicable"


Remedial Action Plan Intermodal Logistics Centre @ Enfield Page 1


1 Introduction A site contamination audit has been conducted in relation to the proposed Intermodal Logistics Centre at Cosgrove Road, Enfield, NSW.

The Audit was conducted to provide an independent review of the suitability and appropriateness of a plan of remediation i.e. an audit for the purpose stated in Section 47 (1) (b) (iv) of the NSW Contaminated Land Management Act 1997 (the CLM Act).

Details of the audit are:

Requested by: Christa Sams on behalf of Sydney Ports Corporation (Sydney Ports)

Request/Commencement Date: 16 May 2008

Auditor: Graeme Nyland

Accreditation No.: 9808

The scope of the audit included:

• Review of the following reports:

– Draft ‘Remediation Action Plan for Known Soil Contamination Intermodal Logistics Centre @ Enfield’ dated 31 March 2009 by Coffey Environments Pty Ltd (Coffey).

– ‘Construction Environmental Management Plan Demolition and Remediation of the Intermodal Logistics Centre at Enfield – Stage 1B’ dated 8 December 2008 by Enviropacific Services (referred to as CEMP)

– Draft ‘Remediation Action Plan for Known Soil Contamination Intermodal Logistics Centre @ Enfield’ dated 13 May 2009 by Coffey.

– ‘Remediation Action Plan for Known Soil Contamination Intermodal Logistics Centre @ Enfield’ dated 3 June 2009 by Coffey.

– ‘Remediation Action Plan for Known Soil Contamination Intermodal Logistics Centre @ Enfield’ dated 23 June 2009 by Coffey.

• A site visit by the Auditor, 13 February 2009

• Discussions with Sydney Ports and with Coffey who prepared the RAP.

The RAP includes the results of additional delineation sampling referred to as the ‘Delineation Assessment’.

A RAP was prepared for Separable Portion 1 (SP1) of the Intermodal Logistics Centre for which a Section B Site Audit Statement (GN 401-1A) was prepared by the Auditor. This was undertaken separately to facilitate the initial works to replace a railway line.

Other previous audit reports and site audit statements prepared in relation to sections of the proposed Intermodal Logistics Centre by the Auditor are:




• ‘Summary Site Audit Report, Enfield Marshalling Yard’ and Site Audit Statement GN-9, dated 20 September 1999.

• ‘Site Audit Report, Delec Depot, Enfield’ and Site Audit Statement GN-34, dated January 2002.

Reports reviewed during the previous Audits, referred to in the current Audit include:

• ‘Detailed Contamination Assessment – Delec Depot Enfield, Version 1 Final’, dated December 2001 by Egis Consulting Australia Pty Limited (Egis).

• ‘Audit Enfield Delec Report’ dated 1991 by CMPS&F Environmental.

The site was formerly used as a rail yard and as a maintenance centre which resulted in the contamination of soil by long chain petroleum hydrocarbons, asbestos and some heavy metals. The site is now being redeveloped for use as an Intermodal Logistics Centre.

The remediation action plan requires excavation of contaminated soil with retention in constructed containment cells or capping the contaminated soil in situ. As contamination will remain on site, a long term environmental management plan will be required to be prepared and implemented following remediation.




2 Site Details 2.1 Location

The Intermodal Logistics Centre site locality is shown on Attachment 1, Appendix A.

The site details are as follows:

Street address: Cosgrove Road, Enfield, 2136

Identifier: Part Lot 2 DP 1006861 and Part Lot 14 DP 1007302 (see Attachment 2 and 3, Appendix A) (The other parts of these lots are covered by Separable Portion 1 discussed below)

Local Government: Strathfield Local Government Area

Site Area: approximately 60 hectares

The boundaries of the proposed Intermodal Centre are the Hume Highway to the north, Roberts Road and Wentworth Road to the west, Punchbowl Road to the south and Cosgrove Road to the east. The site consists of four separable portions referred to by Sydney Ports as SP2, SP3, SP4 and SP5 (Attachment 2, Appendix A). The majority of the site is SP2. SPI (coordinates CP51 to CP66) is a narrow site that was assessed separately and is not included in the current audit.

2.2 Zoning

The current zoning of the site is ‘Special Uses – 5b (Railways)’ under the Strathfield Planning Scheme. The surrounding areas are zoned Industrial 4.

2.3 Adjacent Uses

The site is located within an area of mixed residential and commercial/industrial land use. Adjacent uses are mainly light industrial and warehousing.

2.4 Site Condition

The site has a relatively flat topography, sloping towards Cosgrove Road on the northeast side. Site features are shown as Attachment 4, Appendix A. Railway tracks were present over much of the site, leading mainly to the main locomotive maintenance shed and a turntable. This diesel-electric train maintenance area, referred to as the Delec area, also includes numerous other buildings previously used to service the locomotives. Buildings located over the remainder of the site include a wagon repair shed, Yardmasters office and an administration building. Part of the site is currently leased for the storage of cars with the remainder mostly overgrown.

The Tarpaulin Factory in the south-east corner is not part of the site for the purposes of the audit.

At the time of the Auditor’s visit, some of the buildings adjacent to SP1 had been demolished.




Activities conducted in association with the servicing activities include refuelling, sanding, wheel truing, electronic servicing, and load testing. Ancillary facilities on the site include bulk fuel storage, effluent treatment plants, bulk oil and gas bottle storage.

Materials excavated from SP1 had been stockpiled in a section of the site.

2.5 Proposed Development

It is understood that the site is to be redeveloped by Sydney Ports as an Intermodal Logistics Centre for the loading and unloading of containers between road and rail and the short term storage of containers.

Separable Portion 1 is to provide a rail corridor and the Tarpaulin Shed is to be retained for historical reasons, both located outside the boundaries of this Audit.

A community and ecological area that will include a pedestrian bridge, an access track, a frog habitat, landscaped areas and floodplain, a detention basin and the south rail corridor are to be located at the southern end of the site in the vicinity of the Tarpaulin Shed with the marginal habitat area on the eastern boundary. It is proposed that these areas would be accessible only to those escorted by authorised personnel. The pedestrian bridge will be elevated above the site and will be accessible to the public. An EMP that outlines how these areas will be managed in the context of a commercial/industrial land use setting will need to be prepared.

For the purposes of this audit, the ‘commercial/industrial’ land use scenario will be assumed.




3 Site History Historical activities as they were summarised in audits GN 34 and GN 9 are as follows:

• Prior to the 1950s, it is reported that the site remained low-lying marshland with the areas to the south potentially a market garden.

• In 1957, the former Public Transport Commission of NSW commissioned the Diesel Electric and Electric Locomotive Maintenance Centre (Delec), after acquiring, filling and levelling the site. The nature of the fill constituted ash and clay. A tributary of Cox’s Creek which flowed across the south-eastern part of the site was probably filled at that time. Marshalling yard to the north with site filling of gullies that were not stormwater channels.

• Maintenance of diesel locomotives commenced when the site was decommissioned, and electric locomotives were serviced from the early 1960s.

• A load box facility (partly located on Separable Portion 1) was reportedly used for a period of approximately 20 years until a new load box was built in 1985, after which the old box was taken out of service. The commissioning date for the former load box is unknown. The old load box location is well known.

• Refuelling activities have taken place at the facility, with three large ASTs erected by 1965, used to store diesel fuel. Fuel spills were reported to have occurred over time following refuelling activities. The three ASTs were removed in the 1990s (year not recorded) and replaced by a larger AST in the same location. It appears that the ground surface around the three ASTs was not sealed.

• The fuel dispensing area was reported to have been sealed between 1991 and 1996 (only the bowser area being concreted prior to this period).

• A number of waste dumps were found (reportedly excavated and backfilled during the 1990s). The nature and extent of these waste dumps are unknown/not reported. CMPS&F (1991) shows a “solid waste tip”, but their site plan has no scale. It appears to be near the current wheel set storage.

• Most of the track work outside Delec was removed in the late 1980s.

• It was reported that prior to 1996, a number of the liquid storage facilities (such as fuel storage, mixed liquor tank, chemical store and lubrication oil tanks) were unbunded and unpaved.

• Since the early1990s, a number of environmental improvements were reported to have been implemented, such as ‘tack matting’ used to prevent oil and fuel leaks from parked locomotives, to reduce the impacts of “oily water” discharges into the sub-surface and off-site stormwater drains.

Although the site history is not well documented, it appears that few facilities have been removed and there have been few major changes in site processes over the life of the site. The locations of some previous potential sources of contamination are known (eg, the old load box, former ASTs in an unsealed area, formerly unsealed refuelling area). The major unknown appears to be the presence of waste dumps at unknown locations in the past.




In the Auditor’s opinion, the history is not well documented but the location of the primary targets has not changed over the life of the facility, and the absence of process information is partly compensated for by the bulk of previous investigations




4 Contaminants Of Concern Coffey included a list of the contaminants of concern and potentially contaminating activities that had been listed in the two previous audit reports which are shown again as Table 4.1 and Table 4.2. Delineation sampling was undertaken in a number of these areas and the contaminants of concern targeted have also been listed.

Table 4.1: Contaminants of Concern Outside of Delec (GN-9) Area Activity Potential Contaminants

(Audit Conclusions) Analytical Suite for

Delineation Assessment (Coffey)

Wagon Repair Shed

Light maintenance of wagons and carriages, including axle box maintenance/ stripping, fixing/fitting/re-lining asbestos brake shoes and replacing air hoses etc.

Metals, asbestos, TPH, benzene, toluene, ethylbenzene and xylene (BTEX) (See Section 8.1)

Copper, TPH C10-C36 and asbestos based on elevated concentrations of these contaminants detected at individual sample points. Further sampling was undertaken.

Asbestos Break Shoe Burial Ground (not known at time of GN-9)

On-site disposal (Not encountered during the previous Audit).

Asbestos

Yardmaster’s Office/ Administration Building

Possible use of pesticides under floor slab

Metals and organochlorine pesticides (OCPs) (Concluded that no further works were required for industrial use)

Drainage channels/low lying areas

Fill deposits Metals, polycyclic aromatic hydrocarbons (PAH), phenolics (While there was limited sampling at depth and not clear whether results representative of fill the Auditor concluded that any contaminants would not impact site users, but could impact groundwater’.

Eastern boundary No known activities Metals (Concentrations well below industrial criteria however as sample density is relatively low there is a possibility for hotspots. Investigation and validation of any




Table 4.1: Contaminants of Concern Outside of Delec (GN-9) Area Activity Potential Contaminants

(Audit Conclusions) Analytical Suite for

Delineation Assessment (Coffey)

exposed soil after development in this area is therefore warranted)

Stockpiles Contents of stockpiles not documented

Metals, TPH/BTEX, PAH, phenolics (Concentrations were below the criteria however further characterisation would be required for reuse onsite or disposal)

Groundwater (ENVIRON 2002)

Leaching of contaminants or migration from up-gradient

TPH and metals

Table 4.2: Contaminants of Concern within Delec (Audit GN34)

Area Activity Contaminants of Concern (and on

completion of the Audit)

Coffey Potential Contaminants

All track areas, especially load box and refuelling areas, fuel and lubricant storage, etc

Spills and leaks TPH, especially long chain oils and diesel

TPH C10-C36

Filled area, which is most of the site

Filling with ash and other unknown materials

PAHs, unknown metals Copper (at one particular location)

Diesel AST area Abrasive blasting Zinc, copper, lead, mercury

Zinc (at one particular location)

Carpark and diesel AST area, based on previous results

Steam boiler wastes Chromium (Audit (GN 34) noted that while chromium was detected at elevated concentrations in previous investigations, the criteria for chromium was higher in 2002 than what was used at the time of the original investigation, assuming the chromium is in the form of chromium (3+). No speciation has been conducted).




Table 4.2: Contaminants of Concern within Delec (Audit GN34) Area Activity Contaminants of

Concern (and on completion of the Audit)

Coffey Potential Contaminants

Steam spray shed and electrical workshop, mixed liquor waste tank areas

Cleaning with solvents

VHCs (The Auditor’s opinion (GN 34) was that chlorinated solvent contamination is not likely).

Around old fibro buildings, potentially anywhere on site

Deterioration of building materials, abrasion of asbestos brake linings, disposal of linings

Asbestos Asbestos

Near turntable Possible former market garden

OCPs (The Auditor concluded that the risk of significant pesticide contamination is low).

Groundwater Leaching of contaminants or migration from upgradient

Mainly TPH and metals Copper, manganese and zinc

Contaminants associated with the Wagon Repair Shed, asbestos break shoe burial ground, track areas (especially load box and refuelling areas, fuel and lubricant storage, etc), old fibro buildings, abrasion of asbestos break linings and disposal of linings are of concern to human health.

Validation sampling following demolition of building and infrastructure will include both visually/olfactory observations and sampling and testing for metals, PAHs, TPH, asbestos and OCPs and VOCs to a lesser extent. This is discussed in Section 10.

Given the conclusions and recommendations of the Audits (GN 9 and GN 34) the Auditor considers that the contaminants of concern targeted in the delineation investigations and listed in the RAP for validation are adequate.




5 Stratigraphy and Hydrogeology Following a review of the reports provided a summary of the site stratigraphy and hydrogeology was compiled as follows.

5.1 Stratigraphy

The stratigraphy as summarised in audit GN34 for the site is provided below:

• The topography is relatively flat, as it was extensively filled and levelled during the initial site development. The site would have originally sloped to the east and northeast.

• Fill is underlain by a clay and ash fill. The ash is said to originate from steam locomotives, which were stored on the site prior to the development of the Locomotive Maintenance Centre. The fill extends to depths ranging from 2–4 m, and is thickest on the eastern portion of the property.

• The fill is underlain by 0.2–6 m of natural clay, which is underlain by moderately weathered shale.

5.2 Hydrogeology

The hydrogeology as summarised by audit GN34 for the site is provided below:

• A perched water table was found, in the fill material above the natural clays materials. The depth to perched water and interconnection between perched water bodies are thought to be inconsistent. Flow would be expected to generally follow the fill and natural clay boundary.

• Groundwater is found within the natural clay and shale and deeper fill at a depth of about 2-3 m below ground surface.

• General direction of the natural groundwater flow is easterly. Groundwater abstraction and use is not expected because of low quantity and poor (saline) quality. The nearest receptor is expected to be Cooks River or its tributaries to the east of the site.




6 Evaluation of Quality Assurance and Quality Control Plan

The Auditor has assessed the overall quality of the data by review of the information presented in the RAP in relation to the Delineation Assessment, supplemented by field observations. In addition, Coffey have provided an indication of the QA/QC to be undertaken to ensure the overall quality of the validation data. Validation sampling locations are discussed in Section 10. The Auditor’s assessment follows in Tables 6.1 and 6.2.

Table 6.1: QA/QC – Sampling and Analysis Methodology Assessment Sampling and Analysis

Plan Auditor Comments

Sample locations, patterns and depth

Delineation Sampling: Previous elevated concentrations of contaminants detected in the Delec area, the Wagon Repair Shed and the asbestos break shoe area were treated as hotspots and additional samples were stepped out in four directions 5 m from the original samples. Sampling was undertaken at 0.2m and 0.5 m below the depth of the previous elevated sample result. The locations of the samples were not provided however it is known approximately where they would have been taken as they were north, east, south and west of the previous borehole. Sampling in the asbestos break shoe area was undertaken at four depths extending to 2 m depth. The Auditor considers that the investigation locations provide additional data in relation to the main areas of concern.

Sample Collection Method Delineation Sampling: Samples were collected with hand augers and push tubes. RAP: Samples are to be collected with a trowel, hand auger or collected directly from the surface with fresh disposable gloves. It is likely that hand augers will not be required (RAP) greatly given the proposed excavations and surface sampling. Use of a hand auger can lead to a loss of volatiles and lead to cross contamination. Given the key contaminants at the site are heavy metals, heavy end TPH and asbestos this deficiency is not considered to be of great significance. There may have been some under reporting of TPH C10-C14 however given the magnitude of the criteria for long term workers and the proposed management plan for maintenance workers, this is unlikely to affect the conclusions.

Decontamination Procedures

Delineation Sampling: The hand augers and push tube were decontaminated between sample locations using potable water and phosphate free detergent. A clean pair of disposable nitrile gloves were used when handling each sample. RAP: All non-disposable equipment would be decontaminated between samples by brushing, washing with Decon 90, rinsing with tap water, spraying with distilled or deionised water and then air dried. New gloves would be used for each new sample. Adequate




Table 6.1: QA/QC – Sampling and Analysis Methodology Assessment Sampling and Analysis

Plan Auditor Comments

Sample handling and containers

Delineation Sampling: All samples were placed into prepared and preserved sampling bottles provided by the laboratory and chilled during storage and subsequent transport to the labs. RAP: All samples will be placed into prepared and preserved sampling bottles provided by the laboratory and chilled during storage and subsequent transport to the labs. Adequate

Chain of Custody Delineation Sampling Chain of custody forms were completed and provided in the report. RAP: Chain of custody forms will be completed and provided in the report.

Detailed description of field screening protocols

Delineation Sampling: Field screening with a PID was not undertaken as volatiles were not of concern. The samples were targeted at the depth of previous reported contamination and no sample descriptions were provided. This has been considered in the review of the results. RAP: Field screening includes visual and olfactory observations. It is also understand that a PID is being used to screen the excavations.

Sampling Logs Delineation Sampling: Soil logs for each delineation location was provided outlining soil stratigraphy and sample collection depth. RAP: In the final report descriptions of the validation samples and the surface in general should be provided.

Table 6.2: QA/QC – Field and Lab Quality Assurance and Quality Control

Field and Lab QA/QC Auditor Comments

Holding Times Delineation Assessment: A review of the chain of custody forms and laboratory reports indicates that most samples were submitted within holding times. Samples collected from BD50 (1), BD51 (1) BH12 (2), BD35, BD11 (1) and BD38 (1) exceeded the holding time by 4 to 6 days. Coffey note that there is ‘the possibility that these soils are impacted with contaminant of concern can not be dismissed’. Three of the seven samples will be targeted for remediation. The Auditor notes that as further validation is proposed following remedial works in three of the locations and that numerous samples were collected in the vicinity of BD50 and BD51, the exceedances are not considered to affect the conclusions.

Field quality control samples

Delineation Assessment: Field quality control samples proposed include intra-laboratory duplicates (10%), inter-laboratory duplicates (5%) and rinsate blank. Trip blanks and trip spikes were not submitted for analysis. RAP: Field quality control samples proposed include intra-laboratory duplicates (10%), inter-laboratory duplicates (5%), rinsate blank (1




Table 6.2: QA/QC – Field and Lab Quality Assurance and Quality Control Field and Lab QA/QC Auditor Comments

per day if non-disposable equipment used) and a trip blank and trip spike (where volatiles are analysed).

Field quality control results Delineation Assessment: RPDs were elevated for most of the duplicate pairs submitted for TPH analysis that reported detections. Coffey attribute this to soil heterogeneity. Coffey consider that the results for five of the pairs ‘should be treated with caution as values are marginally below the adopted criteria’. The Auditor notes that one intra-laboratory sample pair reported elevated concentrations in the primary while the duplicate was non-detect. Other results reported were elevated and were within similar magnitudes between samples. Given the magnitude of the criteria for long term workers and the results the Auditor does not consider these results to affect the conclusions. Zinc was reported in one wash blank at 0.007 mg/L. Coffey consider that the zinc was already present in the water. The reason for the detection is not clear and the Auditor considers that cross-contamination of zinc is low. RAP Data quality objectives will need to be set prior to the works.

NATA registered laboratory and NATA endorsed methods

Delineation Assessment: Laboratories used include SGS (primary) and MGT (secondary).The laboratory certificates were NATA stamped. RAP Laboratories to be used include SGS (primary) and MGT (secondary). Coffey note that the analysis would be undertaken by a NATA accredited laboratory.

Practical Quantitation Limits (PQLs)

Delineation Assessment: PQLs were less than the threshold criteria for the contaminants of concern. RAP PQLs should be less than the threshold criteria for the contaminants of concern. Given soil sampling is proposed this is unlikely to be of concern.

Laboratory Methods Delineation Assessment: Coffey provided a list of the laboratory method codes. SGS provided methodology summaries.

Laboratory quality control samples

Delineation Assessment: Laboratory blanks, laboratory control samples, duplicates, spikes and surrogates spikes were undertaken. RAP Laboratory quality control samples proposed include blanks, spike samples, duplicate spikes, matrix spikes, surrogates and duplicates.

Laboratory quality control results

Delineation Assessment: Laboratory control sample results were adequate. An elevated RPD of 36% for one TPH sample was reported. Laboratory duplicates included samples that were reported at low levels or were not detected above the PQLs. RAP Data quality objectives will need to be set prior to the works

Data Quality Objectives Delineation Assessment: The results were discussed with regard




Table 6.2: QA/QC – Field and Lab Quality Assurance and Quality Control Field and Lab QA/QC Auditor Comments

and Data Evaluation (completeness, comparability, representativeness, precision, accuracy)

to the five category areas. RAP Predetermined data quality objectives (DQOs) were not set. The results of the laboratory analyses will need to be discussed with regard to the five category areas

In considering the data as a whole the Auditor concludes that:

• The concentrations of TPH, particularly in the fraction C10-C14, may be slightly under reported due to exceedances of holding times and the use of a hand auger. The duplicate results also indicate a degree of heterogeneity. Given the magnitude of the TPH concentrations, the Auditor considers that the results are representative of the samples submitted for analysis.

• The data is complete

• There is a reasonable degree of confidence that data is comparable to the previous sampling events, but it is noted that different consultants and different laboratories have been used.

• The primary laboratory provided sufficient information to conclude that data is of sufficient precision

• The data is likely to be accurate.

The Auditor concludes that the sampling and analysis plan is adequate and if implemented is likely to ensure that the data collected is representative, complete and of sufficient precision and accuracy.




7 Environmental Quality Criteria Coffey undertook an on-site health risk assessment (HRA) for the purpose of developing site specific risk based levels (RBLs) for petroleum hydrocarbon impacted soil. RBLs were developed by Coffey for TPH fractions C10-14, C15-28 and C29-36 for non-sensitive commercial land use for various exposures. The RBLs developed by Coffey are outlined in Table 7.1 below.

Table 7.1: Risk Based Levels (mg/kg) developed by Coffey for Petroleum Hydrocarbons

Vapour Inhalation

Direct Contact Vapour Inhalation

Direct Contact Analytes Vapour Inhalation Concrete Slab-on-grade Commercial Premises Unsealed, commercial 1m Deep Sub-Surface

Maintenance Trench

TPH C10-14 >Csat >Csat 18 642 0.261 – 9.05 87 538

TPH C15-28 N/A N/A 13 953 N/A 65 608

TPH C29-36 N/A N/A 13 953 N/A 65 608

>Csat The calculated RBL is greater than the calculated saturated concentration of the chemical in soil based on the soil type at the site N/A Not Applicable – not considered as a contaminant of concern for the exposure scenario.

The RBLs were developed by Coffey using vapour intrusion models provided in the Risk Integrated Software for Clean-Ups (RISC) V4.04 (RISC, 2003). Direct contact pathways were also assessed using RISC. A number of inputs and assumptions were used, not all of which the Auditor agrees with. However as the magnitude of the derived RBLs are consistent with those derived by the Auditor using RISC4, the RBLs are considered to be sufficiently protective of human health under the identified exposure pathways.

The Auditor has assessed the soil data provided by Coffey in reference to

• Soil Investigation Levels for Urban Redevelopment Sites in NSW (SIL Column 4 – ‘commercial/industrial’) in DEC Guidelines for the NSW Site Auditor Scheme (2006).

• EPA (1994) Guidelines for Assessing Service Station Sites for the assessment of BTEX and TPH C6-C9 data.

• RBLs derived by Coffey for the assessment of TPH C10-C36.

Coffey note that the validation results would be considered in reference to

• Health Investigation Levels (HILs) - Column F - ‘Commercial or Industrial) as outlined in the National Environmental Protection Council (NEPC) (1999) National Environment Protection (Assessment of Site Contamination) Measure.

• EPA (1994) Guidelines for Assessing Service Station Sites for assessing TPH C6-C9 and BTEX results.




• RBLs for TPH C10-C36.

Coffey note that any imported materials must satisfy the virgin excavated natural material (VENM) requirements of the NSW DECC. The Auditor notes that the NSW DECC (2008) Waste Classification Guidelines, Part 1: Classifying Waste classifies VENM as “…natural material

• ‘that has been excavated or quarried from areas that are not contaminated with manufactured chemicals or process residues, as a result of industrial, commercial, mining or agricultural activities, and

• ‘that does not contain sulphidic ores or soils, and includes excavated natural material that meets such criteria for virgin excavated natural material as may be approved for the time being pursuant to an EPA gazettal notice.”

On this basis, the Auditor considers that for soil to be classified as VENM, the following criteria generally apply:

• Organic compounds (including petroleum hydrocarbons, PAHs, OCPs, PCBs, Phenols) should be less than the LORs; and

• Inorganic compounds should be consistent with background concentrations.

Coffey note that ‘soils heavily impacted by TPH (i.e. visible free product or surface staining) should be remediated. The Auditor will consider the need for remediation based on the ‘aesthetic’ contamination as outlined in the NEPM (1999) Schedule B(1) Guideline on the Investigation Levels for Soil and Groundwater that states that ‘there are no numeric Aesthetic Guidelines but the fundamental principle is that the soils should not be discoloured, malodorous (including when dug over or wet) nor of abnormal consistency. The natural state of the soil should be considered’. The Auditor notes that discolouration does not necessarily preclude industrial use.

Coffey note that the criteria for asbestos would be ‘nil fibre detected in the representative surface validation samples collected’. The Auditor notes that there are no national or EPA approved guidelines for asbestos in soil relating to human health. DEC (2006) state that Auditors must exercise their professional judgement when assessing whether a site is suitable for a specific use. The DEC states that the position of the Health Department is that there should be no asbestos in surface soil. Where the samples are representative of the surface then the proposed criteria is considered adequate.




8 Evaluation of Soil Analytical Results Following a review of previous investigation results, Coffey identified areas of ‘known soil contamination’ i.e. samples that reported contaminants above the criteria for commercial/industrial uses. Coffey undertook delineation sampling targeting samples that had previously reported elevated concentrations of TPH C10-C36, copper, zinc and asbestos.

Four locations, 5 m distance from the ‘hotspot’ were sampled. The samples did not target specific activities however were collected at the depth at which previous contamination had been noted. This is consistent for all areas except for the break shoe area where grid sampling was undertaken.

8.1 Wagon Repair Shed (SP2)

The Auditor previously noted that TPH and lead were distributed within and around the shed without noticeable pattern, indicating impacts were sourced from activities prior to sealing. The 95% UCL concentration for all contaminants were below the industrial criteria. Asbestos was detected in 25% of the samples. The consultant had recommended remediation of soil containing TPH and asbestos in the vicinity of the wagon repair shed as discussed in Section 10.

An elevated concentration of copper of 8010 mg/kg had previously been reported (TPH C10-C6 at 1817 mg/kg) in one surface sample below the concrete slab. Four additional samples at the same depth and one at 0.2-0.3 m depth estimated to be directly underneath the previous sample did not report copper above 170 mg/kg. Remedial works are discussed in Section 10.

An elevated concentration of TPH C10-C36 of 16166 mg/kg was reported in one surface sample outside of the building footprint. It is understood that additional delineation samples were collected however these were not tabulated in the report. Remedial works are discussed in Section 10.

Asbestos was previously detected in four samples at the southern end and in the mid-section of the Wagon Repair Shed area. Asbestos was detected as fibre bundles in an additional 11 samples during delineation sampling. Coffey noted that soil within the Wagon Repair Shed footprint/curtilage has been impacted by asbestos which is limited to surficial and shallow soils (<0.4 m BGL).

The Auditor notes that the further sampling results suggest that asbestos appears to be associated with the gravely sands (0.3 m) rather than extending into the underlying clays however the lateral extent of asbestos impacted material is not clear. Remedial works are discussed in Section 10.

8.2 Suspected Asbestos Break Shoe Burial Area (SP3)

Sydney Ports previously encountered asbestos break shoes in the southern section of the site, which have since been removed. There was concern that this area had been used a burial area for the break shoes. The borehole logs provided no visual indications of the burial of asbestos break shoes with only gravel, clay and sand fill noted to approximately 1.5 m. Only one of the forty four samples (0.1 m) reported the presence of asbestos, which was in a




plaster fragment (fibro). The detection of asbestos was at the surface which Coffey note may be due to fly tipping.

Coffey conclude that as only one of the 44 samples reported asbestos and as this was in a fragment of fibro that remedial work were not required. The Auditor agrees that break shoes were buried in this area and that no further works are required.

8.3 TPH (SP4)

The Auditor (GN 34) undertook a review of investigations undertaken in the late 1990s in consideration of some historical results and in reference to EPA guidelines. The Auditor noted that TPH had been reported at concentrations that potentially presented a risk. However, as most of the TPH occurred between the railway tracks, the potential for prolonged exposure of workers was very low. Further risk assessment or removal of TPH in shallow soils was recommended.

Coffey (2009) have since derived Risk Based Levels (RBL) for long term workers and have undertaken additional investigations to confirm the magnitude of TPH C10-C36 at previously identified locations of elevated concentrations.

Sampling had previously targeted the potentially contaminating activities and the results indicated that soils had been impacted by TPH. This includes the locomotive fuelling point, former AST area, tracks and turntable, the south side near the (underground) stormwater drain location and the load box. Additional sampling was undertaken by Coffey in the vicinity to confirm the magnitude of these concentrations.

Elevated TPH C10-C36 concentrations in soil were detected which are consistent with the historical activities including fuel storage and maintenance. The results are generally less than the RBLs for long term workers, however two results previously obtained at 0.5 m in separate sections of the site had reported TPH C10-C36 at 17000 and 17128 mg/kg (fractions not known) assumed to be above the criteria. Additional samples collected by Coffey in the vicinity of these did not report TPH C10-C36 above the criteria. Remediation works are proposed to address the exceedances of the TPH C10-C36 for long term workers as discussed in Section 10.

Coffey have provided an indication of the location of oil stained surfaces such as the locomotive fuelling point. It was previously noted that most of the staining was between the tracks, particularly near switching locations. The worst stained surfaces were avoided during sampling however remediation of these stained areas is proposed as discussed in Section 10.

Previous results at and down-gradient of the load box reported slightly elevated concentrations of TPH C10-C36 (maximum of 5700 mg/kg) at depths of 2 to 3 m near the base of the fill with no detections in the shallow samples. These results indicated either migration from an upgradient source such as the load box or trackway area, or burial of contaminants. Additional testing undertaken by Coffey at BH36 at depths of 3 and 3.3 m approximately 5 m from the earlier detections reported TPH at only 310 mg/kg in only one of nine samples. The concentrations are well below the criteria for long term workers. These soils are near the site boundary and Audit (GN 34) had recommended ‘an assessment of off-site migration in areas where TPH had been detected in deep soils near the site boundary’.




TPH C10-C14 was reported at concentrations well above the RBL for trench workers. Coffey note that Sydney Ports will manage the TPH C10-C14 contamination in the trenches by implementing a long term Environmental Management Plan (EMP). Further investigation and remediation works will also be undertaken once the proposed locations of the services trenches are known. This is discussed in Sections 10 and 12.

8.4 Filled Areas (SP4)

It was previously established that a solid waste tip was located at the southern end of the site, that ash fill does not contain PAHs at concentrations that would pose a risk to industrial use and that metals were less than the criteria except for copper in one location.

The high copper concentration was detected at BH21 near the locomotive workshop at 14,000 mg/kg. The nearest bores (eg BH26, which has the second highest recorded concentration of 1100mg/kg) also have elevated concentrations but are all further than 50m away. While it was considered likely that the high concentration was a very localised hotspot, this could not be ascertained on the data presented. Additional sampling in the vicinity of BH21 undertaken by Coffey reported a maximum concentration of 1300 mg/kg (TCLP of 0.12 mg/L). The results are consistent with those obtained in the vicinity. Remediation of the ‘hotspot’ is proposed as discussed in Section 10.

8.5 Diesel AST Area (SP4)

As noted in Audit (GN 34) abrasive blasting of the former ASTs is indicated as a potential cause of metals contamination in this area. Zinc was detected at a concentration of 58,700mg/kg in the previous investigation, in the area that is now concrete sealed within the new bunded AST area. The concentrations of copper, lead, zinc and mercury detected in the surrounding area were not significantly elevated, indicating that high concentrations are probably localised within the existing bunded area. Further sampling by Coffey indicated zinc generally below 210 mg/kg with the maximum of 4300 mg/kg detected to the north. These concentrations are below the criteria for industrial uses. Remediation of the ‘hotspot’ is proposed as discussed in Section 10.

8.6 Asbestos (SP4) Six samples were previously analysed for the presence of asbestos, and it was detected in one sample. Egis state that “the possibility exists for other areas of asbestos contamination to exist…”. The Auditor agreed. Coffey undertook further sampling in the vicinity of this sample. Asbestos was not detected. Remediation to address oil stained soil is proposed in this area.




9 Evaluation of Groundwater Analytical Results Groundwater investigations were undertaken previously in the former marshalling yards and the Delec site.

The Audit (GN 9) prepared in 1999 concluded that ‘it is probable that metal concentrations in the fill are impacting the quality of the perched water’. ‘The concentrations [of petroleum hydrocarbons] are very low and the distribution indicates that they are not related to site activities’.

The Audit (GN 34) prepared in 2002 for the Delec site concluded that ‘No significant contamination has been detected in groundwater wells. Some metal concentrations exceed trigger values but they cannot be linked to on-site sources. While there are no indications of widespread TPH contamination, the potential for groundwater contamination cannot be eliminated while significant sources remain’.

Further groundwater assessment is proposed prior to the remedial works to determine the potential risks from contaminated soil and with respect to off-site migration and current DECC groundwater guidelines. The groundwater assessment in relation to the proposed remedial works is discussed in Section 11.




10 Evaluation of Remediation 10.1 Remediation Strategy and Methodology

The remedial works proposed are summarised in Table 10.1.

Table 10.1: Evaluation of Remediation Description Extent of Remediation Required Preferred Options

SP2

Asbestos under the wagon repair shed

Entire building footprint and curtilage as shown on a site plan to a minimum depth of 0.4 m BGL.

Copper hotspot under the wagon repair shed

Will be targeted as part of the asbestos extent discussed above.

TPH C10-C36 hotspot under the wagon repair shed

Hotspot extending to 0.3 m depth and in a 2.5 m radius.

Arsenic hotspot in marshalling area

Depth of 0.3 m and 5m radius

Excavate and landfarm (only TPH impacted soils), retain in a containment cell or move and cap and contain in SP4 If free oil impacted material (visual) or readily leachable materials are encountered – excavate and dispose off-site. The Auditor notes that the consolidation of material is desirable, where possible.

SP4

TPH hotspots in Delec

Depth of between 0.7 and 1.5 m and 5 m radius based on previous analytical results.

TPH stained soils in Delec

Horizontal and vertical extent based on visual observations. Some indications are provided on Figure 5A of the RAP. This will also address some asbestos detected at one of these locations.

Zinc hotspot in Delec Depth of 0.7 m and 5m radius

Copper hotspot in Delec

Depth of 0.7 m and 5m radius

In-situ capping with 200 mm of fill and 500 mm of impermeable pavement. Fill would be suitably validated and paving is to consist of concrete, bitumen or a mixture of both. In areas outside of capping - excavate and landfarm (only TPH impacted soils), or place in a containment cell or move and cap and contain in SP4. The extent of capping not yet known. If free oil impacted material (visual) or readily leachable materials are encountered – excavate and dispose off-site.

USTs located to the south of SP1.

Excavate fuel impacted soils from underneath the USTs to 0.2 m from the base and the walls.

Excavation and off-site disposal or landfarming of associated impacted materials.

Oil impregnated concrete

Remove from Buildings 1 and 14 as found to be leachable. The extent not discussed.

Off-site disposal or on-site containment. No details on the containment cell are provided.

TPH stained surfaces in track

Horizontal and vertical extent based on visual observations.

In areas outside of capping - excavate and place in a containment cell or move and




Table 10.1: Evaluation of Remediation Description Extent of Remediation Required Preferred Options

areas cap and contain in SP4 If free oil impacted material (visual) or readily leachable materials are encountered – excavate and dispose off-site.

SP5

TPH stained surfaces in SP5

Horizontal and vertical extent based on visual observations.

In areas outside of capping - excavate and place in a containment cell or move and cap and contain in SP4 If free oil impacted material (visual) or readily leachable materials are encountered – excavate and dispose off-site.

All Areas

Fly tipped material Unknown, required if identified in the field

In areas outside of capping - excavate and place in a containment cell or move and cap and contain in SP4 If free oil impacted material (visual) or readily leachable materials are encountered – excavate and dispose off-site.

Building Footprints Demolition of buildings and removal of surfaces

Validation as discussed in Table 10.2

Stockpiles All stockpiles Validation and management as discussed in Table 10.2.

It is understood that concrete, stained with TPH and with asbestos attached to the underside, is stockpiled on-site. The RAP notes that the concrete would be placed in a containment cell.

The RAP does not indicate which materials have ‘free oil impacted material’ or are readily leachable but a plan of management has been provided. Validation works will need to ensure that these two validation criteria are screened for.

Remedial works are proposed to target the known elevated concentrations (hotspots) with the depth and radius to be refined during the works. The Auditor notes that other elevated concentrations may be present. Given the sampling density it is likely that these would be limited in extent and frequency. Further validation is proposed in the RAP following the removal of the buildings and surfacing that would provide confirmation.

Excavations to address visually identifiable impacts, such as stained soils associated with the rail tracks, will be extended based on visual indicators. Further details regarding the proposed validation works are discussed in Table 10.2.




It is understood that the USTs have been excavated and that the associated impacted materials are currently stockpiled on-site. The Auditor notes that the validation report will need to provide details on how the extent of the excavation was determined (visual, odours, PID readings) and the results of those observations. Details on removal of the USTs will also be required. It is understood that the excavated material had a solvent smell. Validation sampling will need to consider VOCs in addition to petroleum hydrocarbons.

Landfarming of TPH impacted soil will involve the break down of lumps and spreading of the material to be no greater than 1 m in thickness to increase surface area. Aeration by periodic turning would be undertaken. Validation sampling will determine whether additives need to be applied to stimulate biological activity. The Auditor notes that the consultant should be able to demonstrate that biodegradation is occurring.

Services at the site are likely to occur at between 1 and 2 m below the final surface layer. Once the locations of the services are finalised, the corridors would be assessed using existing and new data and remediated where necessary. Remediation would include excavation and placement of the materials in the SP4 Area under the cap.

The RAP notes that ‘a groundwater risk assessment and a groundwater monitoring program’ would be required. The monitoring program is to include monitoring during (2 rounds) and following (2 quarterly and then two half yearly) the remediation works. The Auditor understands that further details are included in a plan for additional groundwater assessment prepared separately by Coffey. The groundwater assessment needs to provide adequate coverage, confirm groundwater level depths and flow paths and include at least two sampling rounds.

Depending on the groundwater results, the contingency plans include the containment of materials in appropriately designed containment cells, off-site disposal and/or the allowance for on-going regular groundwater monitoring. If groundwater impacts are identified, the potential for off-site migration would be assessed and appropriate measures taken where required.

The Auditor considers that the preferred options are adequate.

10.2 Evaluation of Remedial Action Plan

The Auditor has assessed the RAP by comparison with the checklist included in the EPA (1999) “Guidelines for Consultants Reporting on Contaminated Sites”. The RAP was found to address the required information as detailed in Table 10.2.

Table 10.2: Evaluation of Remedial Action Plan Remedial Action Pan Comments

Remedial Goal ‘To remediate areas containing unacceptable levels of contamination such that human health risks are reduced to acceptable levels commensurate with the proposed land use (commercial/industrial)’. In the Auditor’s opinion, this goal is considered adequate. Groundwater has not yet been assessed for the potential to migrate off-site or to groundwater.





Proposed Validation Testing – Sampling

Services – The RAP notes that ‘it is prudent to remediate and validate’ the service corridors prior to construction. The contaminant status would be assessed using a combination of existing and new data if required. Excavated Hotspots: Visual assessment followed by one base and four wall samples at the depth of contamination. Additional samples may be required depending on the extent of the final excavation and visual/olfactory observations. Analytical suite will be limited to the contaminant of concern. Demolished Rail Track: - Visual, olfactory and PID screening assessment (free oil, staining, discolouration, odours, asbestos containing materials). 70 surface soil samples evenly distributed considering the likely impacts and the estimated uniform distribution of contaminants. Additional samples would be targeted to observed contamination locations. Analytical suite to include TPH C10-C26 and asbestos. Demolished Building Footprints - Visual, olfactory and PID screening assessment (free oil, staining, discolouration, odours, asbestos containing materials). Where there is evidence of contamination, surface soil samples would be collected. Sample numbers are given in the RAP. The Auditor notes that the observed contamination should be targeted for analysis. Analytical suite to include metals, TPH C10-C36, asbestos and to a lesser extent PAHs, OCPs, VOCs and PCBs. Wagon Repair Shed: Visual assessment. Validation sampling along the walls (1 per 10 linear metres) and base (20 samples) of the excavation. Samples would be submitted for asbestos analysis. The Auditor notes that the visual assessment would also need to be systematic with the excavations extended where required, noting that asbestos fibres can not be visually delineated. Intra-laboratory duplicate samples would be submitted at a rate of 1 per 10 samples or intra-laboratory duplicates at a rate of 1 per 5 samples. Pedestrian Footbridge: Four surface samples for lead and zinc. The Auditor notes the approach is adequate assuming that the final surfaces are visually uniform. USTs: Validation not discussed. An adequate density of testing and field observations will be required. The Auditor notes that validation sampling will need to consider VOCs in addition to petroleum hydrocarbons.

Management of Stockpiles

Stockpiles will be tracked in accordance with the Remediation Contractor’s Stockpile Tracking System outlined in their CEMP. This includes noting the source, volume and destination of the material. The CEMP provides a tracking form for this.

Re-use of Ballast and On-Site Fill Material and Imported Materials

Ballast Stockpile (sourced from track areas): Visually evident fines would be sampled such that spatially representative samples are collected. If fines are present, the sample density would be 1 per 100 m3 with a minimum of 4 per stockpile. This





may be changed depending on the volume and homogeneity of the stockpiled material to determine suitability for re-use or whether off-site disposal is required. Samples would be collected 0.2m beneath the surface. Analytical suite to include TPH and asbestos (additional analytes may be required based on visual assessment). If ‘significantly stained’ then cleaning would be required. Coffey note that where the results meet the criteria and where there is not ‘significant staining’ then the ballast may be suitable for re-use on site. Given the difficulty in sampling ballast (also stained) the Auditor considers it prudent that the materials be cleaned prior to any re-use. Re-use of On-site Fill Material: Visual assessment and 1 per 100 m3 with a minimum of 4 per stockpileThe sampling density will depend on the volume and homogeneity of the material. Analytical suite to include metals, PAHs, TPH C6-C9 and TPH C10-C36, BTEX and asbestos The Auditor notes that the sampling densities are adequate where the materials are relatively homogenous and the sources are known. Material excavated from SP1 was stockpiled at the site. It is understood that the material is impacted by petroleum hydrocarbons and asbestos. It is understood that the material would be validated or remediated in accordance with the other contaminated material at the site. Imported Material: VENM Visual assessment of the source site and ‘spatially representative soil samples’ Analytical suite to include metals, PAHs, TPH C6-C9 and TPH C10-C36 and BTEX. The list will depend on the historical source site use and visual assessment. The Auditor notes that any imported materials would need to be accompanied by adequate documentation and an adequate sample density determined based on information provided.

Long-term engineering security of works

Cell to be excavated to 2.2 m x 70 m x 30 m, filled with impacted materials (ensuring geotechnical requirements are met) (soil first and followed by impacted concrete) and covered with a permeable marker layer. It is understood that the cell is now to be split to avoid a stormwater line (Appendix A, Attachment 5) RAP indicates that the cell would be covered with a mix of ash and ballast (deemed not contaminated) on the compacted material bringing to design levels. The Auditor notes that remediation of ash was not required based on the previous results however if ash is to be used as clean capping, adequate validation will be required. This is considered adequate for the long term engineering security.





Validation of the containment cell and cap

Survey of the base of the cell, the marker layer of the final surface of the impacted materials and the finished levels of the cap. The RAP indicates that the survey of the surface levels before and after capping or drilling through the cap on a grid basis to assess the thickness would be undertaken. The Auditor notes that survey is preferable especially given the requirements to re-instate the cap. A plan indicating the location of the containment cell will be provided in the EMP. This is considered adequate. The Auditor notes that a survey of the cap thickness over SP4 would also be required to validate the suitability of the cap.

Long-term integrity of the cap i.e. risk of the erection of structures on the capped area

The proposed containment area is to be located over an existing stormwater culvert. It is understood that the culvert is located at 7 m depth BGL and that maintenance is unlikely and if required, would not be accessed from the surface. Sydney Ports indicate that the site will eventually be sealed with concrete and form part of the railway marshalling yards reducing the risk of the erection of structures that may penetrate the cap. The in-situ materials will be retained in SP4 with concrete and bitumen pavement to be placed over the cap. The final site use must ensure the long-term integrity of the cap by implementation of a long term EMP.

Long-term minimisation of the potential for leachate formation and/or volatilisation and/or off-site migration.

Not specified in the RAP however it is understood that asbestos impacted materials with some TPH contamination would be retained. The RAP notes that any materials retained would be ‘demonstrated to not pose a significant risk of groundwater contamination’. It is understood that leachate testing (with water) has been undertaken for TPH. Where materials are not leachable, it is good practice to have good drainage in any case so that water does not pass through the cell. The Auditor notes that the current design of the containment cell is adequate to retain contaminants that do not generate leachate or volatiles however the base of the cell should be compacted to ensure this. If materials are contained on-site that are leachable, the validation report will need to demonstrate that the containment cell is adequate to minimise leachate formation in the long-term. The containment cell is to be located above the depth of water flow through the culvert which is understood to be at 7 m depth below ground level.

Contingency Plan if Selected Remedial Strategy Fails

The contingency plan if material cannot be placed within the cell (due to limited space) the material is to be disposed of off-site. If capping is not suitable due to: - potential to impact groundwater (following interpretation of the groundwater results) - potential to cause prohibitive costs to construct works - contaminant characteristics not being suitable for capping (following leachate tests) - physical limitations on the quantity of material that can be capped in





SP4 then the material may be disposed of off-site. The excavation of hotspots and stained material will be ‘refined during excavations’. The Auditor notes that the cell will need to ensure the long term minimisation of leachate.

Contingency Plans to Respond to site Incidents. Site Management Plan for the Operation Phase.

The CEMP includes monitoring, corrective actions and an emergency response plan in response to incidents.

Interim Site Management Plan (before remediation)

Not Applicable

Site Management Plan (operation phase) including stormwater, soil, noise, dust, odour and OH&S

The RAP provides an outline of the inclusions in the CEMP prepared by the contractor and requirements for OH&S. The CEMP was provided to the Auditor and provides a process to manage the operational phase of the site works.

Remediation Schedule and Hours of Operation

Works will commence in June 2009 within the hours of 700 and 1800 hours Monday to Friday and 800 hrs to 1300 hrs on Saturday with no work on Sundays. It is due for completion in August 2009.

Licence and Approvals Off-site disposal will include classification in reference to the NSW DECC (2008) Waste Classification Guidelines. The CEMP indicates that approvals have been obtained under Part 3A of the EP&A Act and Workcover (demolition and removal of asbestos)

Contacts/Community Relations/

Key stakeholders were provided. Contacts and emergency contacts are provided in the CEMP. The CEMP notes that a Community Consultation Plan has been prepared by Sydney Ports and provides a summary.

Long term site management plan

The RAP notes that a long term EMP will be required. The EMP will need to document the final condition of the containment cell and provide controls for any excavation. Given that only 200 mm of fill is located below the pavement sub-grade the EMP should provide commensurate management of risk. The RAP indicates that the EMP will need to address the vapour inhalation risk to the workers constructing and maintaining the corridors. The management requirements will need to be realistic and enforceable.

The Auditor considers that the design of the containment cell is adequate to retain contaminants that do not generate leachate or volatiles, in the long-term, subject to implementation of a long term management plan. While the Auditor does not have any objections to the construction of the containment cell, Sydney Ports should obtain confirmation from the culvert owner regarding maintenance requirements to ensure the long term integrity of the cell. The results of testing for materials to be retained within the cell should be provided to the Auditor prior to placement.




The Auditor considers that the overall remediation approach is adequate to achieve site suitability for protection of human health, subject to implementation of a long term management plan. Groundwater has not yet been fully assessed.




11 Contamination Migration Potential Groundwater is not considered in the RAP objectives.

The Audit (GN 34) previously noted that ‘TPH has not been detected in the current investigation in the well samples. The Auditor notes that TPH contamination has been detected in soils at 3 m depth generally near the base of fill overlying clay, which probably indicates migration from an upgradient source. The Auditor also notes that there are no wells ideally placed to detect migration from the areas where deep contamination is found and that some of these areas are near the down-gradient site boundary. The potential for some, though probably not widespread, migration exists. The potential for migration is reduced because groundwater flow paths in the fill appear to be intermittent and unconnected’.

It is understood that further groundwater assessment is proposed prior to the remedial works to determine the potential risks from contaminated soil and with respect to off-site migration and current DECC groundwater guidelines.




12 Assessment of Risk Based on assessment of the proposed remediation, it is the Auditor’s opinion that the proposed remedial works would reduce the risk to human health to acceptable levels. The actual amount of residual contamination will not be known until the completion of validation. Remaining risk including that posed to trench workers from dermal contact with TPH C10-C14 will need to be managed under a legally enforceable EMP.

Risk based levels were derived by Coffey for TPH only such that a low number of samples require remediation based on concentration data. The magnitudes are consistent with those derived by the Auditor. TPH impacted soil that is inaccessible does not present a risk to human health.

TPH risk based levels derived for trench workers based on an indoor air model indicate that TPH impacted soils on-site present a risk but that the potential risk could be managed by a long term management plan. The risk to human health from the presence of asbestos also needs to be considered under the long term management plan.

The risk could also be mitigated by capping the site and implementing a long term EMP to control excavations below the capped surface. There is the potential for small quantities of asbestos to remain at the site. There is a low risk to human health for excavations beneath the cap, except in the Wagon Repair Shed where there is the potential for higher levels of asbestos and future exposure. This higher risk is to be mitigated by remediation.

12.1 Detailed review of Human Health Risk Assessment

Coffey completed an updated on-site health risk assessment (HRA) (11 March 2009) based on soil sampling results. The purpose of the HRA was to develop site-specific risk based levels (RBLs) for petroleum hydrocarbon impacted soil at the site and to qualitatively assess the potential risks from exposure to asbestos and metal impacts in soil for future on-site receptors based on the future general non-sensitive commercial land use of the site. An assessment of off-site impacts and risks to users of the site under more sensitive land uses was not completed. This section provides the Auditor’s review of the assessment completed by Coffey.

12.1.1 Chemicals of Concern

Given the objectives of the HRA, the chemicals of concern include:

• For quantitative assessment: Petroleum hydrocarbons (measured as TPH fractions. Given TPH fractions < C10 were not detected at the site this included only TPH > C10)

• For qualitative assessment: Metals and asbestos.

12.1.2 Exposure Assessment

The exposure assessment involves the determination of the receptor populations who may be exposed to the chemicals of concern identified for the assessment either in the workplace, at home or during recreational activities and the method (pathway) in which they are exposed.




Exposure Populations

Given the proposed future commercial onsite land use, Coffey identified the following onsite receptor populations:

• Adult commercial workers within a slab-on-grade commercial building

• Adult security workers undertaking security checks at the site

• Adult intrusive maintenance/excavation workers within a 1m subsurface trench

Coffey did not consider transient exposure to occasional visitors to the site as chronic daily exposures are generally considered to represent more significant exposure.

The Auditor considers the potential receptors considered by Coffey to be reasonable.

Exposure Pathways

In identifying the potential exposure pathways at the site, Coffey has noted or assumed:

• A slab on grade construction. i.e. no basement

On the basis of the above, Coffey identified the following potential mechanisms of exposure:

• Volatilisation from soil into indoor air within a commercial building.

• Volatilisation from soil into outdoor air.

• Volatilisation from soil into a subsurface excavation trench.

• Incidental direct contact with contaminated soil.

• Inhalation of particulates of contaminated soil.

The Auditor considers the potential exposure pathways considered by Coffey to be reasonable.

Exposure Scenarios

Considering the exposure pathways and populations identified, the following exposure scenarios were assessed by Coffey:

• Inhalation of vapours from contaminated soil by adult commercial workers in an indoor air space.

• Inhalation of vapours from contaminated soil by adult security workers in an outdoor open space environment.

• Inhalation of vapours from contaminated soil by maintenance or construction workers in a 1 m deep trench.

• Dermal contact and ingestion of contaminated soil by an outdoor security workers.

• Dermal contact and ingestion of contaminated soil by construction and maintenance workers in a 1 m deep trench.

• Inhalation of particulates of contaminated soil by an outdoor security worker.




• Inhalation of particulates of contaminated soil by maintenance and construction workers in a 1 m deep trench.

Exposure Assumptions

The exposure parameters adopted by Coffey as well as the Auditor’s comments and values adopted (where different to those used by Coffey) are outlined in Table 12.1.

Table 12.1: Significant Exposure Parameters Used by Coffey and Auditor’s Comments

Parameter Commercial Worker

Security Worker

Intrusive Worker in 1m

Trench

Auditor Comment

Body Weight (kg) 64 64 64 Acceptable

Lifetime (yrs) 70 70 70 Acceptable

Exposure Duration (ED) (yrs)

30 30 (although model input tables indicate 24 years was actually used)

30 Acceptable however noted that: - 30 year ED acceptable not 24 years - 30 year exposure duration is conservative for a maintenance or construction worker

Exposure Frequency (events/yr)

240 240 10 Acceptable

Inhalation Rate Indoors (m3/hr)

1.25 (equivalent to light activity)

1.25 (equivalent to light activity)

2.5 (equivalent to moderate activity)

Acceptable

Time of exposure (hr/day)

8 8 6 Acceptable

Soil Ingestion Rate (mg/day)

NA 25 100 Acceptable. The Auditor notes that enHealth (2002) soil intake for adults is 25 mg/day. The value used by Coffey for the construction/maintenance worker is therefore not consistent with enHealth but is conservative.

Exposed Skin Area (cm2)

NA 820 (hands only)

3120 (Arms and hands)

Acceptable

Particle Emission (m3/kg)

NA 2.9 x 107 2.9 x 107 Conservative. Auditor has used 1.36 x 109 based on USEPA soil screening guidance1, Regional Screening Levels2 and ASTM3




Table 12.1: Significant Exposure Parameters Used by Coffey and Auditor’s Comments

Parameter Commercial Worker

Security Worker


Trench

Auditor Comment

Soil Adherence Factor (mg/cm2)

NA 0.29 0.29 Non conservative. The Auditor has used a soil adherence factor of 0.51 based on enHealth (2002)

Note: NA – Not Applicable 1 U.S. Environmental Protection Agency. May 1996. Soil Screening Guidance: Technical Background Document, Office of Solid Waste and Emergency Response, EPA/540/R-95/128 2 U.S. Environmental Protection Agency. Region 9. 2008. Preliminary Remediation Goals (PRGs) (Now called Regional Screening Level Table). Available from: http://www.epa.gov/region09/superfund/prg/index.html 3 ASTM. 1995. Standard Guide to Risk-Based Corrective Action Applied at Petroleum Release Sites, ASTM E1739-95

In considering the exposure populations, scenarios and parameters, the Auditor considers that in general the exposure scenarios modelled by Coffey are reasonable although notes that the soil adherence factor used by Coffey is not conservative and could underestimate risks.

12.1.3 Toxicity Assessment

The reference concentrations/doses (RfCs, RfDs) used by Coffey are considered to be up to date and appropriate for use in the assessment.

Coffey have also considered that exposure to the chemicals of concern may also occur from other sources (considered as background exposures). Exposure to background sources were considered by Coffey as:

• 20% of the tolerable concentration was allocated to the contaminated site for exposure to vapours

• 25% of the tolerable daily intake was allocated to the contaminated site for direct exposure to soil

This adjustment is considered reasonable.

12.1.4 Acceptable Levels of Risk

As petroleum hydrocarbons are the only COC for quantitative assessment, only threshold risks were assessed by Coffey. Coffey has considered a Hazard Index (HI) less than 1 as representative of an “acceptable” risk.

12.1.5 Data and Calculations

In order to develop RBLs, historical site data was not applicable other than in assessing the hydrocarbon fractions present and the ratio of the fractions. Coffey did not collect any additional data specifically for use in the risk assessment. An assessment of the data quality and data usability was completed by Coffey and also as part of this review (Section 6 of this SAR).




12.1.6 Modelling Inputs and Assumptions

Model Used

Coffey used a vapour intrusion model provided in the Risk-Integrated Software for Clean-Ups (RISC 2003 V4.03) to assess potential vapour risks. Within the RISC package there are a number of models available for assessing different exposure scenarios. Coffey used the Dominant Layer Model within RISC which is a variation of the original Johnson and Ettinger Model known also as the Johnson, Kemblowski and Johnson (1999) model or for assessing vapour intrusion. An outdoor air “Box Model” (within RISC) was used for assessing vapour intrusion into outdoor open space air. For assessment of vapour intrusion into a 1 m subsurface trench Coffey have also used the indoor air model. The approach adopted by Coffey is conservative however it is not considered appropriate for assessing vapour inhalation risks in a 1m trench given the indoor air model includes advection and a low air exchange rate. Use of a modified outdoor air model would be considered more appropriate.

Relevant calculations were presented in the report and are considered appropriate.

The Auditor used the Risk-Integrated Software for Cleanups (RISC) Version 4.03 in review of the risk assessment.

Model Inputs

Table 12.2: Model Inputs Coffey and Auditor Comments Parameter Commercial

Worker Security Worker


Trench

Auditor Value / Comments

Distance from building to source (m)

0.01 – 3.9 Based on 3 separate soil layers assessed

0.01 – 3.9 0.01 – 3.9 Assumes no basement. Auditor considered only situation where contaminated soil directly beneath slab at 0.1 m (as most conservative scenario)

Cross sectional area of building (m2)

150 NA 4.0 As no existing building on the site, the default size (10m x 10m) based on USEPA (2004) 1 has been used by the Auditor. Not considered suitable to assess trench worker using an indoor air model

Volume of building (m3)

400 NA 4.0 As no existing building on the site, the default volume (244 m3) based on USEPA (2004) 1 has been used by the Auditor. Not considered suitable to assess trench worker using an indoor air model

Number of air exchanges per

48 NA 48 Auditor has used CalEPA (2005) value of 1 exch/hour =




Table 12.2: Model Inputs Coffey and Auditor Comments Parameter Commercial

Worker Security Worker


Trench

Auditor Value / Comments

day (exch/day) 24exch/day. for commercial building. It is noted that the USEPA1 default value is 0.25exch/hour = 6exch/day Not considered suitable to assess trench worker using an indoor air model

Foundation thickness (m)

0.1 NA NA Acceptable

Total soil porosity (%) 2

0.28 0.28 0.28 Auditor value = 0.38 based on sand2

Water porosity (%)

0.03 0.03 0.03 Auditor value = 0.054 based on sand2

Soil bulk density 2.0 2.0 2.0 Auditor value = 1.6 based on sand2

Fraction of cracks in foundation (%)

0.1 NA NA Acceptable

Porosity in foundation cracks (%)

0.38 NA NA Acceptable. Based on sand1

Water content in the foundation cracks (%)

0.12 NA NA Auditor has assumed no moisture directly beneath the building as assumes the building is relatively water proof

Height box (m) NA 2.0 NA Acceptable

Length box (m) NA 10.0 NA Acceptable

Wind speed (m/s)

NA 8.0 NA Auditor has used 4 m/s for a trench worker.

NA – Not Applicable 1 USEPA (2004) – Users Guide For Evaluating Subsurface Vapor Intrusion Into Buildings 2 Given soil to 4.0 m is described by Coffey as “granular fill” the Auditor has assumed soil parameters for sand from USEPA (2004).

The model inputs used by Coffey are generally considered to be appropriate except where noted above.

Sensitivity analyses were performed by Coffey and ENVIRON to assess whether changes in selected modelling parameters and scenarios would significantly affect the results of the risk assessment and the derived RBLs. The sensitivity analysis completed indicated that a broad range of results could be obtained.




It is noted that changes to the following exposure assumptions and model input parameters could potentially mean a decrease in the RBLs (which could mean an increase in the scope of the remediation required):

• An increase in the exposure frequency for a trench worker

• An increase in the area of skin exposed during direct contact pathways

• A decrease in the air exchange rate

• A decrease in the soil moisture content

Based on the RBLs derived for the site, Coffey made the following conclusions relating to potential health risks at the site:

“…it was considered that petroleum hydrocarbon COPC concentrations in excess of the established RBLs in soil at certain locations at the site…may pose an unacceptable health risk to:

• On-site security workers undertaking security patrols where direct contact with surficial soil impact is a complete exposure pathway; and

• On-site maintenance workers within a 1 m deep sub-surface maintenance trench where vapours generated within the sub-surface emitted from a granular fill into a sub-surface structure….”

Qualitative assessment of residual asbestos and metal impact at the site found:

• “…this contamination may pose an unacceptable health risk to future users of the site in the event a complete exposure pathway is established via direct contact pathways and/or inhalation of airborn dust.”

The Auditor has completed a review of the Coffey (March 2009) risk assessment. On the basis of his review, the Auditor considers the conclusions drawn by Coffey (stated above) to be conservative and found that the RBLs derived by Coffey for TPH fractions were of magnitudes consistent with those derived by the Auditor or lower.

TPH risk based levels derived for trench workers based on an indoor air model indicate that TPH impacted soils on-site present a risk but that the potential risk could be managed by a long term management plan. The risk to human health from the presence of asbestos also needs to be considered under the long term management plan.




13 Compliance with Regulatory Guidelines And Directions Guidelines currently approved by the EPA under section 105 of the NSW Contaminated Land Management Act 1997 are listed in Appendix C. The Auditor has used these guidelines.

The investigation was generally conducted in accordance with SEPP 55 Planning Guidelines and reported in accordance with the EPA (1997) Guidelines for Consultants Reporting on Contaminated Sites. The checklist included in that document has been completed and is kept on file. The EPA’s Checklist for Site Auditors using the EPA Guidelines for the NSW Site Auditor Scheme 1998 (December 1999) has also been completed and is kept on file.

The development proposal was declared a Major Project under section 75B(1)(a) of the EP&A Act and conditions of approval by the Minister for Planning were stated in ‘Project Approval Section 75J of the EP&A Act 1979’ File No: 9037344 dated 5 September 2007.

A condition of this approval is that a Site Audit Statement be prepared that verifies that the contaminated areas have been remediated to a standard consistent with the intended land use. The current Audit has been prepared in the interim.




14 Conclusions and Recommendations Based on the information presented in the RAP, conclusions of the previous SAR and observations made on site, and following the Decision Process for Assessing Urban Redevelopment Sites in DEC (2006) Guidelines for the NSW Site Auditor Scheme, the Auditor concludes that the site can be made suitable for the purposes of ‘commercial/industrial’ use if the site is remediated in accordance with the following remedial action plan:

• ‘Remediation Action Plan for Known Soil Contamination Intermodal Logistics Centre @ Enfield’ dated 23 June 2009 by Coffey.

• ‘Construction Environmental Management Plan Demolition and Remediation of the Intermodal Logistics Centre at Enfield – Stage 1B’ dated 8 December 2008 by Enviropacific Services.

Subject to compliance with the following conditions:

• A Site Audit Statement certifying suitability is prepared at the successful completion of remediation.

• A suitable long term Environmental Management Plan is prepared and implemented.

• The Validation Report must include the following:

• Details on the extent of the UST excavation, how this was determined (i.e visual validation, odours, PID readings), sufficient validation results (including VOCs) and tank disposal documentation.

• Observations of the soil following removal of the building footprints and the process by which validation samples were selected.

• Details on how the ballast was prepared (i.e. cleaned) and validated for re-use on-site.

• A discussion on the homogeneity, the sources and the validation sample densities for fill re-used on-site. Where ash is to be used as clean capping, adequate validation will be required.

• Adequate documentation for any imported materials and a commensurate sample density.

• The location and final design of the containment cell (including drainage and compaction of the base).

• A survey of the position and thickness of the cap (cell and SP4).

• Demonstration that the containment cell into which leachable material is placed is adequate to minimise leachate formation in the long-term.

• Confirmation from the culvert owner regarding maintenance requirements to ensure the long term integrity of the cell constructed above it.

• Reference to a realistic and enforceable EMP that provides commensurate management of risk given the remedial works undertaken.

• The risk of migration of contaminants to groundwater has been fully assessed and no further on-site groundwater management or remediation is required.




15 Other Relevant Information This Audit was conducted on the behalf of Sydney Ports for the purpose of assessing the suitability and appropriateness of a plan of remediation, as contemplated in Section 47 (1) (b) (iv) of the CLM Act.

This summary report may not be suitable for other uses. Coffey included limitations in their report. The audit must also be subject to those limitations. The Auditor has prepared this document in good faith, but is unable to provide certification outside of areas over which he had some control or is reasonably able to check.

The Auditor has relied on the documents referenced in Section 1 of the Site Audit Report in preparing his opinion. If the Auditor is unable to rely on any of those documents, the conclusions of the audit could change.

It is not possible in a Site Audit Report to present all data which could be of interest to all readers of this report. Readers are referred to the referenced reports for further data. Users of this document should satisfy themselves concerning its application to, and where necessary seek expert advice in respect to, their situation.



July 2009 Z:\Projects\Sydney Ports\873_ILC Enfield\SAR_873_Enfield RAP_2Jul09.doc

Appendix A: Attachments

Attachment 1: Site LocationAttachment 2: Site Coordinates

Attachment 3: Lot and DP InformationAttachment 4: Site Features

Attachment 5: Proposed Containment Area

Attachment 1: Site Location

Attachment 2: Site Coordinates

Attachment 3: Lot and DP Information

Attachment 4: Site Features




Appendix B:Soil Criteria

Soil investigation levels for urban development sites Department of Environment and Conservation NSW (April 2006)

Health-based investigation levels1 (mg/kg) Provisional phytotoxicity-

based investigation

levels2 (mg/kg)

Residential with gardens and accessible soil (home-grown produce contributing < 10% fruit and vegetable intake; no poultry), including children’s day-care centres, preschools, primary schools, townhouses, villas (NEHF A)3

Residential with minimal access to soil including high-rise apartments and flats (NEHF D)

Parks, recreational open space, playing fields including secondary schools (NEHF E)

Commercial or industrial (NEHF F)

Substance

Column 1 Column 2 Column 3 Column 4 Column 5 Metals and metaloids

Arsenic (total) 100 400 200 500 20 Beryllium 20 80 40 100 – Cadmium 20 80 40 100 3 Chromium (III)4 12% 48% 24% 60% 400 Chromium (VI) 100 400 200 500 1 Cobalt 100 400 200 500 – Copper 1,000 4,000 2,000 5,000 100 Lead 300 1,200 600 1,500 600 Manganese 1,500 6,000 3,000 7,500 500 Methyl mercury 10 40 20 50 – Mercury (inorganic)

15 60 30 75 15

Nickel 600 2,400 600 3,000 60 Zinc 7,000 28,000 14,000 35,000 200

Organics Aldrin + dieldrin 10 40 20 50 – Chlordane 50 200 100 250 – DDT + DDD + DDE

200 800 400 1,000 –

Heptachlor 10 40 20 50 – PAHs (total) 20 80 40 100 – Benzo(a)pyrene

1 4 2 5 –

Phenol6 8,500 34,000 17,000 42,500 – PCBs (total) 10 40 20 50 –

Petroleum hydrocarbon components7 > C16–C35 (aromatics)

90 360 180 450 –

> C16–C35 5,600 22,400 11,200 28,000 – > C35 (aliphatics)

56,000 224,000 112,000 280,000 –

Soil investigation levels for urban development sites Department of Environment and Conservation NSW (April 2006)

Health-based investigation levels1 (mg/kg) Provisional phytotoxicity-

based investigation

levels2 (mg/kg)

Residential with gardens and accessible soil (home-grown produce contributing < 10% fruit and vegetable intake; no poultry), including children’s day-care centres, preschools, primary schools, townhouses, villas (NEHF A)3

Residential with minimal access to soil including high-rise apartments and flats (NEHF D)

Parks, recreational open space, playing fields including secondary schools (NEHF E)

Commercial or industrial (NEHF F)

Substance

Column 1 Column 2 Column 3 Column 4 Column 5 Other

Boron 3,000 12,000 6,000 15,000 –8 Cyanides (complex)

500 2,000 1,000 2,500 –

Cyanides (free) 250 1,000 500 1,250 –

1 The limitations of health-based soil investigation levels are discussed in Schedule B(1) Guidelines on the Investigation Levels for Soil and Groundwater and Schedule B(7a) Guidelines on Health-based Investigation Levels, National Environment Protection (Assessment of Site Contamination) Measure 1999 (NEPC 1999)

2 The provisional phytotoxicity-based investigation levels proposed in this document are single number criteria. Their use has significant limitations because phytotoxicity depends on soil and species parameters in ways that are not fully understood. They are intended for use as a screening guide and may be assumed to apply to sandy loam soils or soils of a closely similar texture for pH 6–8.

3 National Environmental Health Forum (NEHF) is now known as enHealth. 4 Soil discolouration may occur at these concentrations. 5 Total mercury 6 Odours may occur at these concentrations. 7 The carbon number is an ‘equivalent carbon number’ based on a method that standardises according to boiling point.

It is a method used by some analytical laboratories to report carbon numbers for chemicals evaluated on a boiling point GC column.

8 Boron is phytotoxic at low concentrations. A provisional phytotoxicity-based investigation level is not yet available. Notes: This table is adapted from Table 5-A in Schedule B(1): Guidelines on Investigation Levels for Soil and Groundwater to the National Environment Protection (Assessment of Site Contamination) Measure 1999 (NEPC 1999). Soil investigation levels (SILs) may not be appropriate for the protection of ground water and surface water. They also do not apply to land being, or proposed to be, used for agricultural purposes. (Consult NSW Agriculture and NSW Health for the appropriate criteria for agricultural land.) SILs do not take into account all environmental concerns (for example, the potential effects on wildlife). Where relevant, these would require further consideration. Impacts of contaminants on building structures should also be considered.

For assessment of hydrocarbon contamination for residential land use, refer to the Guidelines for Assessing Service Station Sites (EPA 1994).

Threshold Concentration for Sensitive Land Use – Soils Guidelines for Assessing Service Station Site (NSW EPA 1994)

Contaminant Threshold Concentration (mg/kg)

TPH (C6-C9) 65

TPH (C10-C36) 1,000

Benzene 1

Toluene 1.4

Ethylbenzene 3.1

Xylenes (total) 14




Appendix C:EPA Approved Guidelines

Guidelines made or approved by the EPA under section 105 of the Contaminated Land Management Act 1997

(as of 28 March 2007)

Guidelines made by the EPA

• Contaminated Sites: Guidelines for Assessing Service Station Sites, December 1994 - servicestnsites.pdf, 1.3Mb

• Contaminated Sites: Guidelines for the vertical mixing of soil on former broad-acre agricultural land, January 1995 - vertmix.pdf, 149kb

• Contaminated Sites: Sampling Design Guidelines, September 1995

• Contaminated Sites: Guidelines for Assessing Banana Plantation Sites, October 1997 - bananaplantsite.pdf, 586 kb

• Contaminated Sites: Guidelines for Consultants Reporting on Contaminated Sites, November 1997

• Contaminated Sites: Guidelines on Significant Risk of Harm from Contaminated Land and the Duty to Report, April 1999 (revised July 2003) - sroh.pdf, 164kb

• Contaminated Sites: Guidelines for Assessing Former Orchards and Market Gardens, June 2005 - orchardgdlne05195.pdf, 172 kb

• Contaminated Sites: Guidelines for the NSW Site Auditor Scheme (2nd edition), April 2006 - auditorglines06121.pdf, 510kb

• Guidelines for the Assessment and Management of Groundwater Contamination, March 2007 - groundwaterguidelines07144.pdf 604 kb

Note: All references in the EPA's contaminated sites guidelines to the Australian Water Quality Guidelines for Fresh and Marine Waters (ANZECC, November 1992) are replaced as of 6 September 2001 by references to the Australian and New Zealand Guidelines for Fresh and Marine Water Quality (ANZECC and ARMCANZ, October 2000), subject to the same terms.

Guidelines approved by the EPA ANZECC publications

• Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites, published by Australian and New Zealand Environment and Conservation Council (ANZECC) and the National Health and Medical Research Council (NHMRC), January 1992

• Australian and New Zealand Guidelines for Fresh and Marine Water Quality, Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand, Paper No 4, October 2000

EnHealth publications (formerly National Environmental Health Forum monographs)

• Composite Sampling, by Lock, W. H., National Environmental Health Forum Monographs, Soil Series No.3, 1996, SA Health Commission, Adelaide

• Environmental Health Risk Assessment: Guidelines for assessing human health risks from environmental hazards, Department of Health and Ageing and EnHealth Council, Commonwealth of Australia, June 2002

National Environment Protection Council publications

• National Environment Protection (Assessment of Site Contamination) Measure 1999

The Measure consists of a policy framework for the assessment of site contamination, Schedule A (Recommended General Process for the Assessment of Site Contamination) and Schedule B (Guidelines). Schedule B guidelines include:

B(1) Guideline on Investigation Levels for Soil and Groundwater B(2) Guideline on Data Collection, Sample Design and Reporting B(3) Guideline on Laboratory Analysis of Potentially Contaminated Soils B(4) Guideline on Health Risk Assessment Methodology B(5) Guideline on Ecological Risk Assessment B(6) Guideline on Risk Based Assessment of Groundwater Contamination B(7a) Guideline on Health-Based Investigation Levels B(7b) Guideline on Exposure Scenarios and Exposure Settings B(8) Guideline on Community Consultation and Risk Communication B(9) Guideline on Protection of Health and the Environment During the Assessment of Site Contamination B(10) Guideline on Competencies & Acceptance of Environmental Auditors and Related Professionals

Other documents

• Guidelines for the Assessment and Clean Up of Cattle Tick Dip Sites for Residential Purposes, NSW Agriculture and CMPS&F Environmental, February 1996

• Australian Drinking Water Guidelines, NHMRC & Natural Resource Management Ministerial Council of Australia and New Zealand, 2004

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