ATA Environmental - MRA · ATA Environmental _____ A review of contamination identified in previous investigations and additional investigations by ATA for inclusion in a Public Environmental

ATA Environmental ________________________________________________________________________________

TABLE OF CONTENTS

1. INTRODUCTION ............................................................................................................ 1

1.1 Background .............................................................................................................. 1 1.2 Purpose..................................................................................................................... 1 1.3 Nature and Extent of Contamination........................................................................ 2

1.3.1 Soil (including Waste Fill) Contamination Overview..................................... 3 1.3.2 Comparison to Contaminants in Helena West Waste Fill ............................... 4 1.3.3 Groundwater Contamination Overview .......................................................... 5

2. AIR QUALITY ISSUES .................................................................................................. 7

2.1 Overview.................................................................................................................. 7 2.2 Potential for Emissions ............................................................................................ 7 2.3 Potential Contaminants in Air.................................................................................. 7 2.4 Potential Receptors - Surrounding and Onsite Land Use......................................... 8

2.4.1 Helena East and the Southern Embankment ................................................... 8 2.4.2 MIA Containment Area................................................................................. 10

3. MANAGEMENT OF AIR EMISSIONS ....................................................................... 11

3.1 Overview................................................................................................................ 11 3.1.1 Roles and Responsibilities............................................................................. 11

3.2 Dust Management .................................................................................................. 12 3.2.1 Overview ....................................................................................................... 12 3.2.2 Earthworks .................................................................................................... 12 3.2.3 Internal Access Tracks .................................................................................. 13 3.2.4 Off-site Transport of Waste........................................................................... 14 3.2.5 Importation and Placement of Clean Fill ...................................................... 14

3.3 Dust Management – Post Remediation Phase........................................................ 14 3.3.1 Pre-Development Phase ................................................................................ 14 3.3.2 Development Phase ....................................................................................... 15

4. AIR QUALITY MONITORING.................................................................................... 16

4.1 Overview................................................................................................................ 16 4.2 Air Quality Management Objective ....................................................................... 16 4.3 Air Quality Zones................................................................................................... 16 4.4 Siting of Monitoring Stations................................................................................. 17 4.5 Asbestos Fibres ...................................................................................................... 20

4.5.1 Monitoring Program...................................................................................... 20 4.5.2 Analytical Method......................................................................................... 20 4.5.3 Air Quality Standards.................................................................................... 20

4.6 Total Suspended Particulates ................................................................................. 21 4.6.1 Monitoring Program...................................................................................... 21 4.6.2 Analytical Method......................................................................................... 21 4.6.3 Assessment Criteria....................................................................................... 21

4.7 Fine Particulates (PM10) ....................................................................................... 22 4.7.1 Monitoring Program...................................................................................... 22 4.7.2 Analytical Method......................................................................................... 22 4.7.3 Assessment Criteria....................................................................................... 23

4.8 Dust Management Assistance - DusTrak............................................................... 23 4.8.1 Monitoring Program...................................................................................... 23

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4.8.2 Analytical Method......................................................................................... 24 4.8.3 Assessment Criteria....................................................................................... 24

4.9 Metals..................................................................................................................... 25 4.9.1 Monitoring Program...................................................................................... 25 4.9.2 Analytical Method......................................................................................... 25 4.9.3 Assessment Criteria....................................................................................... 25

4.10 Baseline Monitoring............................................................................................... 27 4.11 Visible Nuisance Dust............................................................................................ 27 4.12 Hydrocarbon Monitoring ....................................................................................... 28

4.12.1 Monitoring Program...................................................................................... 28 4.12.2 Analytical Methods ....................................................................................... 28 4.12.3 Air Quality Standards.................................................................................... 28

4.13 Review of Air Quality Monitoring......................................................................... 30

5. CONTINGENCY RESPONSE....................................................................................... 32

5.1 Corrective Action during Remedial Works............................................................ 32 5.2 Notification of Exceedance .................................................................................... 32

6. REPORTING.................................................................................................................. 33

6.1 Regulatory and Auditor Review of DAQMP......................................................... 33

REFERENCES........................................................................................................................ 34

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LIST OF TABLES

1. Onsite Land Use

2. Air Monitoring Equipment

3. Asbestos Criteria

4. TSP Criteria

5. Fine Particulates Air Quality Criteria

6. Heavy Metal Particulates Air Quality Criteria (24 Hour Averages)

7. International Guidelines for Ambient Air Toxics

8. Ambient Air Toxics Criteria 9. Criteria for PAH

LIST OF FIGURES

1. Regional Location

2. Helena East Precinct Location within MRA Area

3. Site Plan with Buildings

4. Soil Locations with Asbestos Identified

5. Land Uses Surrounding Helena East Precinct

6. Indicative Air Monitoring Locations

LIST OF APPENDICES Appendix A Review of Air Emissions Management at Previous MRA Remediation Sites Appendix B Soil Sampling Results Summaries for Helena East Sampling Programs Appendix C Site Classification Assessment Chart for Helena East Appendix D Bureau of Meteorology Monthly Data for Perth Airport Appendix E Table 1 - Summary Statistics for Metals in Soils Appendix F DEC Letter, Dust and Air Quality Management for ANI Bradken Appendix G Example Reporting Forms Appendix H Correspondence Documenting Review of Dust And Air Quality

Management Plan

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1. INTRODUCTION 1.1 Background The Midland Redevelopment Authority (MRA) was established in 2000 and charged with the responsibility of remediating and redeveloping the former Midland Railways Workshops site to create a new mixed use development, which adds to Midland as a major regional centre while retaining the important heritage values associated with the workshops. Several stages of the redevelopment process have been completed and the MRA is now working on the remediation of the Helena-East Precinct. Figure 1 shows the regional location of the site while Figure 2 shows the location of the current development area (Helena East Precinct) in relation to the overall Midland Workshops Development. The Site (Helena East Precinct) is shown on Figure 3, along with historical building names. The proposed remediation of Helena East represents a significant earthworks event that requires a strong commitment to management and dust control. The MRA has demonstrated through its management team that it can undertake similar large scale earthworks whilst ensuring air quality is maintained at the strict standards set by the Department of Environment and Conservation (DEC) (formerly Department of Environment, DoE) and Department of Health (DOH). Remediation activities at the former Midland Railway Workshops have been subject to extensive air monitoring since the first major remedial works were carried out in Area E in April 2002. A review of MRA’s management and monitoring of air quality during the remediation of various parts of the site has been undertaken to summarise MRA’s commitment to managing this important issue. The review includes dust management and air quality monitoring at Area E, Helena West, Area B, C, and D (WAPS), and Helena Street Extension, and is provided in Appendix A. Proactive dust management is a key component as experience has shown that air monitoring alone will not ensure maintenance of air quality. A thorough understanding of effective dust management, together with real time air monitoring, ensures the best outcome. MRA is committed to effective dust management measures in addition to undertaking air monitoring to demonstrate and document that acceptable air quality will be maintained during the remediation program at Helena East. 1.2 Purpose A Dust and Air Quality Management Plan (DAQMP) has been prepared to address the issue of nuisance dust and other adverse air quality impacts during the remediation phase at the Helena East site within the former Midland Workshops area. The objective of the plan is to ensure that nuisance and contaminated dust, including asbestos fibres, is controlled during the remedial works and is minimised to the greatest practical extent in accordance with ALARA (as low as reasonably achievable) principles. Air quality is to comply with regulatory guidelines set for the protection of human health. This DAQMP specifically addresses the following:

measures and practices to minimise the generation of dust; •

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location of air quality monitoring sites; •

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monitoring for fine particulates;

monitoring for airborne asbestos fibres;

monitoring for nuisance dust;

confirmatory monitoring for heavy metal particulates contained within the dust;

monitoring for volatile compounds associated with the removal and remediation of hydrocarbon impacted soils;

identification of target, corrective action and work stoppage levels; and

nomination of contingency measures in the event that air quality approaches or is likely to exceed the nominated target or action criteria.

Section 2 of this document outlines background information, Section 3 details the proposed dust management program, and monitoring is outlined in Section 4. Contingency response to adverse air quality is detailed in Section 5. The following appendices are also included to provide background information: • Appendix A Review of Air Emissions Management at Previous MRA

Remediation Sites. • Appendix B Soil Sampling Results Summaries for Helena East Sampling

Programs. • Appendix C Site Classification Assessment Chart. • Appendix D Bureau Of Meteorology Monthly Data For Perth Airport. • Appendix E Table 1, summary Statistics for Metals in Soils. • Appendix F DEC Letter, Dust and Air Quality Management for ANI Bradken. • Appendix G Example Reporting Forms. • Appendix H Correspondence Documenting Review Of Dust And Air Quality

Management Plan.

1.3 Nature and Extent of Contamination Helena East is the most intensively investigated Precinct in the MRA Workshops site, due to the long history of industrial use of that portion of the site, as well as the variety of potentially contaminating activities that took place there. A total of some 250 locations were tested across Helena East; approximately 10 locations across the Southern Embankment, and 43 at the MIA Containment Area.



A review of contamination identified in previous investigations and additional investigations by ATA for inclusion in a Public Environmental Review (PER) indicates that contamination can broadly be assigned to one of three categories as follows: • Waste Fill deposits from historical dumping at the site (generally comprising bulk soil,

metal fragments, ash, slag, asbestos, and other debris). The Waste fill is present in a thin layer (0.5-1metre thickness) over the majority of site as it was used a as a drainage media on top of the natural clay soils. The fill is present to a depth of several metres on the southern embankment of the whole Helen-East Precinct. The waste fill is characterised by low levels of metal and PAH contamination which tend to be tightly bound to the soils matrix and are therefore not highly leachable. The heterogeneous nature of the fill material means that it is geotechnically unsuitable for conventional construction techniques and needs to be removed where feasible.

• In a number of locations the Waste Fill and the underlying natural soil has been

affected by contamination (typically hydrocarbons) migrating from overlying sources. • Groundwater impacted via migration of contaminants through overlying fill and/or

natural soil. 1.3.1 Soil (including Waste Fill) Contamination Overview The Waste Fill material is characterised by concentrations of a variety of heavy metals that exceed the EIL guidelines, and some asbestos contamination. Soil underlying contaminated fill generally does not exhibit concentrations of heavy metals that exceed EIL guidelines, indicating negligible impact by the overlying fill. In some specific areas the waste fill and the underlying natural soil has been impacted by the migration of one of more of the following compounds through the soil profile: • cyanide; • total petroleum hydrocarbons (TPHs); • the solvents benzene, toluene, ethylbenzene, and xylenes (BTEX); • polycyclic aromatic hydrocarbons (PAHs); and/or • volatile organic compounds (VOCs), including monocyclic aromatic hydrocarbons, and

halogenated aliphatic and aromatic hydrocarbons. In addition to the above compounds, asbestos has been detected in surface soils around the Panel Shop, Copper Shop, Element, Shop Diesel Shed, Electrical Store, Tarpaulin Shop and Plating Shop as shown on Figure 4. This asbestos cement material is considered to mainly derive from asbestos sheeting that clad the former Plating Shop. Asbestos has also been detected in the Southern Embankment. Table B1 (Appendix B) summarises concentrations of heavy metals in waste fill and soil samples from Helena East. Overall, contamination associated with Waste Fill deposits comprises the bulk of soil contamination identified at the site, with an estimated in situ volume of possibly up to 100,000m3 in total identified in the Helena East and Southern Embankment areas. Soil affected by hydrocarbons and/or solvents (i.e. TPHs, BTEX, PAHs and/or minor amounts of VOCs) is also relatively extensive at Helena East and the Southern Embankment, with an estimated in situ volume of 30,000m3 (including 5,000m3 which overlaps with Waste Fill in the Southern Embankment).



Cyanide contamination is very localised and minor. It is only identified at 3 sample locations adjacent to a former cyanide treatment plant area. 1.3.2 Comparison to Contaminants in Helena West Waste Fill For the purpose of identifying the most appropriate air sampling methodology and criteria, the concentrations of contaminants in soil and waste fill measured in samples from Helena East were compared with concentrations in waste fill from Helena West. Tables summarising Helena East soil sampling results are provided in Appendix B. Metals Table B1 (Appendix B) summarises combined results for concentrations of metals in both waste fill and soil samples from Helena East (ATA, 2005). Table B2 summarises concentrations of metals in waste fill from Helena West (ENV, 2003 and EPA, 2003). The ENV (2003) report provided results on the Helena West Waste Fill separately to the Helena West soil. The concentrations of metals in material to be remediated from Helena East are, in general, in the same order of magnitude or lower than those that have been previously remediated from Helena West, with five exceptions. Copper and lead, while each having a similar average concentration in the Helena East results (Table B1) to the Helena West results (Table B2), both have a maximum concentration that is approximately an order of magnitude higher in the Helena-East results than in the Helena West results. The average antimony level for Helena East is an order of magnitude higher with much higher maximum values than Helena West. Total chromium is approximately double the average soil concentration at Helena East. Concentrations of cobalt detected in the Helena East soil range from 2 to 360mg/kg with an average of 14.6mg/kg below both to the EIL criterion of 50mg/kg and the HIL-A criterion of 100mg/kg. Cobalt is not included in the Helena West results. As the nature of the soil contaminants and the proximity to sensitive receptors is similar to that experienced at Helen-West, it is considered appropriate to adopt similar air quality criteria for heavy metals used during the remediation of Helena East. In addition, air quality criteria for other similar sites in Perth will be considered. Cyanide Table B1 (Appendix B) also provides a summary of cyanide results. Cyanide at concentrations above the EIL criterion of 10mg/kg has been detected at 3 locations adjacent to the Tarpaulin Shop, between 0.4mBGL and 1.5mBGL. It is understood that cyanide was used in metal treatment operations and wastewater from these operations was treated in the Waste Water Treatment Plant, which is located in the vicinity of the Tarpaulin Shop. Concentrations of cyanide measured in soil range from 1.3 to 30mg/kg. The average concentration of 9.4 is lower than the DoE (2003) Health Investigation Level for standard residential housing (HIL-A) and is considered to be of minor importance during the relatively short duration (weeks to months) of remedial works, compared with the lifetime assumption used to calculate HIL-A. Given the relatively low concentrations of cyanide detected in soil, it is considered that cyanide poses a very low risk to the public during remedial works and air monitoring is not required.



Asbestos Table B3 (Appendix B) provides a summary of asbestos results by sub area within the Helena East Precinct. Asbestos fibres have been identified in soil in the southern half of Helena East as well as in the Southern Embankment. Fibres are primarily found in buried Waste Fill in these two areas as illustrated on Figure 4. Fragments of this sheeting were visually identified in the area of the shop. ENV reports indicate that within Waste Fill, asbestos is present almost exclusively in the form of chrysotile. Hydrocarbons In contrast to Helena West, significant concentrations of hydrocarbons have been detected in soils from Helena East. Tables summarising Helena East soil sampling results are provided in Appendix B. Total Petroleum Hydrocarbons (TPH) and Polycyclic Aromatic Hydrocarbons (PAH) are summarised on Table B4 (Appendix B). Volatile Organic Compounds (VOC) are summarised on Table B5 (Appendix B). Hydrocarbon contamination in soil is localised, in contrast to the widespread metals contamination at the site. Specific hydrocarbons were detected at the following areas (Figure 3):

Foundry Area – PAH, TPH; • • • •

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Main Blocks (1, 2, 3) – PAH, TPH; Power House Area – TPH; Element Shop – PAH, TPH, xylenes, VOCs (including trichloroethene and tetrachloroethene); Diesel Shed & Refuelling Area – PAH, TPH; and Tarpaulin Shop Area – PAH, TPH, VOCs (including trichloroethene and tetrachloroethene).

Air Quality monitoring to be undertaken during remediation of hydrocarbon contaminated soil is discussed in Section 4. 1.3.3 Groundwater Contamination Overview Hydrocarbon and solvent contamination in groundwater is localised within areas of the site where extensive hydrocarbons and/or solvents were identified in soil, particularly south of the Power House/Element Shop and south of the Tarpaulin Shop. Based on soil and groundwater results for hydrocarbons, it is considered that there may be multiple overlapping plumes of different composition in the vicinity of the Power House/Element Shop, and two separate plumes south of the Tarpaulin Shop. A layer of light non-aqueous phase liquid (LNAPL) comprising hydrocarbon fractions similar to mineral turpentine and degraded diesel was identified in one bore south of the Element Shop. PAHs that exceed the Fresh Waters assessment levels are naphthalene (3 bores) and total PAHs (2 bores). Solvents that exceed the Drinking Water assessment levels are benzene (2 bores), toluene (1 bore), ethylbenzene (2 bores), and xylenes (1 bore); one other bore is likely to exceed the criteria for BTEX, based on detectable concentrations of C6-9 chain-length hydrocarbon material. A variety of VOCs were identified in six bores adjacent to the Power House/Element Shop, predominantly comprising halogenated aliphatic hydrocarbons (including tetrachlorethene, trichlorethene, dichloroethane, dichloroethene, and vinyl



chloride). At three bores, one or more VOCs exceed both Fresh Waters and Drinking Water assessment levels. Although ENV (2004) reported that pesticides were largely undetected in Helena East soils, organochlorine pesticides are present at concentrations exceeding the Fresh Waters assessment levels in the same bore where free-phase LNAPL was identified. The available data suggest that the hydrocarbon and solvent plume south of the Power House/Element Shop has a limited lateral extent within the Shallow Superficial Aquifer. Two hydrocarbon plumes are located south of the Tarpaulin Shop: one to the southeast, by the Water Tank (which was used for diesel storage), and one adjacent the southwest corner of the Tarpaulin Shop. Both plumes extend from the southern portion of Helena East into the Southern Embankment and have a significant lateral extent. Both also appear to be migrating towards the Helena River. TPH in groundwater, derived from an LNAPL source (light non-aqueous phase liquids, which are less dense than water) appears to have migrated through the Upper Clays to the Lower Sands; consequently, contamination is migrating through this material along the upper surface of the Lower Superficial Aquifer. No free-phase NAPL was identified in the affected bores. Widespread low level metal contamination is not considered of significance for air quality.



2. AIR QUALITY ISSUES 2.1 Overview The Proponent recognises the need to control dust emissions during the remediation phase in order to maintain the health and well being of people who are involved in the remedial works and those that work and live in areas adjacent to the site. The location of the site in relation to nearby users is described in Section 2.4. The major potential sources of dust generation will be from earthmoving activities associated with the excavation of contaminated soil. Due to the presence of low levels of contaminants in the fill, special efforts are required to minimise the generation of dust. Dust is generated when there is sufficient wind velocity and frequency to lift fine particles from the ground surface. The susceptibility of the particles to lift is a function of the presence of any ground cover, compaction and the moisture content of the ground. Dust has traditionally been measured as Total Suspended Particles or TSP, which refers to particles that can remain suspended in the atmosphere but not necessarily inhaled into the lung. Recent research has shown that the finer dust fractions (<10 micron) are of greater concern because they tend to remain airborne for longer and are capable of penetrating deeply in to the human respiratory system. As a result TSP measurements tend to be used as an indication of overall dust burden and the nuisance impact of dust emissions while measures such PM10 (the concentration of particulate matter less than 10 micron in diameter) are used when assessing health impacts. The following subsections describe the potential for dust to be generated from the remediation program and the potential human health risks. The proposed monitoring program is outlined in Section 3. 2.2 Potential for Emissions Remediation activities will involve the handling of up to 100,000m3 of low-level contaminated soil that contains levels of heavy metals that are generally in compliance with commercial land use health based criteria. Hydrocarbon based Volatile Organic Compounds (VOCs) are also contained in some soils. Activities will include excavation of the soil, loading into trucks, movement of vehicles on unsealed tracks, temporary stockpiling and placement of clean sand fill. Dust could be generated as a consequence of any of these activities. The severity of dust generation will be a function of the magnitude of earthworks, moisture content of the fill, prevailing weather conditions and the presence of fine particles. High wind speeds may exacerbate the potential for dust generation. VOC’s are volatile compounds which unlike metals will potentially be emitted when soils containing VOC’s are simply uncovered or disturbed in any way. As a result the management and monitoring techniques for VOC contaminated soils require a different approach. 2.3 Potential Contaminants in Air The contaminants identified in the soils to be disturbed are discussed in Section 1. These contaminants may be present in airborne particulate matter or as gaseous phase emissions in



the case of VOCs. The extent of any impact will depend on the extent of contamination, the extent of earthworks and the management measures employed to limit emissions. The criteria proposed for assessing the acceptability of air quality are described in Section 4. 2.4 Potential Receptors - Surrounding and Onsite Land Use 2.4.1 Helena East and the Southern Embankment Helena East and the Southern Embankment area are surrounded by the following land uses (see Figure 5). • North - Railway Reserve and Midland town centre. • South - Helena River floodplain and Helena River. • East - Area E (proposed hospital development) and Areas B, C, D (to be used for

Western Australian Police Service site (WAPS) activities and commercial activities). The CADCOM complex is located adjacent to the central eastern boundary of Helena East.

• West – Former rail yards remediated and subject to future residential redevelopment

(Helena West). Housing is being built in the far western section of Helena West, adjacent to Amherst Road, as part of the Woodbridge Lakes residential development.

The nearest established residential areas are the new housing being constructed in Helena West, approximately 250m to the west of the Helena East Precinct and existing housing located approximately 200m to the north from the northern boundary of the site across Railway Parade in Midland. Semi-rural residences exist approximately 150m-200m south of the southern site boundary but approximately 180m from the nearest earthworks. The closest primary schools are Midland and Woodbridge Primary Schools located approximately 800m both north and west of Helena East, respectively. The majority of the soil to be remediated is located centrally in the precinct and as a result the separation distances between the remediation operation and the sensitive land uses is generally somewhat larger than the distances stated above. Various parties holding lease agreements with the MRA are currently using several buildings within the Helena East site on a daily basis. Several of these leases are due to expire in the next 12 months. A list of buildings being occupied by lessees, their activities and expected period of occupation is presented below. It is noted that the receptors considered include the Helena River, and it is acknowledged that excessive dust reaching the River could create an adverse impact. It is considered that with the high level of dust control planned, nuisance and health concerns to humans are the major concerns. It is considered that the Helena River will be adequately protected given the dust management measures that will be undertaken to protect human health and to avoid nuisance dust. In addition, the Helena River is located to the south of the site, and northerly winds are the least frequent wind direction so that it is unlikely any dust would be blown toward the River on a frequent basis.



TABLE 1 ONSITE LAND USE

Location Tenant Use Lease End

Security Office Security service Workshops Village gate security

ongoing

Former Chief Mechanical Engineers Building

IIBT (International Institute of Business & Technology)

Education development December 2007


CERT (Centre for Excellence in Rail Training)

Railway guard training December 2007


Police Licensing Administration November 2008


ECU Education Purposes Ongoing

Laboratory Building (west end CME Building)

Australian Experiential Learning Centre

Administration Ongoing

Block 1/western end of Block 3

Restorative works contract

Restoration November 2007

Pattern Shop Circa Furniture Fine wood industry incubation program

Ongoing

Eastern Portion of Block 3

Machinery Preservation Club

Restoration & storage of Heritage machinery items

Ongoing

Former Railway Institute Building

Midland Redevelopment Authority (MRA)

MRA Offices Until completion of MRA project (ongoing)

Former Timekeepers Office

MRA / Rail Heritage WA

Railway Workshops Interpretive Centre. Starting point for Workshops tours.

Ongoing

The impact of remediation activities on the various tenancies will be reviewed on a regular basis through the remediation process. Tenants will be advised of the remediation program and possible impacts. As earthworks are going to undertaken on a staged basis, assessment of which buildings will be occupied will be made prior to each stage of earthworks. Air monitoring to assess the air quality experienced by personnel working in the on-site tenancies will be undertaken where there is a reasonable concern that tenants may be impacted, for example at earthworks near the pattern shop. It is not envisioned that monitoring for tenants will be required for small scale excavations where sufficient dust management practices are used (e.g. between Blocks 1, 2 or 3). If valid complaints or concerns are raised then appropriate monitoring will be initiated to assess occupational health targets. In general it is proposed that if remediation will be occurring within 50m of tenants the following measures will be undertaken:

Background occupational health monitoring for 1 week prior to works commencing • • Occupational health monitoring for 2 weeks during earthworks.



Review results of monitoring. If concentrations are below 25% (average) of occupational levels then discontinue monitoring (to be reviewed on a case by case basis). If concentrations are 25% to 100% of occupational levels then continue monitoring and works. If concentrations exceed occupational levels then works shall cease or tenants shall be removed from the impacted environment. For asbestos, if asbestos is not identified then discontinue monitoring. If asbestos is identified continue monitoring.

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It is envisioned that personal samplers will be used to monitor air quality. It is proposed that the asbestos will be monitored when remediation for soils containing asbestos is undertaken, and that Volatile Organic Compounds (VOCs) will be monitored during works in proximity to the Pattern Shop. 2.4.2 MIA Containment Area As part of the remediation process, it is proposed that a containment cell is established on land to the east of the Helena-East Precinct. The cell will be constructed as low hill (12-15 metres above existing grade) with waste being placed in compacted in layers and then capped with clay to form a stable non-eroding landform. The location of the MIA bund is shown in Figure 5. The MIA containment area is surrounded by the following land uses: • North Saleyards to be redeveloped as commercial use subject to MOU with

MIA. • South Brickworks (Austral Bricks). • East Saleyards to be developed for commercial use subject to MOU with MIA. • West WAPS site to be used for WAPS activities and commercial activities

(Areas B, C, and D), portion of Austral brickworks site. The containment area is located within a commercial/light industrial area, with the closest residential areas situated approximately 350m to the north across Railway Parade and approximately 650m to the south near Stirling Crescent.



3. MANAGEMENT OF AIR EMISSIONS 3.1 Overview This section describes the measures that will be employed to minimise air emissions generated as a result of earthmoving activities. The objective is to ensure that any on-site or off-site airborne contaminant emissions are kept to a minimum and comply with the relevant health protection criteria. For the full duration of the works, the Environmental Supervisor will perform a daily check as to the adequacy of control measures and siting of monitors. The Supervisor will be responsible for maintaining the log book and reporting results to the DEC. 3.1.1 Roles and Responsibilities Roles and responsibilities are specified below in relation to management of air quality and implementation of the DAQMP in order to clarify who is responsible for what and also the ‘chain of command’:

The Client is Midland Redevelopment Authority (MRA). The MRA is responsible for paying invoices. The MRA’s role is to provide guidance (via ATA Environmental) on whether the scope of the contract with the Air Monitoring Services Contractor meets its requirements.

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The Environmental Supervisor for Air Quality Monitoring is ATA Environmental or person(s) with delegated authority. ATA’s role is to oversee implementation of the DAQMP on behalf of MRA and to interpret and enforce conditions of the Air Monitoring Services contract on behalf of MRA. ATA is responsible for:

- overall systems monitoring to assess Air Monitoring Services Contractor

compliance with the DAQMP; - undertaking daily inspections regarding dust management and completing the

‘daily inspection form’. Complete ‘air quality exceedance report sheet’ if exceedance occurs;

- reviewing data and reports provided by the Contractor; - reviewing complaints and exceedances to assess if additional monitoring is

required. At a minimum, the requirement for additional monitoring (i.e. scope change) will be assessed monthly;

- directing the Air Monitoring Services Contractor regarding changes in scope; - advising the ECI Earthworks Contractor (Georgiou Group) if changes in

practice (dust management) are required; and - undertaking liaison with the MRA and with Georgiou Group.

The ECI Earthworks Contractor is Georgiou Group (GG). GG’s role is to undertake earthworks as per the ECI Contract. GG is responsible for:

- implementing dust management measures to control dust as per the DAQMP; - positioning the portable DusTrak monitor to a downwind position at least 2

times per day and recording the location and wind direction in a logbook. - Undertaking occupational health air monitoring as required by workplace

health and safety guidelines within the fenced work area (exclusion zone).

The Air Monitoring Services Contractor is to be appointed. The Air Monitoring Services Contractor’s role is to conduct air monitoring and reporting as per the



DAQMP and the Air Monitoring Services Contract and report to ATA. The Contractor shall provide evidence of relevant certification to undertake maintenance and calibration, sampling and analysis (e.g. NATA). The Contractor shall have a recognised or defined (and adequate) quality system. The Contractor is responsible for:

- advising of any exceedances of site criteria in a timely manner; - providing fortnightly or monthly reports to ATA; - participating in scope review meetings; and - assisting in liaison with the DEC and DOH.

The Auditor as required by the Contaminated Sites Act 2003 is Jeremy Hogben, ERM. The Auditor’s role is to monitor dust management performance and the results received from air monitoring. The Auditor will also undertake the following:

- assess if the management and monitoring are appropriate as per the DAQMP; - participate in scope review meetings as the Auditor deems appropriate; and - communication with the DEC as appropriate.

3.2 Dust Management 3.2.1 Overview The remediation works are anticipated to commence in the first or second quarter of 2007 and are expected to take 6-12 months to complete. A Site Classification Assessment Chart for Helena East is provided in Appendix C. As per the guideline “Land Development Sites and Impacts on Air Quality” (DEP, 1996), the site is Classification 3, considered a medium risk. Bureau of Meteorology (2005) data for the Perth Airport station is considered relevant to the weather patterns experienced at the site, and is presented in Appendix D. Dust management will comprise wind fencing, surface stabilisation (e.g. Hydromulching as areas are completed) and the use of dust suppression in the form of water trucks and sprinklers. These will be made available for the entire remediation phase. A windscreen will be constructed on the boundaries of earthworks area where they adjoin properties that are under active use. The wind fences act to reduce wind velocities over disturbed areas and thereby reduce dust lift-off. The windscreen will be constructed of shade cloth or Hessian on a 1.8m security high-fence. This will also act as a visual screen to the remedial earthworks. Clean fill imported onto the site is to be sufficiently damp to prevent dust emissions during transportation to site and tipping. The moisture content of the fill being brought onto site will be inspected periodically by the Environmental Supervisor. If too dry, the cartage firm will be required to wet the fill at the source. 3.2.2 Earthworks Dust control measures will conform with DEP Guidelines (DEP, 1996). This will involve the following measures:



• The rate of emissions of any pollutants can be directly related to exposed surface areas. The Earthworks Contractor will be responsible for staging works to minimise the area of disturbed soil (including stockpiles) to the extent practically feasible. Undertaking earthworks in stages will avoid the creation of large areas of disturbance which represent a source of dust emissions. The Environmental Supervisor, ATA, will work closely with the contractor to see that this is achieved.

• Wind fencing will be used as described previously. • Water carts will be available with a total storage capacity of 10,000 litres per 5ha of

disturbed site. This equates to at least two trucks with a total of 20,000 litres available. • Watering will be conducted using water trucks and impulse sprinklers at the following

areas:

• sites undergoing excavations. In areas being remediated, the application of water will be controlled to prevent ponding or run-off occurring.

• on all internal access tracks and machinery storage areas.

• Given water restrictions related to the use of sprinklers, the irrigation bore on-site will

be utilised where possible to supplement or fully source the water demands related to dust suppression. This groundwater is from a separate aquifer system (the Leederville) and is not contaminated. It is therefore suitable for such a use.

• Long-term stockpiles or large exposed areas that will remain open for extended periods

will be mulched. Mulch will also be used as required to stabilise areas that may be emitting excessive dust in strong winds or during extended periods of hot, dry weather. Mulched areas will be checked periodically to assess effectiveness of mulch in preventing dust. Re-mulching or use of tarpaulins or other techniques will be used as necessary to achieve dust and air quality objectives in relation to stockpiled soil.

3.2.3 Internal Access Tracks Waste material will be carted between the area of excavation and relocation along a dedicated internal road (limestone base track as a minimum) capable of supporting the volume of traffic. Trucks and roads will be wetted down and fine water sprays will be applied to minimise dust generation in transport areas. Application of a fine water spray will prevent water runoff from occurring in these areas. Water will be applied to the access tracks in the morning prior to each day or activity. Additional water will be applied to the tracks during the day as required. To prevent the spread of contaminated material back into remediated areas, a vehicle washdown bay will be provided (if required) on the exit route from contaminated areas to remove any soil adhering to vehicle tyres and undercarriage. If required, vehicles leaving the contaminated zone will be cleaned by high pressure water spray. The Earthworks Contractor be responsible for the design of the wash down bay. ATA Environmental will review and approve the design. It is envisioned that the washdown bay will be constructed of a compacted layer of limestone. Any sediments accumulating in the wash down pad will be considered waste and will be disposed off-site to landfill after sampling and analyses to determine contaminant levels.



3.2.4 Off-site Transport of Waste Waste fill will also be disposed off-site. Any material that is carted off-site will be transported along the major arterial road network. To prevent the spread of contaminated material onto the public road system, all loads will be below tare, thoroughly wetted and covered with tarpaulins. The Earthworks Contractor will ensure that dirt is removed from the outside of trucks prior to their leaving site to prevent dust generation A vehicle wash-down bay will be provided on the exit route from contaminated areas to remove any soil adhering to vehicle tyres and undercarriage. If required, vehicles leaving the site will be cleaned by high pressure water spray. The Earthworks Contractor will provide the specific design of the wash down bay. The objective of the wash down bay is that trucks are free from any soil that may create dust during transport. It is envisioned that the wash-down bay will be constructed of a compacted layer of limestone. The Earthworks Contractor will manage the truck wash bay so that no contamination of soil or groundwater occurs from wash down bay waste. For example, any sediments accumulating in the wash-down pad will be considered waste and will be disposed off-site to landfill after sampling and analysis to determine contaminant levels. The Waste Management Plan (PER Appendix 12, Section 6) describes in detail the management of waste taken off-site. In summary, the ECI Earthworks Contractor is responsible for managing the trucks transporting material so that trucks do not create excessive dust or spread contaminated material. The ECI Earthworks Contractor is also responsible for preventing cross contamination from machinery and for managing waste from the wash down bay. ATA Environmental is responsible for documenting the ECI Earthworks Contractor’s management of these issues and for requesting corrective action if necessary. 3.2.5 Importation and Placement of Clean Fill It is envisioned that up to 100,000m3 of clean fill will be imported onto the site using the public road system. In order to prevent nuisance dust emissions arising, all fill is to be sufficiently damp to prevent dust emissions on route and during tipping. The moisture content of the fill being brought onto site will be inspected periodically by the Environmental Supervisor. If too dry, the cartage firm will be required to wet the fill at the source. 3.3 Dust Management – Post Remediation Phase 3.3.1 Pre-Development Phase During the period between completion of remediation and prior to site development, the potential exists for dust emissions due to the bare ground surface. In order to minimise dust emissions form the uncovered land, soil stabilisation will be undertaken over the entire disturbed part of the site using suitable dust suppressors such as chipped vegetation, hydromulch or a chemical equivalent (e.g. Dustex). Most dust suppressors effectively stabilise soil for a period of months before they deteriorate, provided there is no traffic on the surface. Traffic over the stabilised surface will therefore be minimised to avoid breaking the crust. In the event that traffic on the surface is unavoidable, all traffic will be restricted to a designated track to limit overall damage to the stabilised surface. This track will be maintained to prevent soil erosion.



For the period between the completion of remedial works and commencement of development, dust monitoring will consist of visual inspections of the dust suppression and visual assessments of dust generation during strong winds. Where visual assessments indicate a problem, additional dust control agents will be applied to stabilise the areas that are generating dust. 3.3.2 Development Phase Once development proceeds, portions of the site could be the responsibility of either the MRA, City of Swan or an independent developer. In each case the owner at that time will be will be responsible for managing any potential dust generation during development. However, since contaminated soil will be removed and replaced by clean fill, the dust issues will be those typical of development sites.



4. AIR QUALITY MONITORING 4.1 Overview This section describes the monitoring program and rationale that will apply to ensure that the removal and relocation of the contaminated soil does not result in air quality levels that exceed criteria set for the protection of human health. Monitoring will consist of three set monitoring stations measuring a mixture of TSP (High Volume Samplers) asbestos fibre concentrations, fine particulates (TEOM or DusTrak) and hydrocarbon monitoring. These will be supplemented, if considered necessary by ad hoc use of DusTrak samplers in high risk areas if concerns exist that the fixed monitors are not adequate. The following subsections provide details on air quality monitoring: • 4.5 Asbestos fibres; • 4.6 Total Suspended Particulates (TSP); • 4.7 Fine Particulates (PM10); • 4.8 Dust Management Assistance – DusTrak; • 4.9 Heavy Metals; • 4.10 Baseline Monitoring; • 4.11 Visible Nuisance Dust; • 4.12 Hydrocarbon Monitoring; and • 4.13 Review of Air Quality Monitoring. 4.2 Air Quality Management Objective The objective of the air quality management program is to manage earthworks to prevent the exposure of remedial workers, employees in nearby workplaces and members of the public in areas outside the site boundary to possibly harmful levels of airborne contaminants. The purpose of air monitoring is to confirm that members of the groups mentioned above are not being exposed to potentially hazardous levels of contaminants. 4.3 Air Quality Zones An exclusion zone will be established by the contractor around those areas undergoing active earthworks to prevent unprotected personnel coming into contact with contaminated material. The earthworks contractor will be responsible for assessing the exposure of personnel (including employees, contractors and visitors to the site) within the exclusion zone and ensuring compliance with occupational legislation and policy. The earthworks contractor shall develop a health and safety plan to assess hazards and management measures, including personal protective equipment (PPE) requirements and procedures as required. We note that this includes the potential need for contractors, consultants and other visitors in the exclusion zone to wear personal air monitors for asbestos as an occupational health and safety measure. This measure shall be included in the health and safety plan(s) to be developed by Georgiou Group and/or ATA. The contractor will also be responsible for controlling access by others into the exclusion zone and ensuring that procedures in the relevant health and safety plan(s) are followed (e.g. all necessary personal protective equipment (PPE) is worn).



Air quality outside of the site boundary at publicly accessible areas will be monitored by the MRA to ensure compliance with standards set for the protection of public health. This will be along the northern, eastern and western site boundaries. As various contractors and leaseholders will be working within the Helena East Precinct during the remediation works, there may be a need for some additional monitoring to be conducted either at the edge of the exclusion zone boundary or alternatively in proximity to the potentially exposed contractors or leaseholders. Where such monitoring is required, the nature and extent of monitoring will be determined by ATA Environmental. AQMB, DOH or Department of Consumer and Employment Protection (DOCEP) will be consulted where appropriate. 4.4 Siting of Monitoring Stations To the extent that is feasible given the number of large buildings on the site, the air monitoring sites will be situated so that they are representative of the particular location and contaminant being tested for. In accordance with Australian Standard 2922-1987, Ambient Air-Guide for the Siting of Sampling Units, the following considerations will need to be taken into account when locating permanent monitoring sites:

Avoiding sites with restricted air flows such as near buildings and trees. The minimum clear sky angle for the sampling inlet should be 120 degrees.

•

•

•

•

Avoiding sites that may cause physical and chemical interference such as motor vehicle emissions.

Avoiding sites that may adsorb and absorb contaminants such as trees. Monitoring stations should be located at least 20m from trees and leafy vegetation.

Locating the monitoring inlet near the human breathing zone, ie 1m to 2m above ground level.

To assist in assessing data and the location of monitoring equipment, a weather station that complies as far as possible with AS2923 (including wind vane and anemometer) will be permanently located at the MRA site. The location of the weather station will be agreed to by the Air Quality Contractor, ATA, the Auditor and the DEC Air Quality Management Branch (if required). The weather conditions (including as a minimum, ambient temperature, wind speed and wind direction) will be monitored and recorded (in detail) during all monitoring, including the baseline assessment. Fixed monitoring stations will be located in locations that are downwind in the direction of the major prevailing breezes for the season prevailing during the remediation. Where necessary the fixed monitoring locations may be relocated based on an assessment of wind data and the major focus of remediation activities Monitoring for public exposure will be undertaken continuously with permanent stations located along the northern and western boundaries. Figure 6 presents indicative monitoring locations pending permission from MRA, CADCOM and the WAPS. Monitoring for asbestos will be performed along the fixed monitoring stations on the northern and western boundaries, and also in the CADCOM Police yard. Figure 6 shows the monitoring locations. The CADCOM location may not fully comply with AS 2922-1987 (Standards Australia, 1987) because of the number of large buildings, which will induce



major wake effects in the air flow but it is the nearest area where a substantial number of persons may be impacted by emissions. Where necessary additional short-term monitoring stations will be located at the boundary of exclusion zones to ensure that dust controls are effective in preventing release of fibres outside the exclusion zone. The requirement for any additional monitoring stations will be considered during the fortnightly/monthly review of monitoring data. In addition to the fortnightly/monthly review, additional monitoring will be considered if high numbers of exceedances occur or if visual observations or valid complaints suggest that receptors are being impacted. The final location of the fixed monitoring stations will be determined after discussion between ATA Environmental, MRA and the monitoring contractor. The input of Air Quality Branch will be sought during these discussions. Table 2 details the monitors that will be sited at each location.

TABLE 2 AIR MONITORING EQUIPMENT

Amenity and Public Exposure Monitoring

Stat

ion

Num

ber

Station Location Equipment Compound(s) Monitoring Duration

Personal Air Sampler Asbestos

4-8hrs/day – 2 weeks background monitoring and during active remediation works

HVAS Heavy Metals and TSP

2 weeks background monitoring and for at least 4 weeks during active remediation works.1

TEOM PM10 Fine Particulates 2 weeks background monitoring and throughout works

1

CADCOM Building to the East of Helena East

Canister (TO-15)* VOCs

(4 to 6 background samples) 2 weeks background monitoring and initial 4 weeks of hydrocarbon remediation2





2 Northern Boundary of Helena East





Stat

ion

Num

ber

Station Location Equipment Compound(s) Monitoring Duration








3 Western Boundary of Helena East


Ad Hoc As required As required As required As required

Notes 1. If no areas of soils containing significant levels of metals (i.e. exceeding EIL Criteria) are remediated during

the first 4 weeks of monitoring, the HVAS at each site will continue in operation until results representative of air quality during remediation of a metals contaminated area can be obtained. The results of monitoring undertaken during remediation of a metals contaminated area will be reviewed to assess if ongoing metals monitoring is required.

2. Assuming that Helena East is considered a stage 2 site Sampling (as per Schedule 2, Item 6 (iii) Sampling and

Analysis for Preliminary Monitoring National Environment Protection (Air Toxics) Measure, National Environment Protection Council, Dec 2004) for preliminary monitoring as a minimum must be carried out every second day over two consecutive weeks.

The VOC and PAH sampling will be targeted so that it is only undertaken to establish baseline levels and then during the period when hydrocarbon contaminated soils are being actively remediated

Exclusion Zone Boundary Monitoring

Equipment Compound(s) Monitoring Duration

Personal Air Sampler PAH (NIOSH 5506 or 5515)

4-8hrs/day – 2 weeks background monitoring and initial 4 weeks of hydrocarbon remediation

DusTrak (for management only) PM10 Fine Particulates

throughout works at downwind edge of activity zone



Note: monitors/samplers should be relocated by the ECI Earthworks Contractor (Georgiou Group) twice per day (e.g. morning and at approximately midday) to ensure that they are at the exclusion zone boundary, downwind of excavation works. Times of deployment, relocation and removal plus all GPS locations are to be recorded.

4.5 Asbestos Fibres 4.5.1 Monitoring Program Airborne asbestos fibres will be monitored using personal air samplers at three locations. A sampler will be located along the northern and western site boundaries. In addition, a personal air sampler will be placed within or adjacent to the CADCOM Police building. The personal air samplers are to be used in consultation with occupational testing procedures and sampling will be undertaken for 4-8 hours duration during each day of activity. Asbestos was mostly detected in the south portion of the site and then only as a few discrete fibres in soil samples. Although asbestos containing material has not been detected (or rarely detected) at the balance of the site, asbestos air samplers will operate at all times when active remediation works are being undertaken to be conservative, given the nature and history of the site. 4.5.2 Analytical Method Asbestos levels will be measured in accordance with the National Occupational Health and Safety Commission’s (NOHSC) Membrane Filter method for the determination of airborne fibre. In the field, a known volume of air will pass through the filter with any asbestos fibres being trapped. The filter is treated to become transparent and observed using phase contrast optical microscopic techniques. Particles of conforming dimensions (including non-asbestos fibres) are “counted” as fibres. Hence this method can overestimate the true amount of asbestos present (i.e. err on the side of caution). The volume of air that has passed through the filter is recorded, allowing an average concentration of airborne fibres to be determined. 4.5.3 Air Quality Standards The applicable standards for monitoring asbestos are provided in Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres 2nd Edition [NOHSC:3003(2005)], Worksafe Australia Asbestos: Code of Practice and Guidance Notes, (NOHSC, 1988a); Worksafe Australia No. 2002 Code of Practice for Asbestos Removal (NOHSC, 1988b); and the Occupational Safety and Health Regulations 1996. In terms of protecting public health at the CADCOM Police building (nearest site with a large number of employees), the target background level will be the collection and detection limit of 0.01 fibres/mL (10 times below the occupational limit). In view of the sensitivity of this monitoring location, it is proposed that excavation work will cease while dust management procedures are reviewed if this target criteria is exceeded while the wind is likely to be directing dust from the excavation site to the CADCOM monitor. Table 3 outlines the asbestos fibre air quality criteria.



TABLE 3 ASBESTOS CRITERIA

LOCATION TARGET CRITERIA (fibres/mL)

WORK STOPPAGE (fibres/mL)

Off-site <0.01 0.01

4.6 Total Suspended Particulates 4.6.1 Monitoring Program Total Suspended Particulates (TSP) dust monitoring is a general measurement for assessing the performance of the dust management program. TSP includes fine particulates (PM10) and larger particles that are suspended in air as dust. It is anticipated that, with good dust prevention and management measures in place, there may not be the requirement to undertake both PM10 and TSP monitoring. TSP monitoring will be undertaken at all three monitoring sites for the first 4 weeks of the remediation program. The short-term TSP program will be undertaken for two reasons: 1. Firstly to provide a site specific relationship between TSP and PM10 results to allow the

TEOM and DusTrak results to be used to develop conservative estimates of TSP values. It if recognised that this relationship will be affected by factors such as meteorology and the distance between the remediation site and the monitoring sites. But the PM10 measurement is the primary result of concern and the TSP estimate simply be used to estimate amenity impacts; and

2. To provide an estimate of contaminant levels contained in TSP. This will be achieved

by analysing the daily filter papers for the following parameters:

• metals (antimony, arsenic, cadmium, chromium, cobalt, copper, lead, manganese, mercury, nickel and zinc).

The results will be assessed at the end of the 4 weeks monitoring and decision made whether to undertake further TSP monitoring. 4.6.2 Analytical Method High Volume (Hi-vol) air sampler (HVAS) with TSP fittings as per AS3580.9.3 (Standards Australia, 2003). 4.6.3 Assessment Criteria TSP results will initially be compared to the TSP criteria (Table 4) derived from the criteria used in the current Kwinana Air Quality Environmental Protection Policy for residential area air quality (DEP, 1999).



TABLE 4 TSP CRITERIA

LOCATION TARGET CRITERIA

(ug/m3)

WORK STOPPAGE fibres/mL (ug/m3)

Off-site 90 (24 hour average) 750 (15 minute average)

150 (24 hour average) 1000 (15 minute average)

The 15 minute criteria will only be used in the event that complaints are being received that excessive dust emissions as the measurement of 15 minute average data for TSP requires the use of specialised portable equipment. The continuous PM10 measurements can act as surrogate for 15 minute TSP data in the first instance. 4.7 Fine Particulates (PM10) 4.7.1 Monitoring Program Fine particulate (PM10) dust monitoring captures that fraction of airborne particulates which represents the greatest potential health issue as it is capable of being respired into the lung. PM10 monitoring will be undertaken for off-site exposure at all three fixed monitoring locations for the duration of the remedial works. Monitoring will be with a continuous air sampler capable of providing alert messages for initiating corrective action. Results will be assessed against the relevant standards as outlined in Section 4.7.3. In addition, a DusTrak monitor will be operated on site in the activity/exclusion zone. 4.7.2 Analytical Method Particulate monitoring for public exposure will be undertaken using TEOM (Tapered Element Oscillating Microbalance) analysers in accordance with AS3590.9.8-2001. Three TEOM monitors will be placed at fixed locations near the CADCOM Police building to the east, at the northern boundary and at the western boundary of Helena East and provide constant real time measurements of PM10 particulates. These monitors will be run for 24 hours per day seven days per week during the course of the works. A plan for backup power for the TEOM has been considered, in the event that a power failure to the TEOM is experienced. The goal of the backup plan is to retain data and continue TEOM monitoring as soon as practical in case of a power failure so that representative monitoring results are obtained. It is considered that an acceptable level of data loss before there is a valid concern regarding representativeness would be the loss of 48 hours. The Air Monitoring Services Contractor will be required to provide a backup plan to address how to replace a power source in case of failure (e.g. identify an appropriate generator and demonstrate suitable specifications and expected time frame to bring the replacement power source online). The Contractor will also be required to advise how much data loss would occur in case of a power failure (minimum and maximum) and advise how data loss will be routinely prevented and what backup measures are in place.



A SMS text alert will be connected to the monitor and set up so that an SMS message will be sent to the Site Supervisor and Environmental Supervisor if the Corrective Action Response Level is ever exceeded. The averaging period for the results will be set at 10 minutes as this was the monitor default settings rather than 15 minutes as nominated by the DEC. This shorter averaging period provides for a greater degree of conservatism as the 10 minute results will be compared to the 15 minute criteria specified. 4.7.3 Assessment Criteria The PM10.results obtained from the TEOM will be assessed against the National Environmental Protection Measure (NEPM) for Ambient Air Quality (NEPC, 1998). This standard represents a longer term goal for ambient air quality “that allows for the adequate protection of human health and well being”. The NEPM specifies an ambient air quality target of 50µg/m3 for PM10. The NEPM criterion is a 24-hour average. Instantaneous levels can be considerably higher than the NEPM criterion. For works completed previously on the MRA site, the Air Quality Management Branch of the DEC has also nominated a short-term air quality criteria to be used as a management target and with the aim of ensuring that the 24 hour average complies with the NEPM criterion. The short-term limits are: a 1 hour average corrective action limit of 120µg/m3; and a 1 hour work stoppage value of 600µg/m3.

Table 5 summarises the fine particulate air quality criteria that are proposed by the MRA. As per the DEC AQMB it is understood that if the offsite Target Criteria levels for PM10 are exceeded then these levels may need to be revised downwards.

TABLE 5

FINE PARTICULATES AIR QUALITY CRITERIA

Location Target Criteria (µg/m3)

Corrective Action Response Level

(µg/m3)

Work Stoppage (µg/m3)

Off-site PM10

<50 (24 hour) or background,

whichever is the higher

120 (1hr)

600 (1hr)

On-site (activity/exclusion

zone) PM10

NA 300 (1hr) 750 (1hr)

Note: For on-site (activity/exclusion zone) PM10 monitoring the appropriateness of the monitoring will be reviewed by comparing results to the off-site PM10 monitoring. 4.8 Dust Management Assistance - DusTrak 4.8.1 Monitoring Program To provide an additional tool for dust management, an aerosol monitor capable of recording data on a continuous basis will be located at the edge of the exclusion/activity zone boundary.



The results shall be assessed against the relevant standards as outlined in Section 4.7.3 and Table 5. The higher assessment criteria adopted for the monitor located at the edge of the exclusion zone boundary recognises that this monitor is not assessing public exposure and is intended to provide results that will guide the need for improved dust management practices to ensure that off-site criteria are not exceeded. The DEC, DOH and Auditor have all expressed a preference for a DusTrak to be placed downwind of remediation activities at all times. A DusTrak will be used as an early warning assessment tool at the downwind edge of the activity zone to provide the ability to assess potential issues to tenancies within the site and to provide an early warning of any dust issues before they are triggered at site boundaries. The DusTrak will be moved to a downwind position at least 2 times per day by ECI Earthworks Contractor, Georgiou Group staff, and the location recorded in a logbook. The DusTrak will have a PM10 alarm set at 300 µg/m3 with work stoppage at 750 µg/m3. These higher concentrations have been adopted in view of that fact that the exposures within the Helena East precinct are largely of an occupational nature and generally there is a large travel distance to a site boundary where members of the general public will be exposed. It is considered that controlling to these levels at the exclusion zone boundary will be protective of air quality at the site boundary. If this is not the case the levels will be reviewed. WAPS Mounted Section Training Ground In view of the concerns raised by the WA Police Services, the MRA will position a further real-time monitor (Dustrak) on the WAPS site in proximity to the Containment Cell (during Mounted Section use of the training ground) to monitor particulate levels during periods when the waste is being placed in the cell or the cap is being constructed. In the event that the target criteria set in the Air Quality Management Plan are exceeded, dust control practices would be reviewed. However, based on recent information it is understood that it is the Mounted Section use of the training ground has been postponed and it is unlikely that the training ground will be used during remedial works. 4.8.2 Analytical Method Aerosol monitoring will be determined using a “DusTrak” or equivalent optical scattering monitor. These results will not be used for compliance purposes but rather as a management tool for dust suppression to ensure compliance criteria are met at the boundaries. Instruments of this type generally rely on an assessment of light scattering or attenuation by particulates over a fixed path and are calibrated with ‘standard dust’. The manufactures suggest that the results can be used as an estimate of PM10. 4.8.3 Assessment Criteria The criteria to be used for assessment of these results for on-site activity/exclusion zone monitoring are shown in Table 5. The results will be used for dust management purposes only, and not for regulatory purposes.



4.9 Metals 4.9.1 Monitoring Program The potential for elevated concentrations of metals to be present in airborne particulates is assessed as being low due to the nature of the waste fill material being excavated The waste fill material is generally coarse material and the metals are generally contained in a slag material which binds the metals and minimises dust generation. It is proposed that metal concentrations will be assessed in High Volume Sampler filter papers from the 2 week baseline sampling program and the initial 4 weeks of the remedial works to assess the levels of metals present in the particulate matter. Monitoring will target the full suite of metals present in the soils that exceed Ecological or Health Investigation Levels as required by the DEC AQMB. The filter papers will be provided to the laboratory on the same day, if possible, to obtain the fastest possible turnaround in results and prompt response to dust management if required. It is noted that the AQMB requested that no gravimetric determination TSP was performed on the filter papers to speed the turn around time for metals analysis. However, the DOH indicated that it did not believe that metals were likely to represent an urgent public health risk and as a result and for simplicity, it is proposed that all HVAS papers will be subjected to gravimetric determination of TSP as well as analysis for metals. Results shall be assessed against the relevant standards as outlined in Section 4.9.3. 4.9.2 Analytical Method Metal particulate monitoring for public exposure will be undertaken using Hi Volume Sampling in accordance with AS 3580.9.3 and AS2800 Laboratory analysis of the filters will be undertaken for the first 4 weeks of earthworks. This approach provides quantitative results for concentrations of metals in the air, but there is a delay (of 2-4 days) before results are available from the laboratory so that Hi-Vol monitoring is not suitable for immediate management purposes. However, DusTrak samplers will also be employed to assess the effectiveness of dust prevention and management measures as described in Section 3.2. The results of Hi-Vol monitoring will be assessed against the air quality standards. If the metals results are below the target criteria specified in Table 6, monitoring may be discontinued. If concerns are raised regarding metal concentrations in airborne dust at any time during remediation, monitoring may be re-initiated. 4.9.3 Assessment Criteria Metal concentrations will be assessed against the criteria specified in Table 6. Justification for the application of the criteria for the Helena East Site is discussed below. The Target Criteria/Corrective Action levels for antimony and cobalt are discussed below. The Target Criteria/Corrective Action levels for arsenic, copper, lead, zinc, cadmium, chromium, manganese and nickel have been revised to reflect other criteria that are currently being used in Perth Metro area as at November 2006. As stated in the 12 May 2004 letter from DEC regarding the ANI Bradken site (Appendix F), as part of the prior Midland remediation, the Department of Health (DOH) provided DEC with the guidelines listed below (for arsenic, cadmium, chromium, lead and zinc) and these have also been considered by the DOH to be applicable to the South Beach remediation. These guidelines are also considered to be suitable for Helena East remediation since the nearest potential residential receptors for South Beach are 193m north-northeast (residences within the suburb of South Fremantle)



(ANI Bradken EMP; ENV, 2005). The nearest potential residential receptors for Helena East are a similar distance and also in the prevailing wind direction (see Section 2.4, Potential Receptors). Using this same reasoning, the manganese guideline from the South Beach project has also been adopted. It is also noted that these same metals guidelines have been used for the Vickers Hadwa Former Foundry Site, Lot 839 Railway Parade, Bassendean. The nearest residential receptors are adjacent to the Site across Iolandthe Street to the east and Scaddan Street to the north. The metals guidelines used for the Vickers Hadwa Site, which has residential receptors closer than the Helena East Site, are considered applicable to the Helena East Site. Using this reasoning the copper and nickel guidelines from the Vickers Hadwa Site have been adopted. It is understood that antimony and cobalt have not typically been included in metals monitoring suites in Western Australia, so the proposed Target Criteria for each is discussed below. The cobalt Target Criteria proposed is 5ug/m3, which is an order of magnitude lower than the NIOSH/ACGIH 8-10 hour TWA limits. Cobalt compounds are listed as U. S. Federal hazardous air pollutants and in Section 8(d) of the Toxic Substances Control Act (TSCA). The American Conference of Governmental Industrial Hygienists (ACGIH) has established a concentration of 0.05 mg Co/m3 for cobalt metal dust and fume as the eight hour time-weighted average (TWA) threshold limit value (TLV); the Occupational Safety and Health Administration (OSHA) has set a permissible exposure limit (PEL) of 0.1 mg Co/m3 for cobalt metal dust and fume as the TWA for general industry, the shipyard industry, and the construction industry; and the National Institute of Occupational Safety and Health (NIOSH) has recommended an exposure limit of 0.05 mg/m3 as cobalt for the metal, dust, and fumes as the ten-hour TWA. The antimony Target Criteria proposed is 14ug/m3, which is more than an order of magnitude lower than the NIOSH REL/ACGIH TLV/OSHA PEL, and has been used in the USA for deconstruction projects. The NIOSH recommended exposure limit (REL) is the recommended exposure limit for an 8 or 10 hour TWA exposure and/or ceiling. The ACGIH TLV expressed as a time-weighted average; the concentration of a substance to which most workers can be exposed without adverse effects. The OSHA PEL is expressed as a time weighted average; the concentration of a substance to which most workers can be exposed without adverse effect averaged over a normal 8 hour work day or a 40 hour work week. Mercury has been included as part of the full metals analytical suite as required by the DEC AQMB. However, since the average mercury concentration in soils on site approaches zero (see Appendix E, Table 1) it has not been considered necessary to propose a target criteria at this time. Table 6 summarises air quality criteria for metals in airborne particulates. The Target Criteria and Corrective Action have been combined, and Work Stoppage Level removed to reflect the practicalities of High Volume monitoring i.e. results will be received several days after sampling so that any Corrective Action will be made in response to values approaching the Target Criteria.



TABLE 6 HEAVY METAL PARTICULATES AIR QUALITY CRITERIA

(24 HOUR AVERAGES)

LOCATION TARGET CRITERIA/ CORRECTIVE ACTION

(µg/m3) Antimony 14

Arsenic dust 0.8 Cadmium 0.2 Chromium 1.0

Cobalt 5 Copper 90 Lead 1.3

Manganese 1 Nickel 1.8 Zinc 350

Note: Mercury has been included as part of the full metals analytical suite as required by the DEC AQMB. However, since the average mercury concentration soil on site approaches zero (see Appendix E, Table 1) it has not been considered necessary to propose a target criteria at this time. 4.10 Baseline Monitoring Baseline continuous monitoring will be conducted before the commencement of remedial works for a period of two weeks at the monitoring sites to provide a background measure of air quality for the local area. The observed range of background levels will be used as the benchmark for assessing any degradation of air quality as a result of the remedial works; this is described in more detail in the following subsection. Weather conditions will also be monitored and recorded (in detail) during this observation period. The following baseline monitoring will be undertaken: • Asbestos; • Metals (antimony, arsenic, cadmium, chromium, cobalt, copper, lead, manganese,

mercury, nickel, zinc) using High Volume Samplers; • TSP (Total Suspended Particulates using High Volume Samplers) • PM10 (Fine Particulates) using TEOM; • PM10 (Fine Particulates) using DusTrak; • VOC using canister method TO-15; and • PAH using NIOSH Method 5506 or 5515. 4.11 Visible Nuisance Dust Nuisance dust will be assessed by visual inspection on a regular basis. Visual inspection results will be maintained on a daily logging sheet for reference.



4.12 Hydrocarbon Monitoring 4.12.1 Monitoring Program The excavation of hydrocarbon contaminated soil is expected to continue for at least 10 weeks to allow excavation of soil in the vicinity of the Powerhouse and the Southern Embankment. During the excavation of hydrocarbon contaminated soils, monitoring of VOC levels will be undertaken using evacuated canisters as per method TO-15. For the first 4 weeks of the program, canisters will be deployed at the three fixed monitoring stations and left in operation for 24 hours to provide an assessment of average concentrations. The results of the initial program will be reviewed in a workshop between ATA Environmental and the monitoring contractor and the extent of duration of TO-15 monitoring beyond that will be determined. Written advice will be sought from the Auditor and DEC will be advised before amending the monitoring protocols. PAH concentrations will be assessed at the edge of the exclusion zone boundary using NIOSH Method 5506 or 5515 and XAD resin, as PUF is not well suited for sampling naphthalene which is the most prevalent PAH compound present in the soils. The previous proposal to measure PAH’s using the High Volume Samplers tasked to measuring metals and TSP has been discounted based in comments by AQMB. Advice from Compliance Monitoring recommended that the NIOSH methods would be best suited to accurately measure volatile PAH compounds such as naphthalene which are more prevalent in soils on the site. PAH monitoring will be undertaken during the first 4 weeks of works where hydrocarbon contaminated soils are being actively remediated. The need for ongoing monitoring will be determined based on assessment of collected data. In view of the uncertainties in this program it is considered essential that the data collected is reviewed regularly and the program adjusted to ensure that it is both effective and represents value for money. 4.12.2 Analytical Methods VOC using TO-15 (canister) as per Compendium of Methods for the Determination of Toxic Organic compounds in Ambient Air (USEPA 1999a, USEPA 1999b). PAH using NIOSH Method 5506 or 5515. 4.12.3 Air Quality Standards There are a few published ambient air quality criteria for many of the VOC compounds that may be present on the site. As a result, it is proposed that the World Health Organisation Guidelines are used to assess the results. The 24 hour average guidelines cited in the Volatile Organic Compounds Monitoring in Perth, Baseline Air Toxics Project (DEP, 2000) report are referenced (Table 7) in the absence of other appropriate guidelines. As the WHO Criteria are generally set for long term protection of health in a prolonged exposure environment, they will be used as target values. Corrective action levels will initially be set at these WHO Criteria and work stop levels will be set at 200% of the WHO Criteria. The effectiveness of this approach will be evaluated based on the results of the first month of monitoring. The proposed Criteria are set out in Table 8. (Note: where the WHO criteria in Table 7 are set on weekly averages, they have been adjusted by a factor 150% to reflect that they are being used as 24 hour average criterion in this case).



The only exception is for Benzene where the criteria has been derived from the Department of Employment and Workplace Relations (DEWR) 8 hour occupational health guideline as indicated in the footnotes to Table 8.

TABLE 7 INTERNATIONAL GUIDELINES FOR AMBIENT AIR TOXICS

CONCENTRATIONS (ppb)

Other Annual Average Guidelines AIR TOXINS WHO 24-h Average Guidelinesa Swedenb UKc

Dichloromethane 792 100-250 - Chloroform 0.2 - - 1,2-Dichloroethane 159 100-150 - Benzene - 0.4 5 Trichloroethylene - 100-150 - Toluene 63.2* 10-100 - Tetrachloroethylene 33.8 100-200 - Ethylbenzene 4644* - - Xylenes 1013 - - Styrene 55.9* 10 - a WHO guidelines quoted are for 24h averages except for compounds with asterisks (*) which are 1 week averages (WHO, 1987, 1994, 1996 & 1997) b OECD, 1995

c EPAQS, 1994 TABLE 8

ADOPTED CRITERIA FOR VOLATILE COMPOUNDS

CONCENTRATIONS (ppb)1

Corrective Action Levels Work Stop Levels AIR TOXINS

(24 hr avg unless indicated)

(24 hr avg unless indicated)

Dichloromethane 790 1580 Chloroform 0.2 0.4 1,2-Dichloroethane 160 320 Benzene 750 2 1,500

Trichloroethylene - - Toluene 95 190 Tetrachloroethylene 35 70 Ethylbenzene 6,970 13,940 Xylenes 1015 2030 Styrene 90 180

Note: No hourly or weekly average criteria could be identified for trichloroethylene

1. Given the nature of the adjusting factors applied to derive these criteria, the final criteria

have been rounded slightly for ease of reporting and interpretation. 2. The benzene criteria has been derived from the DEWR 8Hr TWA value for benzene of 1ppm

(1000ppb). A factor of 75% has been applied to the 8 hr occupational health criterion to reflect the longer 24 hour averaging period proposed for the TO-15 method at this site

Only the most volatile PAH, naphthalene, has a guideline limit. 2-methylnaphthalene (also found at the site) is not currently a USEPA listed hazardous air pollutant.



Naphthalene limits only exist for workplace safety. The TWA (8hr) is 10ppm (52mg/m3) (NOHSC, 1995). As the sampling is being performed at the exclusion zone boundary then this is considered to be the appropriate action limit. The criteria for PAH are set out in Table 9.

TABLE 9

CRITERIA FOR PAH CONCENTRATIONS

Corrective Action Levels Work Stop Levels PAH

(8 hr) (8 hr)

Naphthalene 10ppm (52mg/m3)

20ppm (104mg/m3)

Note: As with the other volatile criteria the work stop level has been set at 200% of the Corrective Action Level

4.13 Review of Air Quality Monitoring On the basis of comments received from the DEC AQMB and the DOH, MRA has adopted a more dynamic approach to monitoring based on monthly reviews of data throughout the works program to allow the monitoring program to be fined tuned to reflect the changing nature of the works and our improved understanding of the level of impact. The review will be undertaken monthly during the majority of the program. The only exceptions would be: • An initial review will be undertaken on completion of the background monitoring and

prior to commencement of the remediation works; • During the first 6 weeks of remediation, the review will occur fortnightly; and • Additional reviews will be undertaken if high levels of exceedances or justified

complaints are received. Each Review will address the following: 1. An assessment of all monitoring data to hand including:

• The full metals suite monitoring using Hi Vol sampling. Monitoring may be discontinued if results indicate low risk;

• TSP; • PM10 ; • Dust Management Assistance – DusTrak; • VOC; and • PAH. 2. The performance of the monitoring equipment and the adequacy of data quality. 3. The performance of the monitoring contractor and the adequacy of data quality. 4. The performance of the earthworks contractor equipment and the adequacy of air

management measures. 5. The extent of complaints or exceedances received during the remediation period.



6. The need for changes to the nature or extent of monitoring. The monthly review will be chaired by the Environmental Superintendent (ATA) with input

ased on comments from the DEC and the DOH, the following will also be considered:

As proposed by DoH (Comment 3), if appreciable metals concentrations are

As per DEC AQMB (Comment 9), it is understood that if the offsite Target Criteria

from the Air Monitoring Services Contractor. Records to be reviewed will include daily inspection forms, Air Quality Exceedance Report Sheets (if any), any valid complaints recorded and corrective action. This information will be summarized in a fortnightly or monthly report and provided to the Auditor and the DEC. Invitations to each review meeting will be extended to the Auditor and the Air Quality Branch of the DEC. B •

consistently reported for more than 2 weeks the ground disturbing activities will cease until more effective management practices are established.

• levels for PM10 are exceeded then action levels may need to be revised downwards. DoH and DEC AQMB comments are included in Appendix H.



5. CONTINGENCY RESPONSE Should air quality monitoring show that dust and airborne contaminant emissions exceed the Corrective Action Response Levels, dust management practices will be immediately reviewed and corrective action taken to improve air quality. If the Work Stoppage Level is exceeded, all remedial work creating the dust source will cease until monitored levels fall below the Corrective Action Response Level. 5.1 Corrective Action during Remedial Works The corrective action taken will typically comprise the following sequence of actions:

check all trucks are appropriately covered and that earthmoving machinery is operating in wetted down areas;

•

•

•

•

•

•

increase the water application rates over all disturbed areas;

reduce the level of earthmoving activity if evaporation rates are drying the fill quicker than water can be applied;

reduce the area of disturbance to minimise VOC emissions;

apply a suitable physical dust suppressant to any inactive areas; and

cease all work if extreme weather conditions are the prime reason for excessive dust levels and dust suppression techniques have been ineffective in controlling the dust.

5.2 Notification of Exceedance The Auditor and DEC will be notified in writing by ATA Environmental within 24 hours of knowing of the occurrence if there has been an exceedance of the corrective action or target values. Should there be a work stoppage this will be notified immediately on the day by phone and in writing.



6. REPORTING Reporting of the Dust and Air Quality Management for Remediation of Helena East Soils at Midland Railway Workshops will be undertaken in two formats as follows:

periodic reporting during remediation works • •

• • • • • •

a summary report will be prepared after the conclusion of the remedial works. The fortnightly/monthly reporting will provide information on general trends of dust management via dust monitoring results to the Auditor and DEC. In addition, the Auditor and DEC will be provided with notification of any compliance breaches (if they should occur) within 24 hours of ATA Environmental becoming aware of the occurrence. The fortnightly/monthly reporting will be prepared by the Air Monitoring Services Contractor and will comprise a summary presentation including: • a matrix/table of monitors present at each sampling location and monitor performance

during the period; • all monitoring results compared to criteria specified in the DAQMP; • location of the portable dustrak (with wind direction) during the period; and • recommendations for changes to the program. ATA Environmental will generally undertake daily inspections as a tool to verify compliance with the DAQMP. A ‘daily inspection form’ will be completed by ATA to document items that will be used to assess compliance. If an exceedance of An Air Quality Exceedance Report Sheet will be completed. An example of the ‘daily inspection form’ and the ‘air quality exceedance report sheet’ are included in Appendix G. A Dust and Air Quality Management Report providing the following information will be provided after the conclusion of the remedial works:

Air Monitoring Parameters Air Quality Standards Air Monitoring Methods Air Monitoring Locations Air Monitoring Results Conclusion

Upon submission of the Report to the Auditor and DEC, ATA Environmental on behalf of the MRA, will request that any condition(s) regarding dust and air quality management are formally cleared by the Auditor and the DEC. 6.1 Regulatory and Auditor Review of DAQMP Liaison with the DEC Air Quality Management Branch (AQMB) and the Department of Health (DoH) has been undertaken during the early stages of preparation of the Dust and Air Quality Management Plan (DAQMP) to seek input and agreement on the proposed dust management and monitoring strategies. The DAQMP was submitted for review to the AQMB and also to the DoH. Letters of comment and responses are provided in Appendix G. In addition, the DAQMP was provided to the Contaminated Sites Auditor appointed by the MRA for review, and comments received in May 2007. These comments and responses provided by ATA Environmental are also included in Appendix G.



REFERENCES ATA Environmental (2006). Helena East Precinct Remediation and Redevelopment Public

Environmental Review. Prepared for Midland Redevelopment Authority. March 2006. Bureau of Meteorology (2005). Climatological Data for Perth Airport Using Data from 1944

to (November) 2005. Climate and Consultancy Section in the WA Regional Office of the Bureau of Meteorology, Australian Government. December 2005.

DEP (1996). Land Development Sites and Impacts on Air Quality. Department of

Environmental Protection (DEP), Perth. November 1996. DEP (1999). Revised Draft Environmental Protection (Kwinana) (Atmospheric Wastes)

Policy 1999. Department of Environmental Protection (DEP), Perth. June 1999. DEP (2000). Volatile Organic Compounds Monitoring in Perth. Baseline Air Toxics Project.

Department of Environmental Protection (DEP), Perth. January 2000. DoE (2003). Assessment Levels for Soil, Sediment and Water (Draft). Contaminated Sites

Management Series. Department of Environment (DoE), Perth. ENV (2003). Detailed Site Investigation Helena West, Midland Railway Workshop Site.

Prepared for Midland Redevelopment Authority. March 2003. ENV (2004). Environmental Investigations in Support of Referral, Helena East, Midland

Railway Workshop Site. Prepared for Midland Redevelopment Authority. October 2004.

ENV (2005). Attachment K, ANI Bradken EMP, Dust and Air Quality Management Plan.

05.013 Attach K/RP001 July 2005. Final. EPA (2003). Remediation of Midland Workshop Site, Helena West Precinct, Midland

Bulletin 1111. Prepared Environmental Protection Authority (EPA). September 2003. EPAQS (1994). Expert Panel on Air Quality Standards, Benzene, 1994. Expert Panel on Air

Quality Standards (EPAQS), Department of the Environment, London. NEPC (1998). National Environmental Protection Measure for Ambient Air Quality. National

Environmental Protection Council (NEPC). NEPC (2004). National Environment Protection (Air Toxics) Measure. National Environment

Protection Council (NEPC). Dec 2004 EPC (2004). National Environment Protection (Air Toxics) Measure. National Environment

Protection Council (NEPC). December 2004. NOHSC (1988a). Worksafe Australia Asbestos: Code of Practice and Guidance Notes.

National Occupational Health and Safety Commission (NOHSC), August 1988. NOHSC (1988b). Code of Practice for the Safe Removal of Asbestos. National Occupational

Health and Safety Commission (NOHSC), August 1988. NOHSC (1995). Adopted National Exposure Standards For Atmospheric Contaminants In

The Occupational Environment [NOHSC:1003(1995)]



NOHSC (2004). Code of Practice for the Managements and Control of Asbestos in Workplaces (NOHSC:2018). National Occupational Health and Safety Commission (NOHSC).

OECD (1995). Control of Hazardous Air Pollutants in OECD Countries. Organisation for

Economic Co-operation and Development (OECD), Paris. Standards Australia (1987). Australian Standard AS 2922 – Ambient Air-Guide for Siting of

Sampling Units. Standards Australia, Homebush. Standards Australia (2003). Australian Standard AS 3580.9.3:2003 – Methods for Sampling

and Analysis of Ambient Air – Determination of Suspended Particulate Matter- Total Suspended Particulate Matter (TSP) – High Volume Sampler Gravimetric Method.. Standards Australia, Homebush.

USEPA (1999)a. TO-13A Compendium of Methods for the Determination of Toxic Organic

compounds in Ambient Air. Determination of Volatile Organic Compounds (VOCs) in Ambient Air Using Specially Prepared Canisters With Subsequent Analysis by Gas Chromatography. United States Environmental Protection Agency (USEPA) Centre for Environmental Research Information, Office of Research and Development. Cincinnati, OH. Second Edition. January 1999.

USEPA (1999b). TO-15 Compendium of Methods for the Determination of Toxic Organic

Compounds in Ambient Air. Determination of Volatile Organic Compounds (VOCs) in Air collected in Specially-Prepared Canisters and Analysed by Gas Chromatography/Mass Spectrometry (GC/MS). United States Environmental Protection Agency (USEPA) Centre for Environmental Research Information, Office of Research and Development. Cincinnati, OH. Second Edition. January 1999.

WHO (1987). Air Quality Guidelines for Europe. World Health Organisation (WHO)

Regional Publications, European Series No 23, Copenhagen. WHO (1994). Chloroform. Environmental Health Criteria 163, World Health Organisation

(WHO), Geneva. WHO (1996). Ethylbenzene. Environmental Health Criteria 186, World Health Organisation

(WHO), Geneva. WHO (1997). Xylenes. Environmental Health Criteria 190, World Health Organisation,

Geneva.


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LEGEND

FIGURE 3


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G-6G-6

G-7G-7

G-10G-10

G-12G-12

G-13G-13

L-1L-1L-2L-2

L-3L-3

L-4L-4L-5L-5

L-6L-6

L-7L-7

L-8L-8L-9L-9

I-3I-3

I-6I-6

I-8I-8

C-2C-2C-4C-4

C-5C-5

C-6C-6

B1-1B1-1 B1-2B1-2

B1-3B1-3

B1-4B1-4

B2-2B2-2

B2-6B2-6

B2-7B2-7

B2-8B2-8

H5-1H5-1

H5-2H5-2

H5-3H5-3

H5-4H5-4

H5-5H5-5

H5-8H5-8

H5-9H5-9H5-10H5-10

H5-11H5-11

H5-12H5-12

H5-13H5-13

H5-14H5-14

A-1A-1 A-2A-2

A-3A-3

A-4A-4

A-5A-5

A-6A-6

A-7A-7

A-9A-9

A-10A-10A-11A-11

A-12A-12

A-14A-14

A-15A-15

A-16A-16

A-17A-17 A-18A-18

S-2S-2

S-1S-1

B-1B-1

B-2B-2

B-3B-3

B-4B-4

B-5B-5

W3-1W3-1

W3-2W3-2

W3-3W3-3W3-4W3-4

W3-6W3-6

W3-5W3-5

W3-7W3-7

W3-8W3-8

W3-9W3-9

W1-1W1-1

W1-2W1-2

W1-3W1-3W1-4W1-4

W1-5W1-5

W1-7W1-7

W1-8W1-8

W2-1W2-1

W2-2W2-2

W2-3W2-3

W2-4W2-4

W2-5W2-5

W2-6W2-6

W2-7W2-7

W2-8W2-8

H6-1H6-1

H6-2H6-2

H6-3H6-3

H6-4H6-4

H6-5H6-5

H6-6H6-6

H6-7H6-7

H6-8H6-8

H6-9H6-9

H6-10H6-10

H6-11H6-11

H6-12H6-12

H6-13H6-13

H6-14H6-14

H6-15H6-15

H6-16H6-16

C-1C-1

H1B-23H1B-23

A-1A-1

E-1E-1

F-4F-4

G-1G-1G-3G-3G-4G-4

I-1I-1

I-2I-2

C-3C-3

C-7C-7

C-8C-8

H4-6H4-6

A-1A-1

A-2A-2

A-8A-8

A-12A-12

A-2A-2 A-5A-5

D-3D-3

D-1D-1

F-5F-5

G-5G-5

G-8G-8

G-9G-9

G-11G-11

G-14G-14

I-4I-4

I-5I-5

I-7I-7

C-1C-1

B2-1B2-1

B2-3B2-3B2-4B2-4

B2-5B2-5

A-8A-8

A-13A-13

S-3S-3

W1-6W1-6

H1-19

H3-54H3-55H3-55 H3-52H3-52

H3-56H3-56H3-57H3-57

H3-53H3-53

H3-61H3-61

H3-60H3-60

H3-52H3-52

H3-46H3-46

H3-37H3-37 H3-36H3-36

H3-38H3-38

H3-59H3-59

H3-35H3-35

H3-45H3-45H3-47H3-47

H3-48H3-48 H3-44H3-44

H3-39H3-39 H3-33H3-33 H3-34H3-34

H3-32H3-32H3-40H3-40

H3-41H3-41H3-51H3-51H3-500

H3-499

H3-43H3-43 H3-42H3-42

H3-29H3-29H3-28H3-28H3-27H3-27H3-26H3-26H3-25

H3-233 H3-24H3-24 H3-19H3-19

H3-18H3-18H3-22

H3-17H3-17H3-16H3-16

H3-30H3-30

H3-31H3-31

H3-15H3-15H3-14H3-14

H3-13H3-13

H3-20H3-20

H3-11H3-11

H3-12H3-12H3-21H3-21

H3-10H3-10

H3-5H3-5

H3-6H3-6

H3-3H3-3

H3-4H3-4

H3-1H3-1H3-2H3-2

H3-7H3-7

H3-8H3-8

H3-9H3-9

A2-1

A2-2

A2-3

A2-4

A2-5

A2-6

A2-7

A2-8 A2-9

A2-10

A2-11

A2-12

A2-133

A2-14

A2-15TPETPE

TPF

TPG

A3-1A3-1

A3-2A3-2A3-3A3-3

A3-4A3-4

A3-5A3-5

A3-6A3-6

A3-7A3-7

A3-8A3-8

A3-9A3-9

A3-10A3-10

A3-11A3-11

A3-12A3-12

A3-13A3-13

A3-14A3-14

A3-15A3-15

A3-16A3-16

A3-17A3-17

A3-18A3-18

A3-19A3-19

A3-20A3-20

A3-21A3-21

A3-22A3-22

A3-23A3-23

A3-24A3-24

A3-25A3-25

A3-26A3-26A3-27A3-27

A3-28A3-28

A3-29A3-29

A3-30A3-30

A3-31A3-31

A3-32A3-32

A3-33A3-33

A3-34A3-34

A3-35A3-35

A3-36A3-36

A3-373-37

A3-38

A3-39-39

A3-40

A3-41

A3-42

A3-43

A3-44A3-44

A3-44A3-44

A3-46A3-46

A3-47A3-47

A4-1

A4-2

A4-3

A4-4

A4-5A4-64-6

A4-7A4-7

A4-8A4-8

A4-9A4-9 A4-10A4-10

A4-11A4-11

A4-12A4-12

A4-13A4-13

A4-14A4-14

A4-15A4-15

A4-16A4-16

A4-17A4-17

A4-18A4-18

A4-19A4-19

A4-20A4-20

A4-21A4-21

A4-22A4-22

A4-23A4-23

A4-24A4-24

A4-29

A4-32A4-32

A4-33A4-33A4-34A4-34

A4-35A4-35

A4-36A4-36A4-37A4-37

HR1

HR29

HR63

HR30

HR64

HR65HR65

HR31HR31

HR32HR32

HR33HR33

HR34HR34

HR35HR35

HR36HR36HR16HR16

HR17

H5HH5H

HE-15HE-15

H5BH5B

HE-16HE-16

HE1HE1HE2HE2

HE3HE3

HE4HE4

HE5HE5

HE6HE6

HE7HE7

HE8HE8

HE9HE9

HE11

HE12HE12

HWMW1HWMW1

HW1W1

HW2HW2

HR10

HR11

HR12HR12

B1

B2B2

B3B3

B4B4

HP1HP1

HP2HP2

HP3HP3

HP4

HP6

HP7

HP8HP8

HP9HP9

HP10HP10

HP11HP11

HP12a12aHP12

HP13HP13

HP14HP14

HP15HP15

HP16HP16

MW1MW1

MW2

MW3

MW4

MW15

MW16MW16

B5B5 B6B6

B7

MB1MB1

MB2MB2

MB3MB3

MB4

MB10MB10

MB11

CD2

CD3

CD5

CD7CD7

CD8CD8

RivbedRivbed

HE14HE14

HE11HE11

HE12HE12

HE13HE13

HE-17HE-17 F-3F-3

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6363

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1818

1313

1616

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22222323

2525

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30303131

2929

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28282727

3232

3737

4545

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4646

4747

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5454

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3535

3636

3333

4343

3939

5050

5151

4444

5656

5959

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5858

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3434

ATA-1ATA-1

ATA-2ATA-2

ATA-3ATA-3

ATA-4ATA-4

ATA-5ATA-5

ATA-6ATA-6

ATA-7ATA-7

ATA-8ATA-8

ATA-9ATA-9

ATA-10ATA-10

ATA-11ATA-11

ATA-12ATA-12

ATA-13ATA-13

ATA-14ATA-14

ATA-15ATA-15

ATA-16ATA-16

F1F1

F2F2

F3F3F4F4

F5F5

F6F6

F7F7F8F8

F9F9

F10F10

F11F11

F12F12

F13F13

F14F14

7474

7878

7171

ATA72ATA72

ATA73ATA73ATA76ATA76

ATA75ATA75ATA77ATA77


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HW1HW1

H3-24H3-24

2929

ATA-9ATA-9

ENV Sample Locations

ATA Sample Locations

Contaminants


Cadastral Boundary

Building Outline

0 25

metres

50 75 100

SCALE 1 : 2 250 @ A3

BASE SOURCE: McMULLEN & NOLAN, May 2005BASE SOURCE: McMULLEN & NOLAN, May 2005SAMPLING DATA SOURCE: ENV Australia, April 2005SAMPLING DATA SOURCE: ENV Australia, April 2005

Soil Sampling Location

Groundwater Monitoring Well

Groundwater Monitoring Bores

Soil Sample Locations

Asbestos (detected)

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FIGURE 4SITE LOCATIONS WITH ASBESTOS IDENTIFIED

AMH

ERST

AMH

ERST

RO

ADR

OAD

HEL

ENA

STR

EET

HEL

ENA

STR

EET

SAYE

R

STR

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SAYE

R

STR

EET

BRO

CKM

AN

RO

ADBR

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KMAN

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RAILWAY PARADE

RAILWAY PARADE

WHITE

MAN

ROAD

WHITE

MAN

ROAD

ELGEEELGEE

LLO

YD

STR

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ION

STM

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PAD

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Y

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RAC

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PAD

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RAC

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GREATGREAT

EASTERNEASTERN

HIGHWAYHIGHWAY

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ADR

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BUSH

BYBU

SHBY

STR

EET

STR

EET

MO

OR

EM

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AVEN

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FER

GU

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EET

KEAN

EKE

ANE

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OLDOLD

GREAT

GREAT

NORTHER

N

NORTHER

NHW

Y

VICTORIAVICTORIA

STREETSTREET

MIL

ITAR

YM

ILIT

ARY

RO

ADR

OAD

CLAYTONCLAYTON

STREETSTREET

LEFR

OY

LEFR

OY

AVEN

UE

AVEN

UE

RO

BIN

SON

RO

BIN

SON

ROADROAD

YELVERTONYELVERTON

DRIVEDRIVE

EASTERNEASTERN

HIGHWAYHIGHWAY

GREATGREAT

VIVE

ASH

RO

ADVI

VEAS

H

R

OAD

HWY

HWY

ROE

CENT

RAL

AVAV

MONTREALMONTREAL ROADROAD

STIRLING CRESCENT

STIRLING CRESCENT

FIGURE 5


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AREA EAREA E





Helena

Helena

RiverRiver

RAILWAYRAILWAY

RESERVERESERVE


MIA Containment AreaMIA Containment Area(Notional Containment(Notional Containment

Cell Envelope)Cell Envelope)

ResidentialResidential

ProposedProposedHospital DevelopmentHospital Development

MixedMixedResidentialResidential

MidlandMidlandTown CentreTown Centre

MidlandMidlandRailwayRailwayStationStation


RedidentialRedidentialDevelopmentDevelopment

( Former Railyards )( Former Railyards )PrimaryPrimarySchoolSchool

Western AustralianWestern AustralianPolice ServicesPolice Services( WAPS ) Site( WAPS ) Site

H e l e n a R i v e r F l o o d p l a i n

H e l e n a R i v e r F l o o d p l a i n

LAND USES SURROUNDINGHELENA EAST PRECINCT



0

metres

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SCALE 1 : 7 500 @ A3

300 400 500




River / Stream, Waterbody Boundary



AREA EAREA E






YELVERTON

YELVERTON

DRIVEDRIVE

HE

LEN

AH

ELE

NA

ST

ST

Boiler ShopBoiler Shop

Black Smith Shop

Black Smith Shop

Tool RoomTool Room

Machine Shop

Machine ShopFitting ShopFitting ShopDiesel Shop

Diesel Shop

Diesel ShopDiesel Shop

Weigh Bridge

Weigh Bridge

StoresStores

ElectricalElectricalStoreStore




PowerHouseHouse

PatternPatternStoreStore Pattern

PatternShopShopBlackBlackSmithSmithStoreStore

CasualtyCasualty

PanelPanelShopShop

FoundryFoundry

CanteenCanteen

Sand BlastSand BlastShedShed

EffluentEffluentTreatmentTreatment

TanksTanks

ApprenticeApprenticeSchool

School


Diesel Shed &

Diesel Shed &Refuelling Area

Refuelling Area

Element Shop

Element Shop

BLOCK 1BLOCK 1

BLOCK 2BLOCK 2

BLOCK 3BLOCK 3

Supply Sheds

Supply Sheds

Supply Sheds

Supply Sheds

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CE

NTE

NN

IAL

CE

NTE

NN

IAL

PLA

CE

PLA

CE

RAILWAYRAILWAY

RESERVERESERVE

Helena

Helena

RiverRiver

Waste WaterWaste WaterTreatment PlantTreatment Plant

1414

1414

10101111

1212

1313

1414

66

55

9988

77

66

55

55

55

44

33

3344

55



Works Managers

Works Managers

INDICATIVE AIR MONITORING LOCATIONS

DUST AND AIR QUALITY MANAGEMENT PLANREMEDIATION OF HELENA EAST SOILS AT

MIDLAND RAILWAY WORKSHOPS




Topographic Contour (m AHD)

Indicative Air Monitoring LocationsFIGURE 6

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APPENDICES

APPENDIX A

REVIEW OF AIR EMISSIONS MANAGEMENT AT PREVIOUS MRA REMEDIATION SITES

REVIEW OF AIR EMISSIONS MANAGEMENT AT PREVIOUS MRA REMEDIATION SITES

1. INTRODUCTION 1.1 Background Remediation activities at the former Midland Railway Workshops have been subject to extensive air monitoring since the first major remedial works were carried out in Area E in April 2002. In recent times community interest has developed regarding adverse air quality associated with remedial works. As such the Department of Environment (DoE) in subsequent assessments of the former Workshops site has required that maintenance of air quality be considered a key environmental objective of the project. The means to ensure this environmental objective has been achieved is through monitoring of air quality during the remediation phase. Impacts on air quality during a remediation are a function of many factors including, but not limited to, the following:

time of year, which determines the moisture content of the ground and thus dust emission potential;

•

•

•

•

•

magnitude or the size of the earthworks;

rate at which the earthworks are undertaken;

proximity of residents or sensitive receptors to the remedial works; and

how effective the management controls are for controlling air quality.

1.2 Proposed Remediation of Helena East The proposed remediation of Helena East represents a significant earthworks event that requires a strong commitment to management and dust control. The MRA has demonstrated through its management team that it can undertake these large scale earthworks whilst ensuring air quality is maintained at the strict standards set by the Department of Environment and Conservation (DEC) (formerly Department of Environment (DoE)) and the Department of Health. The following is a review of how MRA has managed and monitored air quality during the remediation of various parts of the site including Area E, Helena West Area B, C, AND D (WAPS) and the Helena Street Extension. Experience has shown that air monitoring alone will not ensure maintenance of air quality and that an effective understanding of dust management along with real time air monitoring ensures the best outcome.

2. AIR EMISSIONS MANAGEMENT AT PREVIOUS SITES 2.1 Area E Air Monitoring Review The remediation of Area E included the excavation and relocation of localised areas of contaminated shallow soil with concentrations above those suitable for an industrial landuse. The soils were contaminated with heavy metals and/or asbestos fibres. Particulate or dust emissions were the primary mode of transport for these contaminants. In addition to the contaminants in the dust is the fact that fine particulates defined as less than 10 microns (PM10) are themselves a potential health issue. The total volume of soil removed was relatively minor at Area E. Monitoring was extended to include the roadworks associated with construction of Clayton Street due to the large amount of low level contaminated soil that was removed for geotechnical reasons. This additional monitoring was not required by the DoE, but was undertaken by MRA demonstrating a strong commitment to management and dust control. 2.1.1 On-site Air Monitoring for Dust An on-site portable aerosol monitor was used to measure PM10, which was moved in response to where earthworks were occurring and located immediately downwind. These monitors are a light scattering device and provide real time measurement of fine particulates but are limited in that they are not covered by an Australian Standard and are thus subject to a degree of inaccuracy. The air quality standard applied for the remediation and roadworks was the NEPM (National Environmental Protection Measure) of 0.05mg/m3. This standard is a target value for ambient air quality and is protective of the most sensitive persons such as those with respiratory complaints or asthma. On-site personnel were requested to wear personal air samplers for collecting respirable dust over the two days of specific remediation earthworks for assessing occupational exposure which is set at 5mg/m3. WorkSafe Western Australia provided occupational exposure standards. A high volume air sampler (HVAS), which measured total suspended particulates (TSP), was located near the earthworks. The HVAS uses a fan to draw large amounts of air through a filter paper where dust is deposited. The dust from the monitor was also tested for heavy metals known to occur in the waste fill. This type of monitoring was not real-time as the filter papers needed to be weighed and analysed at a laboratory. The HVAS method is to a recognised Australian Standard and as such could be directly compared to standards for compliance purposes. Occupational exposure standards were used for assessment purposes. Asbestos fibres were tested for using an elutriator method where a medium flow pump and baffle is used to draw fine particulate air onto a filter paper where it can then be inspected in the laboratory for fibres. It should be noted that the asbestos fibre monitoring collects any fibre that conforms to a particular size and that the fibre collected may not actually be asbestos. The elutriator method could provide a theoretical asbestos fibre detection level of 0.0002 fibres/mL. It should be noted that subsequent advice from the Department of Health was that this method was not to a recognised Australian Standard for collection and as such the level of detection could not be validated with any surety. Results of this monitoring indicated that no monitored site person was exposed to unsafe levels of contaminants.

2.1.2 Off-site Air Monitoring for Dust No off-site monitoring for dust was undertaken due to the small magnitude of remedial works and the fact that the site was relatively isolated from potentially sensitive receptors at the time. 2.1.3 Summary – Area E Air monitoring for Area E indicated that earthworks at the site did not create adverse air quality and that with good dust management practices and favourable weather conditions, the air quality could be maintained below the NEPM standard (for dust of 50ug/m3 24 hour). Advice back on the asbestos monitoring method was that only the National Occupational Health and Safety Commission (NOHSC) Membrane Filter method should be used for the determination of airborne fibre. This method provides a detection limit of 0.01fibres/mL, which is 50 times higher than the elutriator method. If a fibre requires confirmation as asbestos then the unused portion of the filter paper will need to be tested using Scanning Electron Microscopy (SEM) techniques with an Energy Dispersive X-ray probe (EDAX). 2.2 Helena West Air Monitoring Review The remediation of Helena West included the excavation and relocation of significant amounts of waste fill (63,000m3) and recovery of oily sludges from the base of the Coal Dam by means of a dredge, which was then allowed to settle and dry in purpose built ponds. As such, the air monitoring focused on two distinct contaminant sources; particulates from the excavation and handling of the waste fill, and volatile emissions from the dam sludges. The waste fill was contaminated principally with heavy metals and asbestos fibres at particular areas. The sludges were removed as dredge spoil and thus were in a liquid form. These sludges were contaminated mostly with aliphatic hydrocarbons but also potentially with more volatile forms of hydrocarbons such as benzene, xylenes and naphthalene. When the oils had settled, the sludge was mixed with cinder ash and then placed on top of limestone drying beds for a period of a few months. As the sludges dried they liberated sulphur compounds in the form of sulphur dioxide and hydrogen sulphide. Remedial works commenced in January 2004 with the dredging of the base of the Coal Dam, and in February 2004 with the earthworks. Air monitoring was separated into two receptor groups; on-site personnel or occupational exposure and off-site or the public. As such, there were two distinct air quality standards; those for occupational exposure and the other being public exposure. TheDECwith advice from the Department of Health provided public exposure standards to be used during the remediation phase. The primary method for managing dust suppression was through use of dedicated water carts that continuously wet down the earthworks area and access tracks. 2.2.1 On-site Air Monitoring for Dust On-site portable aerosol monitors were used to measure fine particulates that were moved in response to where earthworks were occurring and located immediately downwind. These monitors are not covered by an Australian Standard and thus subject to a degree of inaccuracy. However they were used as a screening tool to estimate on-site air quality.

On-site personnel were requested to wear personal air samplers from time to time, which collected respirable (fine particulates) dust and the other asbestos fibres on a filter paper. This method of monitoring was to ensure compliance with occupational exposure standards, which are less stringent in comparison to public standards. A HVAS was located near the earthworks, which measured TSP and heavy metals known to occur in the waste fill. As the HVAS required filter papers to be changed daily and then processed in the laboratory, results took a number of days to be calculated. As such this air monitoring provided historical data (for documentation) rather than real time concentrations. The HVAS method is to a recognised Australian Standard and as such could be directly compared to standards for compliance purposes. Results of this monitoring indicated that no monitored site personnel were exposed to unsafe levels of either contaminant. Where works were undertaken in known asbestos impacted areas, machinery cabins were kept closed and air conditioning set to recirculation mode. 2.2.2 On-site Air Monitoring for Other Compounds This monitoring applied specifically with regard to the sludges recovered from the Coal Dam. Monitoring was undertaken on-site, generally in the downwind direction of the drying ponds within 50m. Of primary health concern was the Volatile Organic Compound (VOC) benzene which is a known carcinogen. Initially air was monitored using specific plastic sampling bags that drew in air. These bags detected low levels of VOCs, which were subsequently considered to be associated with residual contaminants within the bag rather than actual air quality. This sampling method was subsequently modified to absorbent tubes, which provided more accurate and reliable data that was consistently lower than the bags. Both methods required laboratory analysis and as such did not provide real time measurements. Polycyclic aromatic hydrocarbons were measured using an absorbent tube and filter (USEPA Method TO13). This method measured both the vapour and particulate form. Concentrations were significantly below the public standard, which was measured on-site close to the source. This method required laboratory analysis and as such did not provide real time measurements. A portable PID (Photoionisation Detector) was used to provide real time measurements of VOC emissions. This device is a screening tool and does not differentiate between compounds. It was calibrated to record all gases as benzene as this was the most significant from a human health perspective. A limitation with regard to the PID meter was the limit of detection which was 0.2ppm, more than 10 times higher than the public standard. Sulphur dioxide and hydrogen sulphide were measured using a portable gas monitor normally used for gas detection in occupational environments, which provided real time measurements. This monitor was placed near the source both during settlement and at the drying pad. At no time did the sulphur gases exceed standards for either occupational or public exposure. 2.2.3 Off-site Air Monitoring for Dust Off-site monitoring was conducted at three specific fixed stations located to the east, north and west of the site. It should be noted that the western monitor was initially sited within the work site much closer to the earthworks compared to the site boundary. The preferred location was to be within the school grounds; however limited access and a suitable site prevented this from occurring.

Two HVAS were located at each of the monitoring sites, one measured fine particulates and the other TSP. Dust from the TSP monitor was also tested for heavy metals known to occur in the waste fill. As stated, the HVAS required filter papers to be changed daily with results taking a number of days to be provided. At the western site an additional HVAS was temporarily installed to sample ultra fine particulates referred to as PM2.5 or particles less than 2.5 microns. Particles of this size are normally related to industrial air emissions rather than soil particles and as such the sampler was monitoring air quality from diesel powered vehicles and machinery. As such this data was not audited by the DoE as there was no applicable Australian Standard for sampling at the time. At each sampling station, asbestos fibres were monitored for using a personal air sampler fixed to the fence. These samplers were changed daily. At no time did the air quality with regard to heavy metals and asbestos fibres exceed the air quality standards at any monitoring station. There was however a number of occasions where the dust measured as both TSP and PM10 exceeded the standards nominated by the DoE. This was mainly in response to access tracks constructed of crushed limestone and the fine particle size associated with the clay subsoils and cinder ash in the waste fill. 2.2.4 Summary – Helena West Air monitoring for Helena West was the most extensive performed for a remediation project in WA at the time. A significant limitation with regard to compliance purposes was for particulates and the time taken to obtain results, thus the absence of real-time monitoring that could be compared directly with a standard. The portable aerosol monitors were subject to variable results and the initial units used did not all have in-built alarms when a predetermined level was exceeded. The other monitoring equipment was generally fit for purpose with again the limitation regarding real time monitoring with the exception of sulphur compounds. The PID meter provided real time measurement of VOCs, however the instrument was not sensitive enough for monitoring against public standards or capable of identifying individual compounds. There were a few issues with the siting of the particulate HVAS monitors, which often became exposed to sources of dust not always related to the site works. The northern monitor site was adjacent to the freight rail line and potential soot emissions from passing trains. The eastern monitor was near a gravel car parking area, limestone access track and a spur line into the Workshops. The western monitor was not on mains power and was subject to some influence from soot emissions from the diesel generator. This confirms the importance of locating such monitors away from secondary sources of air emissions. 2.3 WAPS (Area B, C, and D) Air Monitoring Review The remediation of WAPS included the excavation and relocation of a significant quantity of waste fill (99,000m3) and recovery of hydrocarbon impacted waste fill from the site of the former solvent dump. This remediation was scheduled to occur prior to Helena West and as such the Management Plan prepared for the works was cleared by the DoE prior to the results and performance of Helena West. The waste fill was contaminated principally with heavy metals and asbestos fibres at particular areas. The solvent dump contained the VOC’s benzene and chlorobenzene.

Remedial works commenced in July 2004 with a start to the solvent dump in August. As for Helena West, air monitoring was separated into two receptor groups; on-site personnel and the public. Close to the remedial works was the CADCOM facility staffed by the WA Police service; this building was considered the closest public receptor. Air quality standards were set for the remediation based on recognised standards and advice from government departments. Given the start to remedial works was in mid winter, ground conditions were very damp and not conducive to dust generation. Nonetheless, a water cart was made available to control any dust that was generated mainly in response to access tracks used by dump trucks. 2.3.1 On-site Air Monitoring for Dust On-site monitoring was kept to occupational exposure through the use of personal air samplers for asbestos fibres, respirable dust and inspirable lead dust as well. Experience with the Helena West remediation showed aerosol monitors were not defendable with regard to compliance against standards. Therefore real time monitoring for fine particulates was undertaken as described below at the site boundary. Results of this monitoring indicated that no monitored site person was exposed to unsafe levels of either contaminant. Where works were undertaken in known asbestos impacted areas, machinery cabins were kept closed and air conditioning set to recirculation mode. 2.3.2 On-site Air Monitoring for Other Compounds This monitoring was applied specifically with regard to the removal of the hydrocarbon contamination associated with the solvent dump. The contaminants of concern were VOC’s including BTEX (benzene, toluene, ethylbenzene and xylenes) and chlorobenzene. An absorbent tube as per USEPA method TO17 was employed to monitor air quality at the excavation face and where the material was being placed for future bioremediation, which due to site constraints did not eventuate but rather the soil was disposed off-site to landfill. This method provided a 1 hour ‘snapshot’ of air quality downwind of the contaminant source. The tubes were sent off for laboratory analyses which took a few days for results. Real time monitoring was undertaken using a PID meter which provided VOC results down to 0.2ppm. This was used as a screening tool and as an alert to stop earthworks if concentrations exceeded a predetermined level set at 5ppm. The PID ran continuously when there was earthwork and data logged regular measurements. 2.3.3 Off-site Air Monitoring for Dust Off-site monitoring for fine particulates and asbestos fibres was conducted at three specific fixed stations located to the east and west of the site, with one outside the northern boundary within the CADCOM grounds. The CADCOM location was placed in front of the building near the air conditioning inlet so it was sheltered from any off-site wind direction but would collect any dust emanating from the site. The monitors used were TEOMs (Tapered Element Oscillating Microbalance) which complied with Australian Standards for the measurement of fine particulates (PM10). A wind vane was installed at the eastern monitoring site to provide site specific wind measurements of speed and direction. The TEOMs were connected to a phone system that would send out an SMS text alarm when air quality criteria had been exceeded. This allowed for an immediate response to site activities to manage dust. A daily summary would be provided by

email the following morning advising of predominant wind direction and measured levels at each of the monitoring sites including maximum 10 minute values. Asbestos fibres were monitored for at each station using a personal air sampler fixed to the fence. These samplers were changed daily. A HVAS was run for the initial three weeks of remedial works to confirm TSP concentrations and heavy metal contaminant levels at the CADCOM facility. At no time did the air quality with regard to heavy metals and asbestos fibres exceed the air quality standards at any monitoring station. There was however a number of occasions where the dust measured as PM10 exceeded the standards nominated by the DoE. This was mainly in response to drying weather conditions as the remediation moved into summer 2004/2005 and the exposed clean clay subsoil being subject to wind erosion. Water carts were always directed as a matter of priority towards the areas of waste due to the contaminant potential. There were a large number of occasions where dust was generated from off-site sources east of the remediation works. 2.3.4 Off-site Air Monitoring for Other Compounds VOC monitoring was applied at the CADCOM facility during the removal of hydrocarbon impacted fill from the site of the solvent dump. This comprised the absorbent tube as per USEPA method T017. A passivated canister as per USEPA method T015 was also used to collect air samples over a longer period (8 hours) for three days at the CADCOM facility during removal of the solvent dump. The canister method is an evacuated cylinder that draws air in at a specified rate, which includes analyses for a more extensive suite of VOCs compared to the T017 method. This testing confirmed the absence of other types of volatiles. Monitoring indicated that the CADCOM facility did not experience any VOC levels above the laboratory detection limit and that gases were only detected immediately adjacent to the contamination source and at concentrations below the standard. 2.3.5 Summary – WAPS (Area B, C, & D) Air monitoring for WAPS included real time monitoring for fine particulates in accordance with Australian Standards, which enabled an immediate response to air quality issues. The TEOMs provided vector analyses that enabled determination of the contribution of the site to air quality and so the assessor could differentiate off-site sources. This was an important feature as there were consistent dust emissions from off-site sources onto the work area. Use of TEOMs obviated the need for utilising portable aerosol dust monitors which are unable to be directly compared with standards due to data reliability issues. The VOC monitoring was constrained with regard to real-time monitoring of such emissions and therefore the PID meter was useful as an immediate measuring tool for checking air quality. Commencement of remedial works in winter significantly assisted in the management of dust at the site compared to starting in drier conditions. Siting of the air monitors away from potential dust sources aided in reducing the number of false alerts due to localised non-contaminated dust emissions.

2.4 Helena Street Extension Monitoring Review The remediation of Helena Street Extension included the excavation and disposal to landfill of waste fill (4,200m3) comprising cinders and ash. This remediation occurred following remediation of Helena West and WAPS (Area B, C, AND D). The Helena Street Extension area was excised from Helena East and after referral to the DoE was informally assessed. However, the DoE reviewed and commented on the Dust and Air Quality Management Plan. The waste fill was contaminated principally with heavy metals. Asbestos containing material had previously been removed from one portion of Helena East, but had not been detected in surrounding soils. Remedial works were undertaken in April and May 2005. A draft of the Dust and Air Quality Monitoring Plan (DAQMP) was developed by ENV Australia Pty Ltd for the remedial works, which was provided at the initial referral stage of the Helena Street extension. The report was subsequently reviewed by the Air Quality Section of the DoE and its advice was included in a revised Plan issued to the DoE by ENV on 26/4/05. ATA Environmental co-ordinated the air sampling program that was contracted to Compliance Monitoring of Lesmurdie. SGS Laboratories of Welshpool was subcontracted to perform the asbestos monitoring and testing. The DAQMP identified specific air quality parameters to be measured. This included asbestos fibres and fine particulates in the form of PM10 (air particulates with a size of 10 microns or less). Asbestos fibres were tested for as a precautionary measure on the premise that there had been asbestos demolition activity prior to remediation and that there may have been some residual fibres. 2.4.1 Off-site Air Monitoring for Dust Air monitoring to the Australian Standard was performed at a permanent monitoring station located to the immediate south of the TAFE building as this represented the most significant potential receptor in terms of number of persons. The TEOM monitor operated constantly for the entire duration of the works, including nights and weekends. At no time was the Corrective Action Response Level or Work Stoppage values exceeded. The 24 hour NEPM criteria of 50µg/m3 was not exceeded. A portable aerosol monitor was used to check fine dust air quality in locations other than the TAFE building. The Dust Trak monitor was used during the work day to monitor air quality for dust management purposes. At no time was the Corrective Action Response Level or Work Stoppage values exceeded. The 24 hour NEPM criteria of 50µg/m3 was not exceeded for the day average. 2.4.2 Off-site Air Monitoring for Other Compounds Asbestos was monitored at two locations twice daily within the excavation area, at the downwind site boundary with the works. Asbestos levels were below the limit of reporting of 0.01 fibres/mL in all samples analysed. Fibres were detected on the filter papers at up to 6 fibres/100 field. Two samples with the higher fibre counts were subject to SEM (Scanning Electron Microscopy) analysis to

determine whether they were in fact asbestos. Neither sample contained fibres that were confirmed as asbestos by SEM. 2.4.3 Summary – Helena Street Extension Results of the Helena Street Extension Remedial Works air monitoring program indicate that the air quality associated with the remedial works complied with the nominated DoE and NEPM criteria.

APPENDIX B

SOIL SAMPLING RESULT SUMMARIES FOR HELENA EAST SAMPLING PROGRAMS

TABLE B1 Heavy Metal Concentrations – Average and Range in Waste Fill and Soil

Helena East

Heavy Metals Average (mg/kg) Range (mg/kg) No. Samples Antimony 44.4 3 - 1,300 123 Arsenic 14.5 4 - 87 254 Barium 26.0 1 - 160 133 Cadmium 1.0 0.1 - 21 254 Chromium (Total) 39.1 3 - 450 253 Chromium (VI) 5.5 11 - 14 37 Cobalt 14.6 2 - 360 45 Copper 427.1 1 - 16,000 254 Lead 360.5 4 - 13,000 254 Manganese 87.0 0 - 566 78 Mercury 0.3 0.03 - 4.7 254 Nickel 20.6 1 - 660 254 Tin 61.5 7 - 800 133 Zinc 229.7 1 - 6,200 254 Cyanide (Total) 9.4 1.3 - 30 34 Note: The results are biased toward the ‘worst case’ scenario, since sampling was undertaken at various depths to identify maximum contamination. Source: ATA Environmental (2005). Helena East Precinct Remediation and Redevelopment Public Environmental Review. Prepared for Midland Redevelopment Authority. March 2006.

TABLE B2:

Metal Concentrations – Average and Maximum in Waste Fill Helena West 1

Area H1A (36

Samples) Area H2 (10 Samples) Area H3 (60 Samples)

Metals Average Range Average Range Average Range Antimony2 2 <1 - 12 4 <1 - 13 5 <1 - 60

Arsenic 51 <1- 1040 6 <1 - 15 49 <1-1710 Barium2 239 1 - 1070 305 50 - 880 207 2 - 688

Cadmium 1 <1 - 2 4 <1 - 14 1 <1 - 4 Chromium 15 <1 - 35 15 8 - 21 22 <1-444

Copper 385 <1- 7870 213 10 - 866 424 1-3930 Lead 428 <1- 4580 484 21- 2500 315 2-3140

Manganese 180 2 - 439 304 38- 1090 212 4 - 786 Mercury 1.9 <0. -17.8 1.4 <0.1-11.9 0.6 <0.1-9.9 Nickel 21 <1 - 67 30 6 - 42 26 <1-114

Tin 48 <1- 1150 60 2 - 551 48 <1-606 Zinc 206 1 - 1410 2043 32- 8520 229 3-1600

Note: These results include Waste Fill only, since Surface Soil results were presented in a separate table. All results expressed as (mg/kg) Sources: 1. Unless otherwise noted, data source is: EPA (2003). Remediation of Midland Railway Workshop site, Helena

West, Midland. Proponent: Midland Redevelopment Authority. Report and recommendations of the Environmental Protection Authority. Perth, Western Australia. Bulletin 1111. September 2003. Page 8, Summary of Site Contamination – Waste Fill.

2. ENV (2003). Detailed Site Investigation Helena West, Midland Railway Workshop Site. Prepared for Midland Redevelopment Authority. Prepared by ENV Australia. March 2003.

TABLE B3 Number of Sample Locations Where Asbestos was Identified

Area Total Locations with

Asbestos Detected Total Locations

Analysed Percentage Detected

North of copper shop/power house 21 15 13% West of Pattern Store and Panel Shop 2 26 8%

Block 1 to 3, and south of stores 1 32 3% East of Panel Shop, West of Block 3, to southern embankment 35 80 44%

Southern Embankment 4 10 40% Notes: 1 Asbestos was detected beneath floor of Heritage listed Foundry building. Heritage building will be remediated separately as part of the Heritage Restoration Works (ATA, 2006).

TABLE B4: Petroleum Hydrocarbons and PAH Concentrations – Average and Range in

Waste Fill Soil

Petroleum Hydrocarbons Average (mg/kg)

Range (mg/kg)

No. Samples

Benzene 0.0 0 - 0 98 Toluene 0.0 0 - 0 98

Ethyl-benzene 4.8 0 - 4.8 98 Xylenes 28.0 0 - 28.0 98

C6-9 33.0 0 - 33.0 142 C10-14 466.9 100 - 466.9 142 C15-28 1,553.2 510 - 1,553.2 142 C29-36 130.5 120 - 1,000 142 C>36 60.4 20 - 240 142 C6-15 480.8 100 - 1,700 63

C16-35 aromatics 628.4 411 - 2,330 63 C16-35 aliphatics 1,130.9 116 - 5,960 63

Polycyclic Aromatic Hydrocarbons

Naphthalene 8.5 0 - 34 47 2-Methylanphthalene 13.0 0 - 68 47

Acenaphthylene 0.0 0 - 0 47 Acenaphthene 0.0 0 - 0 47

Fluorene 1.0 0 - 2.2 47 Phenanthrene 1.0 0 - 3.9 47 Anthracene 0.1 0 - 0.1 47

Fluoranthene 0.1 0 - 0.4 47 Pyrene 0.2 0 - 0.4 47

Benzo[a]anthracene 0.2 0 - 0.2 47 Chrysene 0.2 0 - 0.2 47

Benzo[b]fluoranthene 0.2 0 - 0.2 47 Benzo[c]fluoranthene 0.2 0 - 0.2 47

Benzo[a]pyrene 0.2 0 - 0.2 47 Indeno[1,2,3,-c,d]pyrene 0.2 0 - 0.2 47 Dibenza[a,h]anthracene 0.0 0 - 0 47

Benzo[g,h,l]perylene 0.0 0 - 0 47 Total PAH 53.0 0 - 107 47

Note: Sampling was undertaken at various depths to identify maximum contamination so that results are biased toward ‘worst case’ scenario.

TABLE B5: Volatile Organic Compounds – Average and Range in Waste Fill Soil

Volatile Organic

Compounds Average (mg/kg)

Range (mg/kg)

No. Samples

Isopropylbenzene 1.05 1 - 1.1 91 n-Propylbenzene 2.2 1.1 - 3.4 91

1,3,5-Trimethylbenzene 16 1.7 - 34 91 1,2,4-Trimethylbenzene 23 5.8 - 48 91

sec-Butylbenzene 2.3 1.7 - 3 91 4-Isopropylbenzene 3.13 2.3 - 4.7 91

n-Butylbenzene 1.6 1.3 - 1.9 91 cis-1,2-Dichloroethene 3.9 3.9 - 3.9 91

Tricholoethene 1.8 1.2 - 2.4 91 Tetrachloroethene 40.7 16 - 56 91

Note: No other common Volatile Organic Compounds (VOCs) were detected

APPENDIX C

SITE CLASSIFICATION ASSESSMENT CHART

FOR HELENA EAST

APPENDIX D

BUREAU OF METEOROLOGY MONTHLY DATA FOR

PERTH AIRPORT

APPENDIX E

SUMMARY STATISTICS FOR METALS IN SOILS

TABLE 1 APPENDIX E Summary Statistics For Metals In Soils

Air Quality Management Plan Helena East Precinct Remediation And Redevelopment

Ant

imon

y

Ars

enic

Bar

ium

Cad

miu

m

Chr

omiu

m (T

otal

)

Chr

omiu

m (V

I)

Cob

alt

Cop

per

Lead

Man

gane

se

Mer

cury

Nic

kel

Tin

Zinc

Assessment Criteria (mg/kg) EIL 20 20 400 3 50 NV 50 60 300 500 1 60 50 200 HIL 'A' 30 100 5370 20 NV 100 100 1000 300 1500 15 600 46900 7000 HIL 'F' 820 500 100000 100 NV 500 500 5000 1500 7500 75 3000 100000 35000

Soil Analytical Result (mg/kg) Mean 44 15 26 1 39 6 15 427 361 87 0 21 62 230 Max 1300 87 160 21 450 14 360 16000 13000 566 5 660 800 6200 Min 3 4 1 0 3 11 2 1 4 0 0 1 7 1 SD 183 14 35 2 66 4 57 1431 1198 104 1 58 132 612 95%UCL 40 8 31 1 46 4 28 582 492 108 0 27 69 293

APPENDIX F

DEC LETTER, DUST AND AIR QUALITY MANAGEMENT FOR ANI BRADKEN

APPENDIX G

EXAMPLE FORMS: Daily Inspection Form

Air Quality Exceedance Report Sheet

2005-004-PER_034_ks_V6 ATA Coffey Environments

DAILY INSPECTION FORM

Dust rating scale

1. No visible dust present 2. Some visible dust present; dust contained within exclusion zone 3. Some visible dust present; dust leaving exclusion zone 4. Continuous visible dust leaving exclusion zone – corrective action required 5. Heavy dust leaving exclusion zone (or strongly detectable vapours/odours) with potential to cause offsite impacts – corrective action required (fill in and attach Air Quality

Exceedance Report Sheet)

Site Name/Project Number: Helena East/ Name: Date & time: SITE CONDITIONS Weather (wind, temp): Visible dust rating: (1-5; see dust rating scale below) Detectable odour? Who is wearing personal air monitor in active zone? (e.g. excavator driver, supervisor, etc) Location of mobile DusTrak monitor – check positioned down wind; sketch on map:

Location of earthworks (grid cells ID) Number of excavations open:

Location of Stockpiles: Number of stockpiles:

Are roads dusty? DUST SUPRESSION Is wind fencing intact? Location of WF appropriate? Check integrity of stockpiles, application of Dustex, hydromulch (if any): Are sprinklers operational? Is water cart available? Complaints? Any offsite works possibly impacting air quality? Any issues with management measures? Corrective Action required? (if yes, describe) – Discuss with Project Manager?

MRA-

Comments:

MRA-2005-004-PER_034_ks_V6 ATA Coffey Environments

AIR QUALITY EXCEEDANCE REPORT SHEET

Site Name: HELENA EAST - MIDLAND WORKSHOPS Project Number: Site Supervisor: Report Date and Time: Location Of Alarmed Monitor (Circle) CADCOM NORTH WEST Result In ug/m3 Date of Exceedance: Time & Length of Exceedance: Wind Direction At Time: Site Activity At Time Of Exceedance:

<600 ug/m3 – CORRECTIVE ACTION (investigate cause) AIR RESULT (OVER 1 HOUR) >600 ug/m3 – WORK STOPPAGE (stop work immediately) Other monitors (describe)

INVESTIGATE CAUSE

Inspect Monitoring Site Notes 1 – Check for emissions of visible dust/ odour? 2 – Note any earthworks in adjacent areas? 3 – Note wind direction relative to earthworks 4 – Determine whether site activity is affecting monitor.

If site activity was the cause of the exceedance, see below.

DUST SUPPRESSION CHECKLIST Notes 1 – Are areas wetted down? 2 – Is the water cart/canon active? 3 – Is enough water being applied? 4 – Are there extreme weather conditions? 5 – Reduce level of site activity or size of work area and increase dust suppression until conditions improve.

6 – Assess all dust suppression on site

CORRECTIVE ACTION UNDERTAKEN (describe corrective actions) OUTCOME (duration of event, effect of actions): Note: Refer to Dust and Air Quality Management Plan

RA-2005-004-PER_034_ks_V6 ATA Coffey Environments

AIR QUALITY DIAGRAM – HELENA EAST (to accompany inspection form or report sheet)

Show the following Name: ____________________ • Location of alarm (if exceedance) Date & Time:_______________ • Wind direction (arrow) Project No.:________________

M

• Location of active excavation • Stockpile locations • Mobile Dustrak Monitor location

APPENDIX H

CORRESPONDENCE DOCUMENTING REVIEW OF DUST AND AIR QUALITY

MANAGEMENT PLAN (DEC AQMB,

DOH, AUDITOR)

1. DoE AQMB Comments (14/06/06)

2. ATA Response Letter to I-Lyn Loo, EPA Service Unit (Response to AQMB Comments) (18/07/06)

3. AQMB Comments on ATA Responses (24/08/06)

4. Comment Letter from Department of Health (25/09/06)

5. Comment Letter from Auditor Jeremy Hogben, ERM (11/05/07)

6. Addendum to Comment Letter from Auditor Jeremy Hogben, ERM (15/05/07)

7. ATA Responses to Auditor Comments

Documents

ATA Environmental - MRA · ATA Environmental _____ A review of contamination identified in previous investigations and additional investigations by ATA for inclusion in a Public Environmental