ATONS LANES RRC · 2019-09-11 · 5.4.1 General Definition 31 5.4.2 Exposure Standards – Asbestos 32 ... (Any building product or material that contains asbestos. AF Asbestos Fines

Occupational Health and Safety Consultants A.B.N. 12 608 093 134

Environmental Management Consultants 48 / 378 Parramatta Road, Homebush NSW 2140

P.O. Box 4266, Homebush NSW 2140

Phone: (02) 9746 3244 Fax: (02) 9746 3266 Email: [email protected] Web: www.hibbs.com.au

PATONS LANES RRC

CONTAMINATION & ASBESTOS MANAGEMENT PLAN, STAGE 1 WORKS PATONS LANE RESOURCE RECOVERY CENTRE

REFERENCE NO. S9171-A3

MARCH 2019

Copy: 1 Copies: 1. Patons Lanes RRC

2. Ian Swane & Associates P/L 3. Hibbs & Associates Pty Ltd.

PATONS LANES RRC - REFERENCE NO. S9171 A3 – FINAL MARCH 2019 HIBBS & ASSOCIATES PTY LTD © 2019 PATONS LANE RESOURCE RECOVERY CENTRE: CONTAMINATION & ASBESTOS MANAGEMENT PLAN PAGE: 2.

CONTAMINATION & ASBESTOS MANAGEMENT PLAN PATONS LANE RESOURCE RECOVERY CENTRE

123 – 129 PATONS LANE, ORCHARD HILLS NSW 2748

Prepared for

PATONS LANES RRC 123 – 129 Patons Lane,

ORCHARD HILLS NSW 2748

by

HIBBS & ASSOCIATES PTY LTD 48 / 378 Parramatta Road,

P.O. Box 4266, HOMEBUSH NSW 2140

www.hibbs.com.au Telephone: (02) 9746 3244 Facsimile: (02) 9746 3266

Copyright © Hibbs & Associates Pty Ltd 2017 Our Reference: S9171

March 2019

Prepared by: Authorised by:

Julie Porter Principal Environmental Consultant

Philip Hibbs Principal Consultant BSc, GDOH, FAIOH, COH

Date: 21 March 2019

Revised by:

Pip Tildesley Environmental Consultant


PATONS LANE RESOURCE RECOVERY CENTRE CONTAMINATION & ASBESTOS MANAGEMENT PLAN

TABLE OF CONTENTS PAGE

1.0 Introduction 11 1.1 Overview 11 1.2 Management Plan Framework 11 1.3 Purpose 13 1.4 Context 13 1.5 Project Brief- Bund Wall Management 14 1.6 Scope of Works of the Management Plan 14

2.0 Description of Operations and Works 16 2.1 Staging 16 2.2 Site Establishment and Construction of the RRA 17

2.2.1 Site Establishment 17 2.2.2 Construction of the RRA 19 2.2.3 Operation 20

3.0 Compliance with Regulatory Requirements 24 3.1 Planning Application MP09_0074, Conditions of Consent 24 3.2 Implementation of this CAMP 26

4.0 Report Limitations & Disclaimer 27 5.0 Asbestos – Properties and Health Effects 28

5.1 Introduction 28 5.2 Asbestos – Properties and products 28 5.3 Brief Summary of Health Effects 28

5.3.1 Asbestosis 29 5.3.2 Lung Cancer 30 5.3.3 Mesothelioma 30 5.3.4 Relative Risks 30

5.4 Exposure Standards 31 5.4.1 General Definition 31 5.4.2 Exposure Standards – Asbestos 32

6.0 Previous Reports and Available Information 33 6.1 Previous Reports 33

6.1.1 DP 2009 Report 33 6.1.2 DP 2010 Report 34 6.1.3 Aquaterra 2010 Report 34

6.2 Present Project Conditions 35 6.2.1 Overview 35 6.2.2 Site Inspection 35

6.3 Known Impacts 36 6.3.1 Extent 36


6.3.2 Summary of Contamination Identified 36 6.3.3 Contamination Assessment – Non Asbestos Contaminants 37

7.0 Remediation Approach 38 7.1 Options for Soil Remediation 38 7.2 Remediation Goals 38 7.3 Evaluation of Alternative Remediation Methods 39

7.3.1 Known Area of Asbestos Contaminated Soil (Special Waste) 40 7.3.2 General Bund Re-profiling 40 7.3.3 Non-asbestos Contamination 41

8.0 Soil Acceptance Criteria 42 8.1 General 42 8.2 Land Use Scenarios 42 8.3 Soil Asbestos Criteria 42 8.4 Soil Acceptance Criteria Non-asbestos Contaminants. 43 8.5 Assessment of Soil Samples for Asbestos 44 8.6 Sampling Analysis Quality Plan 45

9.0 Proposed Bund Wall Reconstruction/Deconstruction 46 9.1 Bund Reconstruction/Deconstruction Process 46 9.2 Final Bund Design 47

9.2.1 Site Establishment 47 9.2.2 Final Site Restoration 47

9.3 Estimated Quantities 47 9.4 Material Tracking 49 9.5 Work Schedule 49

10.0 Administrative Structure 51 10.1 Objectives and Responsibilities 51

10.1.1 Occupational Hygiene Consultant 52 10.1.2 Environmental Consultant 52 10.1.3 EPA Accredited Site Auditor 52

10.2 Reference Material 52 10.3 Asbestos Awareness Training 53 10.4 Asbestos Records 55

11.0 Bund Wall Material Characterisation and Validation 56 11.1 Current Site Characterisation 56 11.2 Known Area of Asbestos Contaminated Soil (Special Waste) 56 11.3 Onsite Relocation of Excavated Natural Materials 56 11.4 Onsite Relocation of General Solid Waste (non-putrescible) 57 11.5 Investigation for Areas in the Vicinity of Test Bores 6, 7, 8, 9, 17, and 18. 58 11.6 Surplus Material for Off-site Reuse 58 11.7 Waste Classification 59 11.8 Validation of Final Bund Surfaces 59 11.9 Validation Plan for End of Project Life 59

12.0 Asbestos and Environmental Management During Earthworks 61 12.1 Control of Earthworks Activities and Dust Management 61 12.2 On-site Movement of Asbestos Waste 62 12.3 Excavation and Material Handling Procedure 62 12.4 Burial into Containment Cell 63


12.5 Stockpiling 63 12.6 Environmental Asbestos Air Monitoring 63

12.6.1 Environmental Asbestos Air Monitoring Programme 64 12.6.2 Baseline and Source Control Monitoring 64 12.6.3 Works Monitoring 64 12.6.4 Asbestos Air Monitoring Action Levels / Emergency Response 64

12.7 Decontamination and PPE 65 12.8 Decontamination of Trucks and Equipment 66 12.9 Air Quality 66 12.10 Surface Water Mangement 67 12.11 Sediment and Erosion Control 67 12.12 Noise Management 67 12.13 Unexpected Finds Protocol 67 12.14 Contingency Risk Management 68

13.0 Restoration and Capping 70 13.1 Containment of Asbestos Waste 70 13.2 Materials to Remain in the Bund Walls 70 13.3 Landscaping 70 13.4 Survey 70 13.5 Record Keeping 71 13.6 Reporting 71 13.7 Community Consultation 71

14.0 References 72 Appendix 1: Site Location Plan and Survey 73 Appendix 2: Consultation with Agencies 75 Appendix 3: Previous Bund Wall Investigation 83 Appendix 4: Aquaterra Groundwater Tables 85 Appendix 5: Site Assessment Criteria 88 Appendix 6: Sampling Analysis Quality Plan 90 Appendix 7: Bund Layout Stage 1 101 Appendix 8: Final Design Surface 103 Appendix 9: Unexpected Finds Protocol 108 Appendix 10: Part B Site Audit Statement 111


List of Tables Table 1: Legislation Summary 24 Table 2: Consent Conditions Summary 25 Table 3: Remediation Option Appraisal 39 Table 4: Health Screening Levels (w/w) 43 Table 5: CMP Responsibilities 51 Table 6: Response Levels & Actions 65 Table 7: Risk Management Actions 69

List of Figures Figure 1: Landfill Environmental Management Plan 12 Figure 2: Management Plan Approval Process 12 Figure 3: Site Establishment Activities 21 Figure 4: Recycling and Re-processing Area 22 Figure 5: Landfill Cell 1 General Arrangement 23

General Terms and Abbreviations

The following general terms, abbreviations and definitions are used in the Contamination and Asbestos Management Plan.

Term Description

AC Asbestos cement

ACD Asbestos contaminated dust or debris

ACM Asbestos Containing Materials (Any building product or material that contains asbestos.

AF Asbestos Fines

AIOH Australian Institute of Occupational Hygienists. Inc.

Amended NEPM

National Environment Protection (Assessment of Site Contamination) Measure 1999 (amended April 2013)

Asbestos The fibrous form of the mineral silicates belonging to the serpentine and amphibole groups of rock-forming minerals, including: actinolite, amosite (Brown Asbestos), anthophyllite, chrysotile (White Asbestos), crocidolite (Blue Asbestos), tremolite, or any mixture containing one or more of these.


Term Description

Asbestos Removal Contractor

the Class A licensed asbestos removal contractor experienced in the large-scale removal of friable asbestos-containing material.

ASC Assessment of Site Contamination

ASS Acid Sulfate Soils

BTEX Benzene, toluene, ethylbenzene and total xylenes

Bonded (asbestos)

products containing asbestos bound in a permanent matrix (e.g. VAT, asbestos cement, electrical backing boards). See also Friable.

C&D Construction and Demolition

CLM Contaminated Land Management Act 1997

Certified Occupational Hygienist

an Occupational Hygienist certified as competent by either the Australian Institute of Occupational Hygienists, Inc., or a NAR certification scheme recognised by the International Occupational Hygiene Association (IOHA).

Code of Practice: Asbestos Management

Safe Work Australia, “How to Manage and Control Asbestos in the Workplace – Code of Practice 2016”.

Code of Practice: Asbestos Removal:

Safe Work Australia “How to Safely Remove Asbestos – Code of Practice 2016”.

Controlled Conditions

Working under asbestos removal conditions using personal protective equipment and observing decontamination procedures.

DECC NSW Department Environment and Climate Change

DP Douglas Partners

ENM Excavated Natural Material

EPA Environment Protection Authority

Exposure Standard

Workplace Exposure Standards represent airborne concentrations of individual substances, exposure at which, according to current knowledge, should not impair the health of, nor cause undue discomfort to, nearly all workers.


Term Description

FA Friable asbestos

FMPPR Further Modified Preferred Project Report for the Orchard Hills Waste and Resource Management Facility September 2011 (FMPPR) prepared by R.W. Corkey & Co. Pty. Ltd (RWC&C).

Friable (asbestos)

means free-asbestos, or an asbestos-containing material which, when dry, is or may become crumbled, pulverised or reduced to powder by hand pressure. See also Bonded.

GHD GHD Pty Ltd

Hazard describes something that has the potential to cause harm or adverse effect or outcome.

LOR Limit of Reporting

m Metres

m AHD Metres Australian Height Datum

mbgl Metres Below Ground Level

Membrane Filter Method

Safe Work Australia “Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres, 2nd Edition [NOHSC: 3003(2005)]”.

n/a Not Applicable

NAFD No asbestos fibres detected at the Reporting Limit of 0.1g/kg

NATA National Association of Testing Authorities, Australia

NEPC National Environment Protection Council

NEPM National Environment Protection Measure

NOHSC National Occupational Health and Safety Commission

NSW New South Wales

Occupational Hygienist

a person with the relevant qualifications and experience who is eligible for membership at a professional grade with the Australian Institute of Occupational Hygienists, Inc.

OCP Organochlorine Pesticides

OEMP Operational Environmental Management Plan


Term Description

Olfactory Relating to the sense of smell

PAH Polycyclic Aromatic Hydrocarbons

PCB Polychlorinated Biphenyl

PID Photo-Ionisation Detector

POEO Act Protection of the Environment Operations Act 1997

PPE Personal Protective Equipment

ppm Parts Per Million

Respirable fibre

a particle with a diameter less than 3 micrometres and a length greater than 5 micrometres and with a length to width ratio of greater than 3:1. These fibres are small enough and possess the aerodynamic characteristics that enable them to reach the deepest part of the lung. 1 micrometre = 1/1000th mm. The thickness of the average human hair is ~100 micrometres.

Risk describes the probability (exposure X frequency) of a specified hazardous event occurring (in a defined set of circumstances) and consequences / severity of that event. The probability is defined as the product of the frequency of exposure to the hazard and level of exposure.

RPE respiratory protective equipment that complies with the requirements of Australian Standards AS1716-2012

SAC Site Acceptance Criteria

SAQP Sampling, Analysis and Quality Plan

Safe Work Australia (SWA)

former National Occupational Health and Safety Commission (NOHSC) (http://www.safeworkaustralia.gov.au)

STEL Short Term Exposure Limits

SWMS Safe Work Method Statement

SW-NSW SafeWork NSW (www.workcover.nsw.gov.au).

TRH Total Recoverable Hydrocarbons

TWA Time-weighted Average

UCL Upper Confidence Limit

http://www.safeworkaustralia.gov.au/

http://www.workcover.nsw.gov.au/


Term Description

WES Workplace Exposure Standard


1.0 INTRODUCTION

1.1 Overview

• Recover a high proportion of clay/shale resources for the brick and construction industry

• Receive and emplace wastes and residuals from the on-site recycling

• Progressively rehabilitate a disused quarry to re-instate the agriculturally productive land consistent with the surrounding lands.

1.2 Management Plan Framework Approval was obtained from the Department of Planning and Environment (DP&E) pursuant to Condition 32 of Schedule 3 of the Project Approval to submit all but two plans (the Site Establishment Noise Management Plan and the Construction Traffic Management Plan) in stages. Stage 1 is defined as being works and activities up to the completion of the extraction of Cell 1 and is estimated to take five to seven years. Stage 1 plans, apart from those outlined above, will need to be updated prior to undertaking subsequent Stages 2 and 3. In accordance with the requirements of the Project Approval, this plan and other plans of management relevant to Site Establishment for the Project were approved by the DP&E and verified via a Pre-Site Establishment Audit process, prior to the commencement of the Site Establishment works and activities (i.e. construction works). Prior to the commencement of operations (i.e. the receipt of any waste materials) additional plans must be prepared and approved by DP&E (in accordance with the Project Approval) and verified via a separate Pre-Operational Compliance Audit. All site establishment and operations management plans are designed to work in conjunction with the Landfill Environmental Management Plan (LEMP) which provides the overarching environmental management framework for the Project. An outline of the management plan framework is shown in Figure 1. The management plan approval process is outlined in Figure 2.

• Provide a facility to assist the NSW Government to meet the recycling targets for C&I and C&D waste

The Patons Lane Resource Recovery Centre (‘the Project’), located in Orchard Hills, NSW (refer to Appendix 1 for location plan) is a resource management facility comprising Lot 40, DP 738126, within the former Erskine Park Quarry owned by SRC Properties Pty Ltd (‘the Principal’). Project Approval MP09_0074 was granted by the Land and Environment Court for the establishment and operation of the resource recovery centre in August 2012 and approved for the landfilling of commercial and industrial (C&I) and construction and demolition (C&D) waste types (general solid (non-putrescible) waste). The objectives of the Patons Lane Resource Recovery Centre (RRC) are to:


Figure 1: Landfill Environmental Management Plan

Figure 2: Management Plan Approval Process

Addtional Plans required to be incorporated in the LEMP •Construction Traffic Management Plan and Bridge Investigation

•Site Establishment Noise Management Plan (SENMP)

Plans to be incorporated in the LEMP•Quarry Operation Management Plan •Detailed Engineering Plans •Asbestos and Contamination Management Plan •Air Quality and Greenhouse Gas Management Plan •Soil, Water and Leachate Management Plan •Fire and Emergency Management Plan •Rehabilitation Plan •Landfill Environmental Management Plan •Construction Quality Assurance Plan Bund Wall, Landscaping and Vegetation Management Plan

Landfill Environmental Management Plan

Management Plan Approval Process

Proponent Consultation with Agencies in development of Plans

Submission of Plans to DP&E

DP&E Approval of Plan

Inclusion of Plans in Audit Documentation, Pre-Site Establishment Audit Completed

Lodgement of Audit with DP&E, Site Establishement works can commence

Plans Covering Stage 1 of the Project – (construction works and operation for 5-7

years)

Plans Covering Site Establishment works and construction of the RRA (i.e.

construction works only – no operations – first 18 months of the project)


1.3 Purpose

The purpose of this Contamination and Asbestos Management Plan (CAMP) is to provide an appropriate management framework for these matters for the works and activities associated with Stage 1 of the project.

In addition, this Plan specifically addresses Schedule 4 Condition 7 of Project Approval MP09-0074. The specific conditions of consent relating to this Plan are set out in Table 2 below which identifies where these particular conditions have been addressed in this Plan.

1.4 Context

This CAMP has been prepared to address the present and potential Construction and Demolition (C&D) Waste associated with the existing bund walls at the Project during Stage 1 activities (a site survey from 2007 is presented in Appendix 1):-

• Bund wall 1 – 446,947 m3 • Bund wall 2 – 105,924 m3 • Bund wall 3 – 14,189 m3 • Bund wall 4 – 373,110 m3

The CAMP has been prepared on the basis that the Project will be undertaken in general accordance with the high level concept plans described in the Further Modified Preferred Project Report for the Orchard Hills Waste and Resource Management Facility September 2011 (FMPPR) prepared by R.W. Corkey & Co. Pty. Ltd (RWC&C).

It is known that the former owner of the the Project illegally imported a range of C&D materials and incorporated those materials within sections of the existing bund walls (5m to 19m high) around the perimeter of the Project. The Proponent at that time (Dellara Pty Ltd) commissioned Douglas Partners Pty Ltd (DP) to undertake investigation works to characterise the materials within the existing perimeter bund walls.

SRC Properties Pty Ltd became the registered proprietor in March 2015 (the current Proponent).

It is estimated that approximately 900,000 tonne (t) (650,000 m3) of material (based on survey differences between Dec-02 to 4.08.07) was incorporated into the existing perimeter bund walls on the Project. Based on the results from the Douglas Partners investigations, the FMPPR provides the following estimates:

• Approximately 540,000 t (60%) of the bund material comprises excavated naturally-derived material originating from Cell 1 within the Project.

• Approximately 355,000 t (40%) of the bund material comprises general solid waste (non-putrescible) being general builder’s rubble including largely demolition waste and waste concrete and similar materials.

• Up to 5,000 t (<0.01%) of bund material comprises special waste (asbestos), which consists mainly of soil and general builder’s rubble containing small quantities of largely bonded asbestos fragments (i.e. fibro).


1.5 Project Brief- Bund Wall Management

“The FMPPR has identified that the four bund walls on the Project Site will require management throughout the life of the Project as follows”:-

1. Their outer slopes are currently too steep and need to be reduced in angle.

2. The upper sections of the existing bund walls are visible from elevated residences within The Vines Estate and Orchard Hills.

3. They are located in places on the footprint of the waste emplacement cells that are planned to be extracted as part of the Project.

4. They contain construction and demolition waste (C&D) classified as general solid waste (non-putrescible) and, in one location, a small quantity of special waste (asbestos).

5. They contain substantial quantities of excavated materials (from Cell 1) that could either be transported off site for use as fill materials or used on site for cover materials for the waste emplacement cells.

All works involving disturbance of the bund walls or management of the materials removed from the bund walls are referred to herein as the Works. All Stage 1 Works disturbing materials in the bund walls must be conducted in accordance with this CAMP.

1.6 Scope of Works of the Management Plan

The purpose of this plan is to provide procedures and protocols that, when implemented, will protect human health and the environment from contamination and asbestos present in materials that make up the bund walls surrounding the Project and to meet regulatory requirements.

This CAMP addresses the following:

• Identify the presence of asbestos containing materials (ACM) and develop a Register of the locations. Any other contamination identified during the Works will also be documented.

• Provide adequate asbestos awareness training to site personnel.

• Minimise the risk of inadvertent or incidental disturbance to the ACM’s and any other contaminants that may be identified during the Works.

• Document a strategy to manage and dispose / re-use the material in the bund walls in accordance with regulatory requirements.

• Describe the minimum safeguards required to complete the Works in a safe manner.

• An unexpected finds protocol.

• Prevent the off-site migration of contamination associated with the bund walls (which will be subject to a site audit statement) or, where there is off-site migration or its potential, manage or monitor the contamination such that it does not present an unacceptable risk to either the on-site or off-site environments.


This CAMP has been prepared in general accordance with Section 3.4.6 of the EPA Site Auditor Guidelines 2006 and Section 4.4 of Penrith City Council (2014) “Penrith Development Control Plan 2014, Volume 1”.


2.0 DESCRIPTION OF OPERATIONS AND WORKS

2.1 Staging

The Project will operate in accordance with three key stages. Stage 1 is defined as being up to the completion of excavation of Cell 1 which includes all site establishment works and Cells 1A, 1B and 1C. Management plans will be updated in future prior to additional works being commenced (such as Cells 2 and 3) as part of Stages 2 and 3.

Stage 1 works and activities are made up of the following components:

• Site establishment works and activities

• Construction of the recycling and reprocessing area (RRA)

• Operation of the landfill and the RRA and cell construction up to the completion of the excavation of Cell 1 (made up of Cells 1A, 1B and 1C).

Stage 1 is expected to take 5-7 years to complete.

Plans for Stage 1 have been prepared based on the impacts of the above activities being carried out at full operational level i.e. up to the maximum permitted tonnages and vehicle movements as permitted by the Project Approval. General construction and operating parameters are summarised in the following sections.

• Hours of construction: 1. Monday to Friday, 7am to 6pm 2. Saturday, 8am to 2pm 3. Sunday, no work

• Total input: up to 450,000 tonnes per annum (tpa)

• Waste recycled: up to 350,000 tpa

• Waste landfilled: up to 205,000 tpa

• Heavy vehicles: up to 250 heavy vehicle movements per day

• Maximum resource export rate: 160,000 tpa

• Maximum stockpile height: RL 54m AHD

• Construction: 10 to 15 people

• Operation: 20 people full time, plus up to 10 part-time contractors

• Hours of operation: 1. Monday to Friday 7am to 5pm 2. Saturday 8am to 2pm.


2.2 Site Establishment and Construction of the RRA

The details of these works and activities which have been included in the assessment undertaken to develop the Construction Traffic Management Plan and the Site Establishment Noise Management Plan (SENMP) are set out below.

These construction activities are expected to take 18 months to complete and will be carried out within the following parameters:

• Hours of Construction: 1. Monday to Friday 7am to 6pm 2. Saturday 8am to 2pm 3. Sunday, no work

• Personnel: 1. Construction: 10 to 15 people.

2.2.1 Site Establishment

The site establishment works and activities are as follows:

• Construction/shaping of the northern face and much of the eastern face to their final rehabilitated landform and landscaping of those faces. Construction of the northern face will be achieved through the following:

1. Reshaping the existing north eastern and north western bund walls, by reducing its height in some areas, raising its height in other areas to create an even northern face with a maximum elevation of 53 m AHD, and a more gentle northerly slope than currently exists. The new northern face and acoustic mound will provide acoustic protection for earthmoving and landfilling equipment/vehicles operating within Cells 1 and 2. The acoustic mound will be removed at the conclusion of capping in Cell 2 when it is no longer needed for acoustic protection

2. Areas to the north of the acoustic mound will be regraded to their final rehabilitated landform with slopes of approximately 5%. Final landscaping of these areas will occur during site establishment.

• Partial rehabilitation of the existing southern and southwestern bund walls through the reduction in the elevation to an approximate elevation of between 57 m AHD and 58 m AHD such that they will not be visible from any residence within The Vines Estate. Once re-shaped, the surface and adjoining batter slopes will be revegetated

• Upgrading and sealing of Patons Lane and upgrading the entrance to the site (from Patons Lane) together with the installation of three weighbridges and upgrade of associated office building

• Site preparatory works within the recycling and re-processing area to create the required landform and create a suitable pad for the materials recycling facility warehouse and mobile recycling equipment


• Construction and commissioning of the on-site wheel wash facility

• Upgrading and sealing the internal road network beyond the proposed wheel wash facility to the exit point from the recycling and re-processing area

• Building and construction works and infrastructure works, as shown in Figure 3.

These works and activities will be undertaken generally in the order set out below (and referenced on Figure 3) noting that the scheduling of specific works will be dependent on factors such as weather, commercial factors including contractor availability, specific logistical requirements and many other issues and will vary accordingly. In addition, many of the works and activities will need to be undertaken simultaneously. The works and activities associated with site establishment are as follows:

1. Construct surface water controls (integrate dams as required)

2. Excavation of stockpiled clay/shale and construct northern face (external and Internal slopes)

3. Regrading/shaping areas north of the northern face

4. Dewatering of quarry void

5. Landscaping northern face

6. Construct track for Transgrid access

7. Construct raw material stockpiles

8. Excavate recycling and re-processing area to 48m AHD to 49m AHD. Extraction of clay to form required landform

9. Clay/shale extraction in Cell 1A, then 1B and 1C

10. Install leachate riser and drainage layer in Cell 1A and then 1B

11. Construct Initial Leachate Evaporation Pond

12. Construction of recycling and re-processing area infrastructure (see Figure 4 for details)

13. Maintain height of the eastern face of 57m to 58m AHD (outer slope reduced for landscaping)

14. Construct/re-establish Dam 3 (3A&B)

15. Construct/re-establish Dam 4 (4A)

16. Construct/re-establish Dam 5 (5A)

17. Construct Dam 6

18. Establish contingency stockpile area


19. Upgrade internal road network [sealed]

20. Upgrade internal road network [unsealed]

21. Construct wheel wash facility Pro

22. Upgrade site entrance

23. Install weighbridges

24. Construct car park

25. Construct site office

26. Reduction in height from southwestern face

27. Establish workshop area

28. Construct acoustic mound.

2.2.2 Construction of the RRA

The management plans have been based on the impacts of the construction of the entire RRA. The layout of the RRA is set out below in X. These items are largely buildings and structures that will be subject to Construction Certificates, BCA regulations and Occupation Certificates certified by an approved certifying authority.

The infrastructure permitted to be constructed as part of the RRA will be undertaken generally in the order set out below (and referenced on Figure 4) noting that the scheduling of specific works will be dependent on factors such as weather, commercial factors including contractor availability, specific logistical requirements and other issues and will vary accordingly. In addition, many of the following works and activities will need to be undertaken simultaneously:

1. Drainage works

2. C&D / C&I Recycling Building

3. Product Bays

4. Delivery Area

5. Small Dam

6. Road network

7. Crushing and Screening Area

8. Recycling Facility Warehouse

9. Amenities building and carpark.


2.2.3 Operation

The specific works and activities associated with Stage 1 operations are the:

• Emplacement of wastes into Cell 1A

• Construction of Cell 1B and 1C including the selective extractive operations to extract the clay/shale resource and related stockpiling activities

• Receipt and processing of wastes in the RRA with residuals being compacted, baled, and emplaced in Cell 1A and 1B.

Figure 5 shows the general arrangement of Cell 1. <Consultant to insert relevant figure number for their specific plan>

Compacted and baled residual waste will be transported form the RRA to the landfill cell via a dedicated on-site heavy vehicle fitted with a walking floor trailer.

Mobile plant and equipment to be used for the placement of waste into the cells include an excavator with a detachable grab attachment for handling the baled waste, and a bucket attachment for movement of daily cover. A compactor will also be used to provide further compaction of residual waste.

Bulldozers, dump trucks and excavators will be used for the excavation of cells 1B and 1C.


Figure 3: Site Establishment Activities

Figure 4: Recycling and Re-processing Area PATONS LANES RRC - REFERENCE NO. S9171 A3 – FINAL MARCH 2019 HIBBS & ASSOCIATES PTY LTD © 2019 PATONS LANE RESOURCE RECOVERY CENTRE: CONTAMINATION & ASBESTOS MANAGEMENT PLAN PAGE: 22.


Figure 5: Landfill Cell 1 General Arrangement


3.0 COMPLIANCE WITH REGULATORY REQUIREMENTS

Works to be undertaken involving handling potentially contaminated soil materials from the perimeter bund will comply with applicable environmental regulatory and legislative requirements. The following table provides a summary of the general requirements for management of contamination within the perimeter bunds.

Table 1: Legislation Summary

Legislation / Regulation Key Requirements

Protection of the Environment Operations Act 1997 (POEO Act). Protection of the Environment Operations (Waste) Regulation 2014.

Undertake all activities so as to minimise harm to the environment (in particular pollution of air and water and noise emissions) and not cause an offence under the Act. Transporters of particular waste types are required to be licensed under the Act Some waste disposal/processing facilities (including those receiving restricted solid waste, hazardous waste) are required to be licensed under the Act. Any waste classified as General Solid Waste suitable for recovery or recycling must meet the contaminant levels stipulated by the Environment Protection Licence.

The Waste Avoidance and Resource Recovery Act 2001.

Minimise the amount of waste for disposal. Where possible recycle.

Contaminated Land Management Act 1997 Statutory Site Audit required at appropriate stages of the works.

Work Health and Safety Act 2011

Specific provisions related to asbestos risk work environments, including work practices in accordance with Work Health and Safety Regulation 2011. Refer to Section 11.

Environment Planning and Assessment Act 1979. Environment Planning & Assessment Regulation 2000.

Planning Application MP09_0074, conditions of consent to be adhered to. Schedule 4 Condition 7 relates to the Contamination and Asbestos Management Plan. Refer to Table 2.

3.1 Planning Application MP09_0074, Conditions of Consent Conditions of consent, Condition 7 of Schedule 4 provides conditions specific to contamination and asbestos management. The table below provides a summary of the conditions and describes and details where the conditions have been met by this CAMP.


Table 2: Consent Conditions Summary

Contamination & Asbestos Management Plan – Schedule 4 Condition 7

CAMP Reference

Comment

The proponent shall prepare and implement a Contamination and Asbestos Management Plan for the site. The plan must:

a) be prepared by an independent expert whose appointment is endorsed by the Director-General;

n/a Endorsed by NSW Planning & Environment, letter reference MP 09_0074 dated 31/8/15.

b) be prepared in consultation with WorkCover NSW, NOW and EPA;

Appendix 2 Submissions were provided during the planning consultation process. See summary of comments and responses as well as correspondence in Appendix 2.

c) be reviewed and endorsed at each stage by an independent accredited site auditor

n/a NSW Accredited Auditor appointed. Endorsed by NSW Planning & Environment, letter reference MP 09_0074 dated 31/8/15.

d) be approved by the Director-General prior to commencement of site establishment;

Section 1.2 Approved by DP&E on 9 August 2017.

e) be based on the results of such further testing or monitoring of the contaminated bunds, the site or groundwater as may be required by the independent accredited site auditor;

n/a No additional information requested to date.

f) adequately characterise the types and quantities of contaminants within the bunds that are proposed to be disturbed and in groundwater in the area of the bunds;

Section 6 Summary of previous investigations is provided in Section 6.

g) provide for the appropriate remediation of any contaminated material;

Section 7 The remediation approach is documented in Section 7.

h) ensure that the environmental and human health risks posed by contamination are adequately addressed;

Section 12 Control Measure to be adopted and implemented are documented in Section 12.

i) provide a protocol for addressing the environmental and human health risks posed by any unexpected finds of contaminants;

Section 12.13 Refer to Section 12.13 – Unexpected Finds Protocol.

j) demonstrate that the proposed control measures will minimise emissions to the atmosphere of asbestos to the maximum extent achievable in accordance with the “Approved methods for the sampling and analysis air pollutants in NSW”;

Section 12.6.2 Asbestos baseline and source control monitoring is proposed, refer to Section 12.6.2..

k) include a Section B Site Audit Statement under the CLM Act; and

Appendix 10 A copy of the Site Audit Statement (SAS 269 dated 23/12/16) is attached as Appendix 10.


Table 2: Consent Conditions Summary

Contamination & Asbestos Management Plan – Schedule 4 Condition 7

CAMP Reference

Comment

l) include a regime for the issue of Section A Site Audit Statements under the CLM Act at appropriate stages of work.

Section 9.4 Refer to Section 9.4, progress reports will be provided on a quarterly basis for the first year and on an annual basis thereafter.

3.2 Implementation of this CAMP

It is intended that this CAMP will be implemented by the current site owner, occupants/users and any future owners during Stage 1 of the Project.

This CAMP is legally enforceable under the Conditions of Consent (Application No MP09_0074) Appeal No. 10928 of 2010.


4.0 REPORT LIMITATIONS & DISCLAIMER

This report was prepared for Patons Lanes RRC solely for the purposes set out herein and it is not intended that any other person use or rely on the contents of the report other than the regulatory authorities and the appointed EPA accredited Site Auditor. The information contained in this report is based on a limited review of the site, interviews with site personnel and review of documentation provided to Hibbs & Associates Pty Ltd at the time of the review. Whilst the information contained in the report is accurate to the best of our knowledge and belief, Hibbs & Associates Pty Ltd cannot guarantee the completeness or accuracy of any of the descriptions or conclusions based on the information supplied to it or obtained during the investigations, site surveys, visits and interviews. Furthermore, conditions can change within limited periods of time, and this should be considered if the Report is to be used after any elapsed time period subsequent to its issue.

Hibbs & Associates Pty Ltd has exercised reasonable care, skill, and diligence in preparation of the Report. However, except for any non-excludable statutory provision, Hibbs & Associates Pty Ltd gives no warranty in relation to its services or the report, and is not liable for any loss, damage, injury or death suffered by any party (whether caused by negligence or otherwise) arising from or relating to the services or the use or otherwise of this report. Where the client has the benefit of any non-excludable condition or warranty, Hibbs & Associates Pty Ltd’s liability is, to the extent permitted by law, limited to re-performing the services or refunding the fees paid in relation to the services or sections of the report not complying with the conditions or warranty.

This Report should not be used for the purpose of tendering, preparing costing, or budgets, programming of works, refurbishment works or demolition works unless used in conjunction with a specification detailing the extent of works. The Report must be read in its entirety and must not be copied, distributed or referred to in part only. The Report must not be reproduced without the written approval of Hibbs & Associates Pty Ltd.

Hibbs & Associates Pty Limited has relied upon, and presumed accurate; information, records, and documents provided by you and will not verify such information, records, or documents. Accordingly, Hibbs & Associates Pty Limited does not warrant the accuracy or completeness of such information, records, or documents.

The analyses, evaluations, opinions, and conclusions in this report are based solely upon the state of the Site at the time of the Site inspection. However, the passage of time, manifestation of latent conditions or impact of future events (including, but not limited to, changes in legislation, scientific knowledge, land use etc.) may subsequently render the report obsolete.


5.0 ASBESTOS – PROPERTIES AND HEALTH EFFECTS

The following section outlines general information on the asbestos materials, a brief summary of the health effects resulting from exposure to asbestos and the occupational Exposure Standards for asbestos. This information is provided as a background for the Risk Assessment.

5.1 Introduction

Asbestos is a vague generic term of no specific geological significance except that it describes the group of naturally occurring fibrous silicate minerals that are characterised by having crystallised in nature as long thin separable fibres. The various properties, health effects, exposure standards, etc. are summarised in the following sections.

5.2 Asbestos – Properties and products The three (3) asbestos types from the group of asbestos minerals that have been mined in any commercial significance include:

• Chrysotile (White Asbestos)

• Amosite (Brown Asbestos)

• Crocidolite (Blue Asbestos)

The asbestos minerals have a unique combination of chemical and physical properties, which at one time gave them great commercial value. These properties include: high electrical resistance, low thermal conductivity, high resistance to heat and flame, high resistance to acid and chemical attack, high tensile strength and its fibrous nature means that it is readily spun into yarn and is a binder/filler in composite materials. Thousands of products have been produced that incorporate asbestos, many of which may be encountered in everyday life.

The common uses of asbestos are in fire retardants, thermal and acoustic insulation materials, frictional products (e.g. brake and clutches), jointing materials, seals and gaskets, building products as reinforcement, for acid and alkaline resistance, filtering media (e.g. chemicals, pharmaceutical & food industries) and as binders or fillers in other products (asbestos cement materials, resins, caulking and sealants).

5.3 Brief Summary of Health Effects

The very properties of the asbestos minerals that make them industrially useful, contribute to their potential to cause disease. The health effects from exposure to asbestos result from the inhalation of asbestos fibres in the respirable size range. The respirable size range is defined as those fibres possessing the following geometric criteria:

• Length – greater than 5 microns; • Width – less than 3 microns in width; and • Aspect ratio (length: width ratio) greater than 3:1.


The respirable fibres possess the aerodynamic characteristics that allow them to travel in an air stream and penetrate deep into the small airways of the lungs, to the gas exchange regions (called the alveoli).

The properties of asbestos of greatest biological significance are its fibrous nature and durability in the lungs. Its fibrous nature and formation in bundles of separable fibrils allows the production of large numbers of respirable fibres.

The chemical composition, shape, and structure of the asbestos fibres make them resistant to attack from biological fluids and mechanisms, and hence durable in the lungs. The durability is relevant in terms of residence time in the lungs with consequent greater potential for damage.

The diseases resulting from exposure to asbestos can be categorised as follows: ▪ Asbestos related pleural disease

➢ Benign (not cancerous) - Plaques - Diffuse pleural thickening - Pleural effusion

➢ Malignant (cancerous) - Mesothelioma

(including pleural, pericardial and peritoneal) ▪ Lung Disease

➢ Benign - Asbestosis

➢ Malignant (cancerous) - Bronchogenic Carcinoma (lung cancer)

The following is a description of the principal asbestos related diseases is summarised in the following sections.

5.3.1 Asbestosis

Asbestosis is defined as a bilateral diffuse interstitial (parenchymal) fibrosis of the lungs caused by the inhalation of all forms of asbestos fibres. In layman's terms, it is a progressive scarring of the lungs (damage to the alveoli) that reduces their elasticity and function (efficiency) resulting in breathlessness. The disease is progressive and irreversible, and usually occurs after high intensity and/or long-term exposure to asbestos.

Asbestosis manifests itself clinically by increasing dyspnoea (shortness of breath), crepitations (abnormal breathing sounds) on inspiration, non-productive cough, and general lung disorder. Sufferers are at an increased risk of: (i) respiratory failure; and (ii) developing lung cancer and mesothelioma.


5.3.2 Lung Cancer

Lung Cancer (bronchogenic carcinoma) is a cancer of the larger and medium sized lung airways and caused by the inhalation of all forms of asbestos fibres. It is similar to, and indistinguishable from, lung cancer caused by tobacco smoke. The combination of asbestos exposure and tobacco smoking has a synergistic effect, which greatly increases the risk of lung cancer.

There is generally a long latency period after exposure before symptoms appear – this is typically at least 10 years and may be as much as 30 or 40 years. The risk of developing lung cancer is increased with the intensity and duration of exposure.

5.3.3 Mesothelioma

Malignant mesothelioma is a diffuse primary cancer of the pleura, peritoneum, or pericardium. Asbestos related mesothelioma most often first occurs in the pleural mesothelium and often spreads to the pericardium and peritoneum causing mesothelial tumours in these areas as well as spreading to other tissues. The tumour involves both the visceral and parietal layers, which become fused into a homogeneous tumour mass up to 1 cm thick. With pleural mesothelioma, the tumour encases and compresses the lung.

Mesothelioma, (like asbestos related lung cancer) has a long latency period. Symptoms typically do not appear until between 20 and 30 years after exposure, extending up to 50+ years in some cases. Unlike lung cancer, mesothelioma is unrelated to the smoking of tobacco products.

In the unexposed population (i.e. those people not directly exposed to asbestos), this tumour is considered exceptionally rare. The amphibole asbestos types, and particularly crocidolite, are very potent in inducing mesothelioma. The situation is less clear for chrysotile, however if chrysotile exposure does induce mesothelioma, then it is considerably less potent than the amphiboles.

5.3.4 Relative Risks

Current scientific knowledge from epidemiological studies indicates that the asbestos related diseases exhibit a dose response relationship and for asbestosis, a no effect threshold. These studies also indicate very clearly that there must be sufficient non-trivial exposure to airborne respirable asbestos fibres before the development of asbestos-related disease (asbestosis, lung cancer, and mesothelioma) can occur.

Dose (i.e. cumulative exposure) is measured as fibre.years/ml. This is calculated from the product of the duration of exposure (measured in years) with the average airborne concentration during the period of exposure (measured as fibres/ml).

Epidemiological studies provide strong evidence that the threshold fibre dose (lifetime occupational exposure to asbestos) below which the fibrotic process cannot advance to the point of clinical manifestation of asbestosis is 25 fibre.years/ml.


The relative risk of lung cancer is estimated to increase 0.5% - 4% for each increase in dose of 1 fibre.year/ml. Using the upper boundary of this range, a dose of 25 fibre.years/ml is estimated to increase the risk of lung cancer two-fold.

Although all forms of asbestos are hazardous and have been shown to cause asbestosis, lung cancer and mesothelioma (the situation is less clear for chrysotile and mesothelioma), there is accumulating evidence that the degree of hazard is intrinsically related to fibre type and fibre size distribution.

The relative potency of fibre type for mesothelioma: crocidolite : amosite : chrysotile = 500 : 100 : 1

The relative potency of fibre type for lung cancer: crocidolite : amosite : chrysotile = 10-50 : 10-50 : 1

5.4 Exposure Standards

Workplace Exposure Standards (WESs) for the evaluation of atmospheric contaminants in the workplace are contained in Safe Work Australia (SWA) “Workplace Exposure Standards for Airborne Contaminants” – effective Dec 2011. Subsequent updates to the listed standards are available from the SWA Hazardous Substance Information System (HSIS) website (http://hsis.safeworkaustralia.gov.au/).

5.4.1 General Definition

The following definition is quoted with some modification from the SafeWork Australia document noted above.

In brief, the Workplace Exposure Standards represent airborne concentrations of individual substances, exposure at which, according to current knowledge, should not impair the health of, nor cause undue discomfort to, nearly all workers. Additionally, the exposure standards are believed to guard against narcosis or irritation, which could precipitate industrial accidents.

The Workplace Exposure Standards do not represent a fine dividing line between a healthy and unhealthy work environment. Natural biological variation and the range of individual susceptibilities mean that a small number of people might experience adverse health effects below the exposure standard. (Reference Source: Guidance on the Interpretation of Workplace Exposure Standards for Airborne Contaminants – April 2012”).

The exposure standards are expressed as time-weighted average concentrations over an eight-hour working day, for a five-day working week, and reflect long-term exposure (over the employees working life time). During the eight-hour averaging period, excursions above the TWA exposure standard are permitted provided these excursions are compensated for by equivalent excursions below the standard during the day. However, as some substances can give rise to acute health effects (not applicable to asbestos) even after brief exposures to high concentrations, excursions above the TWA concentration are restricted by Short Term Exposure Limits (STEL). Asbestos does not have acute effects and hence no STEL.

http://hsis.safeworkaustralia.gov.au/


5.4.2 Exposure Standards – Asbestos

The Exposure Standards for the assessment of asbestos in the occupational environment, specified by SafeWork Australia, are:-

1. Chrysotile 0.1 fibres/ml 2. Amosite 0.1 fibres/ml 3. Crocidolite 0.1 fibres/ml 4. Any mixture or unknown type 0.1 fibres/ml

These values have been defined for fibres longer than 5 microns; width less than three microns; and with an aspect ratio of not less than 3:1, when measured as an 8-hour time-weighted average (TWA) in accordance with the requirements of the SafeWork Australia “Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos fibres, 2nd Edition, [NOHSC: 3003(2005)]”.


6.0 PREVIOUS REPORTS AND AVAILABLE INFORMATION

6.1 Previous Reports

The following reports have previously been prepared for the Project:

• DP, Preliminary In-Situ Waste Classification Assessment, Orchard Hills Waste and Resource Management Facility, September 2009 (DP, 2009).

• DP, Factual Letter Report Supplementary Asbestos Assessment, Orchard Hills Waste and Resource Management Facility, July 2010 (DP, 2010).

• Aquaterra Consulting Pty Ltd, Cell Design and Groundwater Assessment, Orchard Hills Waste and Resource Management Facility, March 2010 (Aquaterra 2010).

6.1.1 DP 2009 Report

The bund walls subject to waste classification assessment are situated along the north-eastern, north-western, and south-western boundaries of the Project. The initial investigations undertaken by DP (2009) involved the drilling of 20 boreholes through the existing bund walls and the collection and analysis of 60 samples, (the DP Test Bore Location Plan is presented in Appendix 3).

The results of the analyses were assessed in accordance with the DECC Waste Classification Guidelines (July 2009). The guidelines define General Solid Waste to include VENM and C&D waste. However, DP (2009) noted that by definition (EPA website) ‘Excavated material that has been stored or processed in any way cannot be classified as VENM’. Therefore, the natural material on site that has been stored in the existing bund walls was referred to by DP as excavated natural material (ENM). In this CAMP the term excavated naturally-derived material is used throughout for material that cannot be classified as VENM.

In general, the profile encountered comprised:-

• Bores 4, 5, 6, 7, 7A, 8, 9, 10, 11, and 20 included the presence of substantial amount of concrete, bricks, building rubble and gravel.

• Bores 12 and 13 comprised a variety of material including brown silty/sandy clay and orange/red-brown mottled grey clay (with less building rubble present).

• Bores 1, 2, 3 and 19 comprised a variety of materials including grey silt and brown to orange-brown clay filling with shale and ironstone fragments. C&D waste was not encountered.

• Bores 14, 15, 16, 17, and 18 contained a variety of materials including brown/black sandy clay and grey/orange/brown clay with some gravel, wood, wire and brick fragments.


Asbestos was found embedded in plaster fragments in one sample near the surface of the existing eastern bund wall (within Test Hole 12 see Appendix 3), slightly above the Reporting Limit of 0.1g/kg at 0.42g/kg. Material containing this level of asbestos is referred to by Douglas Partners as Special Waste (Asbestos). Asbestos was also detected, but below the Reporting Limit, in six other samples recovered from other bores (6, 7, 8, 9, 17, and 18 in the existing eastern bund wall where construction and demolition materials were identified).

All chemical contaminants were found to be within the Site Assessment Criteria (SAC) thresholds taking into account statistical assessment of the results.

Based on site observations and laboratory results, Douglas Partners (2009) concluded that the materials within the existing perimeter bund walls are largely general solid waste (non-putrescible) comprising excavated natural material and general building rubble. The exceptions included the following:-

• Special Waste (Asbestos) – Asbestos was detected in the C&D waste retrieved from a 0.3 m section at the top of Test Bore 12. Based on the bore log, the C&D waste material extended from the surface to ~1.5 m into the bund wall.

• Test Bores 6-9, 17 and 18 may contain minor traces of asbestos and would require further investigations to determine the extent of asbestos contamination in the fill.

6.1.2 DP 2010 Report

The investigation comprised of sampling at eight (8) locations in the vicinity of the previous Test Bore 12. Samples were collected using a small mechanical excavator to a depth of 1.5 metres. Sixteen (16) samples were analysed for asbestos.

C&D waste and fibre-cement fragments were observed in seven (7) of the test pits. Asbestos fibres (chrysotile in all cases and amosite in one case) were detected in five (5) of the soil samples tested.

6.1.3 Aquaterra 2010 Report

In April 2009, Aquaterra Consulting Pty Ltd installed two groundwater piezometers (Licence number 10BL602962) at the Project and measured water levels, sampled and hydraulically tested these in June and July 2009. Groundwater generally follows the topography from high to low locations and the two piezometers are located near the northwest and northeast corners of the Project which are topographic low points. Also present at the Projectis an existing groundwater abstraction bore (Licence number 10BL161098).

Access to the licensed bore nearest the Project which is on the “Coolamon Park” property (GW105382) was unable to be obtained. However, it is understood that this bore is currently not being utilised to access groundwater, but when it is used it is pumped at the rate of 60 L/min. A summary of the shale hydraulic parameters (kh) is presented in Appendix 4, Table 2.1.


Groundwater levels in the shale were measured in the two piezometers on 17 June 2009, 28 July 2009 and 16 November 2009 and were found to be consistent between all dates (depth range 3.76 to 5.14 mbgl). Groundwater levels are presented in Appendix 4, Table 2.2.

A summary of the Project groundwater chemistry is presented in Appendix 4, Table 2.3.

Aquaterra noted “that the bunds are located on the natural ground level which is clay and Douglas Partners noted ‘free groundwater’ was not encountered in any of the bores during drilling’. Also visual inspections of the bunds failed to identify any seeps from the batters of the bunds. This means that there has been very little rainfall infiltration through the bunds, otherwise leachate would likely have been encountered. This further suggests that the waste located in the bunds presents a very low risk of leachate being generated and seeping into the underlying groundwater. Should any leachate be generated from the materials within the bunds, there is about 4 m – 8 m of natural clay beneath them which provides a natural barrier to the groundwater in the shale. If any leachate did seep into the underlying groundwater in the shale, the hydrogeological evidence is that the pollutants would be unable to migrate any significant distance. This view is confirmed by the fact that no evidence of leachate contamination could be found in the two piezometers which are downgradient of the bunds.’’

6.2 Present Project Conditions

6.2.1 Overview At the time of reporting the Project was un-occupied with some infrastructure remaining from the former Erskine Park Quarry. The Project is located within a rural area. To the west of the Project is land owned by the Commonwealth which is used by the Australia Defence Force. To the north and east of the Project is open grazing land and rural housing. Blaxland Creek passes through the north-west boundary of the Project. The land south-west of the Project is occupied by facilities associated with an existing horse stud. The Vines residential area is located approximately 500 m to the north of the Project surrounded by grazing land and low density housing Four bund walls are located around the Project boundaries as shown on the survey presented in Appendix 1. The bund walls are manmade structures with an approximate combined length of 1,800 m and heights ranging from 5 m to 19 m. A number of clay and shale stockpiles are also present within the Project.

6.2.2 Site Inspection Hibbs & Associates Pty Ltd (Hibbs) undertook site inspections of a preliminary nature at the Project on the 5th August 2016 and 19th September 2016. The following observations are noted:-

• No signs of chemical storage such as drums or signs of chemical contamination such as staining were noted at the ground surface (noting that the walkover was limited in extent).


• Evidence of building rubble including brick, concrete and tile fragments was observed on the surface of Bund wall 4. No ACM was noted during the limited walkover.

• Bund wall 2 and Bund wall 4 were accessed by vehicle during the inspection. The bund wall material appeared to have been generally well compacted with good slope stability evident.

• Vegetation was present across all of the bund walls. No obvious signs of vegetation stress was observed.

• The majority of the Cell 1 area was submersed in water.

6.3 Known Impacts

6.3.1 Extent

Based on the results from the previous investigations, for the purposes of this CAMP the bund wall area has been defined into the following categories:

1. Special Waste (Asbestos) 2. General Solid Waste Likely to be present – C&D which may contain minor traces

of asbestos 3. General Solid Waste Likely to be present - C&D 4. Excavated naturally-derived material

Appendix 3, Figure 1 illustrates the anticipated extent of the material categories based on interpretation of the DP 2009 and DP 2010 reports. The interpolation is based on records from 20 boreholes distributed systematically across the bund walls (DP 2009). Where any foreign material was noted on the bore logs it has been assumed that C&D waste is likely to be present. The DP 2010 investigation was limited to the area within the vicinity of BH12. The DP 2010 investigation demonstrated that ACM was present between BH11 and BH13.

Based on the previous DP investigations all chemical contaminants were found to be within the adopted site assessment thresholds taking into account statistical assessment of the results. As such, asbestos is the only material of concern identified to date.

6.3.2 Summary of Contamination Identified The following provides a summary of the contaminants positively identified during the DP 2009 and DP 2010 investigations:-

• ACM – ACM was reported in the field observations as fibre-cement fragments. In the DP 2009 report asbestos was reported above the LOR in one sample which was described as being present within a small piece of plaster, asbestos was detected but below the reporting limit in 6 other samples. In the DP 2010 report the laboratory reported chrysotile asbestos detected in fibres (3 samples), chrysotile asbestos detected in fragments of fibro plaster cement (one sample), chrysotile asbestos detected in a fragment of fibre cement material (one sample) and chrysotile and amosite asbestos detected in a fragment of fibre cement material (one sample).


• Descriptions of foreign material identified as C&D waste included brick, ceramic pipe, glass, plaster, plastic pipe, plastic, concrete, marble fragments, slag, metal pipe, fibre cement, tile, timber, wood, plates, steel scraps, wires.

• A description of paint was recorded within a matrix of C&D waste at 2 locations BH9 (1.5m) and BH20 (0 to 4 m), the consistency of the paint was not described.

6.3.3 Contamination Assessment – Non Asbestos Contaminants

Laboratory analysis was conducted on 60 samples during the DP 2009 investigation for a variety of common contaminants which included heavy metals (arsenic, cadmium, chromium, copper, lead, mercury, nickel and zinc), polycyclic aromatic hydrocarbons (PAH), total recoverable hydrocarbons (TRH), benzene, toluene, ethylbenzene and xylene (BTEX), polychlorinated biphenyls (PCB), organochlorine pesticides (OCP), phenols and asbestos. All chemical contaminants were found to be within the Site Assessment Criteria (SAC) thresholds taking into account statistical assessment of the results.

The analytical suite adopted in the DP 2009 report is considered to encompass the contaminants which are commonly associated with C&D waste. The bore logs generally indicate the presence of inert / immobile foreign materials which will have a limited impact on human health or the environment. Some of the foreign material identified specifically slag and paint will contain some chemical constituents. Chemical testing of the soil has not identified any widespread leaching of such contaminants into the soil matrix. It is further noted that slag and aged paint would be anticipated to have a low potential for leachability.

Field indicators recorded in the DP 2009 report have not identified any triggers for further chemical testing, noting that:

• Odours were only recorded in 2 boreholes, BH07 (strong odour at 0.8m) and BH14 (slight odour at 3.3m).

• Field measurements were collected using a photo-ionisation detector (PID) during the DP 2009 investigation to monitor for the presence of total volatile compounds (VOCs). The majority of measurements were recorded to be <1ppm. The maximum measurement recorded was 2 ppm.

The above summary supports the conclusion in the DP 2009 report that there are no known areas of non-asbestos contamination (other than generally immobile building materials) in the perimeter bunds. Notwithstanding this conclusion it is known that the bund walls have been constructed using uncontrolled fill materials from both on-site and off-site sources. As such, there is the potential that previously unidentified contamination may be present in the bund walls.


7.0 REMEDIATION APPROACH

7.1 Options for Soil Remediation

The Amended Assessment of Site Contamination (ASC) National Environment Protection Measure (NEPM), National Environmental Protection Council (NEPC) (NEPM 2013 amendment) provides a framework for the investigation, assessment and management of contaminated land in Australia. The purpose of the Measure is to establish a nationally consistent approach to the assessment of site contamination to ensure sound environmental management practices by the community, which includes regulators, site assessors, environmental auditors, land owners, developers and industry.

Under the NEPM 2013 amendment the preferred order of options for any site clean-up and management is:-

• on-site treatment of the contamination so that it is destroyed or the associated risk is reduced to an acceptable level; and

• off-site treatment of excavated soil, so that the contamination is destroyed or the associated risk is reduced to an acceptable level, after which soil is returned to the site.

or, if the above are not practicable;

• consolidation and isolation of the soil on site by containment with a properly designed barrier; and

• removal of contaminated material to an approved site or facility, followed, where necessary, by replacement with appropriate material.

When deciding which option to choose, the sustainability (environmental, economic, and social) of each option should be considered, in terms of achieving an appropriate balance between the benefits and effects of undertaking the option.

There are no available technologies for the destruction of ACM contamination in soil. The methods applicable to the remediation of soil ACM impacts at the Project include:

• Source containment. • Excavation and relocation into an on-site waste cell. • Excavation and disposal of soil off-site. • Hand Picking.

7.2 Remediation Goals

The remediation goals for the Project are summarised as follows:-

• Manage the known area of asbestos contaminated soil (special waste) prior to re-profiling of the affected bund area (approximate 25m x 100 m x 1.5m).

• Establish a strategy for on-going characterisation of the bund wall material


including an unexpected finds protocol.

• Remediate soil contamination and asbestos to a level suitable for recreational use once the Environmental Protection License is relinquished.

• Protect human health and the environment from contamination and asbestos in materials that make up the bund walls surrounding the Project.

• Meet the conditions of the Development Consent and other regulatory requirements.

• Demonstrate that the proposed management strategy for the perimeter bunds is environmentally justifiable, practicable and technically feasible.

• Adopt clean-up criteria appropriate for the future use of the Project to mitigate possible impacts to human health and the environment.

• Mitigate possible off-site migration of contaminants.

• Consider the principles pf ecologically sustainable development in line with Section 9 of the Contaminated Land Management Act 1997.

• Minimise waste generation under the Waste Avoidance and Resource Recovery Act 2001.

7.3 Evaluation of Alternative Remediation Methods

Details of the remedial techniques that have been evaluated are presented below:

Table 3: Remediation Option Appraisal

Option Advantages Disadvantages

Off-site Disposal No on-going management plan required.

Cost will be prohibitive. Will require a large number of truck movements off-site. Low sustainability.

Selective Excavation and On-site Disposal

Cost effective. Minimises vehicle transport distance. High sustainability.

Reduced landfill cell space.

Hand Picking Cost effective option. Difficult to validate. Requires significant disturbance of ACM impacts.


Table 3: Remediation Option Appraisal

Option Advantages Disadvantages

Capping In-Situ Cost effective. Minimises ACM disturbance. Material is managed within the bund so does not take up space in the waste cells.

On-going management plan required.

From a sustainability perspective, it is considered impracticable to remove all asbestos contaminated soil (special waste) from the Project. Furthermore, the costs associated with transport and off-site disposal of the expected large volume of contaminated soil present on the Project would be prohibitive and unnecessary.

7.3.1 Known Area of Asbestos Contaminated Soil (Special Waste)

The preferred approach for remediation of the asbestos contaminated soil (special waste) is a combination of selective excavation with transfer to a containment cell constructed on site and in-situ capping of the bund wall.

The primary remediation strategy for the known asbestos contaminated soil (special waste) approximate 25m x 100 m x 1.5m will be selective excavation with transfer to a containment cell constructed on site.

7.3.2 General Bund Re-profiling

During the Project Works, large scale re-profiling of the bund walls will be undertaken. Section 9 below provides a summary of the proposed re-profiling activities and the strategy in each area for waste material. The proposed remediation strategy for waste material uncovered during bund re-profiling comprises:-

• Surplus excavated waste material – Landfill on site.

• In-situ waste material - The surface area of the bund will be capped if waste is present and revegetated.

• Contingency - If any waste is found after completion of the final waste cells the material will be disposed to an off-site landfill.

Based on the previous DP report, the bund material is currently summarised by four (4) different categories as illustrated in Appendix 3, Figure 1. As the project progresses, on-going characterisation will be undertaken in accordance with Section 11.0 below.

The following procedures will be employed in respect of keeping records of any asbestos containing materials found on site which are transported to the landfill for disposal.


Any materials containing asbestos required to be landfilled will be isolated in separate stockpiles. These materials will then be loaded into dump tracks with a front end loader equipped with a computerised weighing/scale system. This will allow the tonnages for materials dispatched to the landfill to be accurately recorded with daily tonnages being printed off for record keeping. As an additional safeguard, the dump trucks to be utilised for this task will also have an internal weighing system.

7.3.3 Non-asbestos Contamination

Non-asbestos contamination, if present will be managed by means of an unexpected finds protocol.

Any restricted or hazardous waste must not be disposed of onsite. Restricted or hazardous waste must be sent off site for disposal to a facility that can lawfully receive that waste.


8.0 SOIL ACCEPTANCE CRITERIA

8.1 General

The assessment of soil contamination is based on a variety of considerations including future land usage and general potential impacts to the site users / occupants and the environment. Specific considerations of soil contamination concentrations should be made with regard to the Project, such that soil levels should not cause:

• Unacceptable health risks to occupants of the Project or the general public off the Project.

• Unacceptable risks to the environment both on and off the Project.

• Unacceptable levels of ground water contamination beneath the Project or migration of contaminated groundwater off the Project.

• Detrimental effects to development infrastructure. The Site Acceptance Criteria (SAC) adopted below apply to materials that form the perimeter bunds.

8.2 Land Use Scenarios

The appropriate generic land use scenario for the soils within the perimeter bunds and adopted SAC for the assessment are described in the following sections.

The following guideline relevant to human health based exposure to asbestos and relevant non-asbestos contaminants was used in adopting the Site Acceptance Criteria:

a) Schedule B1 National Environment Protection (Assessment of Site and Contamination) Measure 1999 (amended April 2013).

During the lifecycle of the resource management facility, the most appropriate land use scenario for the Project is ‘HIL D – Commercial/Industrial’. At the end of the Project, it is intended that the bulk of the Project would be returned to land suitable for grazing with selected areas revegetated for use for nature conservation. The most appropriate land use scenario for the long-term site use is ‘HIL C – Recreational’.

The Amended NEPM (NEPC, 2013) asbestos guidelines have been developed for managing land use impacts associated with asbestos and are applicable for assessing risk to human health. The guideline has been derived from the Western Australian Department of Health (WA DoH 2009) guidance. The guidance covers non-friable Asbestos Containing Material (bonded ACM), Fibrous Asbestos (FA) and Asbestos Fines (AF).

8.3 Soil Asbestos Criteria

The health screening levels for asbestos contamination in soils have been reproduced in the table on the following page from: Schedule B1, National Environment Protection (assessment of site contamination) Measure 1999 (amended April 2013).


Table 4: Health Screening Levels (w/w)

Form of asbestos Residential A1 Residential B2 Commercial / Industrial D4

Bonded ACM (non-friable) 0.01% 0.04% 0.02% 0.05%

FA and AF5 (friable asbestos) 0.001%6

All forms of asbestos No visible asbestos for surface soil (upper 10cm)

1. Residential A with garden/accessible soil also includes children’s day care centres, preschools, and primary schools.

2. Residential B with minimal opportunities for soil access; includes dwellings with fully and permanently paved yard space such as high-rise buildings and apartments.

3. Recreational C includes public open space such as parks, playgrounds, playing fields (e.g. ovals), secondary schools, and unpaved footpaths.

4. Commercial/industrial D includes premises such as shops, offices, factories, and industrial sites.

5. The screening level of 0.001% w/w asbestos in soil for FA and AF (i.e. non-bonded/friable asbestos) only applies where the FA and AF are able to be quantified by gravimetric procedures). This screening level is not applicable to free fibres.

6. While the NEPM lists the Health Screening Level for FA and AF as 0.001%, the Reporting Limit of AS4964 is 0.01%, refer Section 8.5. As 0.001% is not achievable, the Reporting Limit of 0.01% will be used as the criteria for assessment of FA and AF.

The soil asbestos criteria adopted for initial assessment of the bund wall soils with regards to asbestos contamination is the Reporting Limit of 0.01% for free fibre and/or friable asbestos, and 0.02% for non-friable (bonded) ACM. In addition, no asbestos containing materials or debris should be visible on the surface.

8.4 Soil Acceptance Criteria Non-asbestos Contaminants.

The potential non-asbestos contaminants of concern for the Project are considered to be:-

• TRH • BTEX • PAH • Heavy Metals (As, Cd, Cr, Cu, Pb, Hg, Ni and Zn) • Phenol • PCBs

The relevant SAC for non-asbestos contaminants are presented in Appendix 5, Table 1.


The SAC should be applied to the dataset using appropriate statistical analysis in accordance with the Amended ASC NEPM (NEPC, 2013). Soils will be considered to meet the SAC indicating no unacceptable impacts when either all results are below the SAC or when statistical analysis shows that:

• The concentration of each contaminant is less than 2.5 times the SAC.

• The calculated 95% upper confidence limit (UCL) of the average concentration is less than the SAC.

• The standard deviation of the results is less than 50% of the SAC.

The Amended NEPM (NEPC, 2013) ecological investigation levels (EILs) and ecological screening levels (ESLs) have been developed to assess risk to terrestrial ecosystems. They are generally applicable to the top two metres of soil and three metres in arid regions.

In accordance with the Amended ASC NEPM (NEPC, 2013), the aesthetic state of sites is required to be taken into account. Aesthetic issues generally relate to the presence of materials with a negligible risk or non-hazardous inert foreign material in soil or fill resulting from human activity. Sites that have been assessed as being acceptable from a human health and environmental perspective may still contain such foreign material. On the basis that the Project would be returned to land suitable for grazing with selected areas revegetated for use for nature conservation, aesthetic criteria will only be considered for material present within the top 0.5m following final landform.

8.5 Assessment of Soil Samples for Asbestos

Soil samples will be analysed for the presence of asbestos in accordance with Australian Standard “AS 4964-2004 Method for the qualitative identification of asbestos in bulk samples”.

Soil samples will be collected by a “competent person”, as defined by Section 11 of the NEPM (2013 amendment) Schedule B2 guideline. The samples will be examined by stereo microscope. Fibrous materials identified under stereo microscopy are extracted and analysed by Polarised Light Microscopy supplemented with Dispersion Staining. This method examines the morphology and optical properties of the fibres, for those properties that are unique to the asbestos minerals. The optical properties to be examined will include:

− Colour and Pleochroism − Birefringence − Angle of Extinction − Sign of Elongation − Refractive Index by Dispersion Staining

Trace analysis will be conducted on all samples to determine the presence / absence of respirable asbestos fibres.

The Reporting Limit for the method listed in AS4964 is 0.1g/kg.


The results will be reported in accordance with requirements of AS4964 on NATA Endorsed Certificates of Analysis.

8.6 Sampling Analysis Quality Plan

All sampling and analysis conducted on the perimeter bunds will be undertaken in accordance with the Sampling, Analysis and Quality Plan (SAQP) presented in Appendix 6.


9.0 PROPOSED BUND WALL RECONSTRUCTION/DECONSTRUCTION

The FMPPR outlines all aspects of the proposed development. A draft management plan was previously prepared for the Proponent, DP, Draft Bund Deconstruction Management Plan, Orchard Hills Waste and Resource Management Facility, February 2012 (DP, 2012). The DP 2012 draft report provided the following summary relating to the bund wall Works:

• Sections 2.1.4, 2.2, 2.3, 2.8.3.2, 2.8.4, and 2.9.2 of the FMPPR describe the process of bund deconstruction. These are summarised in the following sections, along with additional details provided by GHD (15/02/2012).

9.1 Bund Reconstruction/Deconstruction Process

Initial site establishment works

• Bund material from the north western corner would be removed from the area adjacent to the creek, and would be used for bund reconstruction works (northern bund).

• An area of asbestos contamination around Borehole 12 (on the eastern bund) would be removed and this material placed into the on-site landfill cell. This area would be capped with clay and topsoil.

• The existing north eastern and northern bund walls (including the asbestos area mentioned above) would be re-profiled in accordance with the FMPPR to reduce their outer slopes, and capped with clean soil and topsoil. This would create an even northern face with a maximum elevation of 53 m AHD, and a more gentle external slope than currently exists, which would be revegetated to improve its visual amenity. The north eastern bund wall would be re-profiled to the levels outlined in the FMPPR, including capping and revegetation in accordance with the FMPPR.

• The outer face of the eastern bund wall (the eastern face) would be reprofiled to have a less steep slope than currently exists, and its elevation slightly increased (for acoustic reasons) where it is currently lower than 55 m AHD, using VENM from Cell 1. The eastern bund wall would be capped and revegetated in accordance with the FMPPR.

• The existing southern and south western bund walls would be reduced in height to between 57 m AHD and 58 m AHD. If any contaminated materials are unearthed during re-profiling, these areas would be capped with compacted clay material and layer of soil suitable for revegetation, as outlined in the FMPPR.


During the life of the project

• Material in the various bund walls would be progressively removed during the project, as described in the FMPPR. The final levels of the Project, where the bunds currently stand, would match those of the adjacent capped landfill areas and would be in accordance with the final land profiles shown in the FMPPR. Any areas where waste materials are unearthed during the bund deconstruction process and where any material from the bunds remains would be capped with clay material and topsoil, with a minimum thickness of 1 m (compacted clay capping and topsoil).

• The noise mounds around the recycling and reprocessing area would be removed at the end of the project, as part of the process of decommissioning the recycling area and filling it with excavated naturally-derived materials. (Outside the scope of this CAMP).

9.2 Final Bund Design

9.2.1 Site Establishment

The proposed footprint of the detailed bund design for the end of the site establishment phase is illustrated in Appendix 7 Figure SK002. This design faithfully represents the layout of the high level concept plans for the perimeter bunds set out in the FMPPR which forms part of the project approval. However, it is noted that the detailed designs required some adjustments to give effect to the bund layout in the FMPPR. These adjustments are minor and satisfy the specific requirements that the development be carried out “generally in accordance with” the project approval (MP09_0074 Conditions of Consent, Schedule 3 Condition 2).

9.2.2 Final Site Restoration

Details of the proposed final design surface following completion of Phases 1, 2 and 3 is illustrated in Appendix 8 Figures SK020, SK021, SK022 and SK023.

9.3 Estimated Quantities

The timing of the various bund removal activities and estimated quantities are shown in the FMPPR. It should be noted that only excavated naturally-derived material which is free from visible contamination would be used for bund reshaping / re-profiling and daily covering of waste during on-site landfilling operations. Schedule 4 Condition 8 of the project approval states “the proponent shall ensure that all material to cover and cap waste is VENM, or ENM provided the use of the ENM is approved in writing by the EPA’’. The Proponent shall obtain approval in writing by the EPA prior to re-use of ENM to cover and cap waste.

Quantities stated below are only approximate, and have been rounded off to the nearest 10,000 m3 for simplicity.


• Stage 0 – Approximately 200,000 m3 of the clean excavated naturally-derived material from the southwestern and southern bunds and 50,000 m3 of clean excavated naturally-derived material from the north western corner bund material would be used to re-profile the northern and north eastern bunds (requiring 100,000 m3), and to create the Recycling and Reprocessing Area noise mound (requiring 60,000 m3) and Contingency Stockpile noise mound (requiring 30,000 m3). Excess material classified as ENM would be used for daily covering of waste. The north eastern and eastern bunds would be capped with on-site clay and revegetated in accordance with the FMPPR.

• Stage 1 – Material comprising mainly waste in the north eastern corner of the existing quarry (30,000 m3) would be landfilled during the first stage of on-site landfilling.

• Stage 2 – The western section of the northern bund would be removed, after landfilling is completed in Cell 1. Excavated naturally-derived material classified as ENM in the bund (80,000 m3) would be used as daily cover for landfilling. If contaminated materials are exposed (which is unlikely in this area), this would be landfilled on site. The area beneath the bund would be capped if waste is present and revegetated.

• Stage 5 – The second section of the northern bund would be removed, after landfilling is completed in much of Cell 2. Excavated naturally-derived material classified as ENM in the bund (70,000 m3) would be used for daily cover. If contaminated materials are exposed, this would be landfilled on site. The area beneath the bund would be capped and revegetated in accordance with the FMPPR.

• Stage 6 – The remaining section of the northern bund would be removed, along with the first section of the north eastern bund. Excavated naturally-derived material classified as ENM in the bund (100,000 m3) would be used for daily cover. If contaminated materials are exposed, this would be landfilled on site. The area beneath the bund would be capped and revegetated in accordance with the FMPPR.

• Stage 8 – Another section of the north eastern bund would be removed. Excavated naturally-derived material classified as ENM in the bund (30,000 m3) would be used for daily cover. If contaminated materials are exposed, this would be landfilled on site. The area beneath the bund would be capped and revegetated in accordance with the FMPPR.


• Stage 10 – After completion of the final section of Cell 3, the last section of the north eastern bund would be removed (70,000 m3), along with the south western bund (200,000 m3), and the bunds around the Recycling and Reprocessing Area (10,000 m3) and the Contingency Stockpile area (30,000 m3). If contaminated materials are identified, this would be disposed of to an off-site landfill. The area beneath the bund would be capped and revegetated. The excavated naturally-derived material contained in these bunds would be used to fill the void left after Recycling and Reprocessing Area is decommissioned, which is approximately 300,000 m3 in volume. Any waste materials and excess excavated naturally-derived material remaining after the Contingency Stockpile area is re-profiled would be disposed of off-site.

9.4 Material Tracking All material that forms the perimeter bund will be tracked from cradle-to-grave. Copies of the tracking documentation must be kept by the Proponent and Site Manager. The minimum documentation which needs to be recorded is detailed below:-

1. Daily site records will be maintained by the Proponent (or delegation) when work is being done on the perimeter bunds.

2. Site inspection records by the Environmental Consultant. 3. Physical descriptions and volume estimates of materials moved, their original

location and end destination. 4. Accurate survey of the final bund shape with volume estimates of changes in

material volumes. 5. Survey location of cell where bund wall contaminated material has been placed and

contained. 6. Near-map photos of the Project at times when changes are being made to the

perimeter bunds. 7. Transport and landfill dockets (for any materials taken off-site). 8. Any issues managed under Section 12.13 (the unexpected finds protocol).

Progress reports will be provided to the appointed NSW EPA Accredited Site Auditor to allow an independent check. Progress reports will be provided on a monthly basis for the first year and on an annual basis thereafter.

9.5 Work Schedule

The proposed timing for Stage 1 works and activities is summarised below:

• The proponent intends to undertake the Site Establishment works and activities over 18 months with construction of the northern face completed within the first 4 months (approximately).

• The eastern face would be shaped during the first 12 months of the site establishment phase.


• During the first 12 months of Site Establishment, the Proponent would establish the recycling and re-processing area.

• The emplacement of asbestos waste from the vicinity of hole 12 will be completed within 3 months from the emplacement activities on Cell 1A.

• Note that the general order of the Stage 1 works is set out in Section 1 of this report.


10.0 ADMINISTRATIVE STRUCTURE

The following section details the administrative structure, lines of communication and responsibilities for the development, implementation, and on-going operation of the Management Plan.

The administrative structure includes procedures for the implementation and on-going operation of the Management Plan (and the hazard control strategies) and the reporting and maintenance systems. It also defines the responsibilities of key participants and the systems for the appointment of personnel to implement and manage the programme.

10.1 Objectives and Responsibilities

The objective of this CAMP is to provide clear guidance on the safe and appropriate actions required during earthwork activities which will or are likely to disturb soil which has been contaminated with ACM.

Responsibilities for implementation of this CAMP are summarised in Table 5 below:

Table 5: CAMP Responsibilities

Overall Implementation of the CAMP Proponent

Induct all personnel on site safety and site environmental requirements prior to commencing any work on site

Proponent (or delegation)

Implementation of acceptable environmental controls during all site works

Construction Manager / Site Manager

Develop specific Work Methods and carry out Job Specific Safety Analysis for site personnel


Coordinate site environmental monitoring and compile reports

Construction Manager / Site Manager / Occupational Hygienist

Confirm methods to mitigate impacts and rectify any Environmental Non Conformance or Incident

Occupational Hygienist and Construction Manager / Site Manager

Reporting of all accidents, incidents or emergencies relating to asbestos


Review cradle-to-grave progress reports, unexpected finds records and final validation report.

Occupational Hygienist / Environmental Consultant / EPA Accredited Site Auditor

Issue a Section A Site Audit Statement EPA Accredited Site Auditor


10.1.1 Occupational Hygiene Consultant

The Occupational Hygiene Consultant will provide independent specialist advice and such offer support to the Site Manager as may be required from time to time. As a minimum the consultant will conduct the following:-

• Asbestos Awareness Training.

• Asbestos Air Monitoring and reporting.

• On-going review of the work practices and controls.

• Provide advice for non-asbestos unexpected finds in relation to Occupational Health and Safety (OHS).

10.1.2 Environmental Consultant

The Environmental Consultant will provide independent specialist advice and will offer support to the Site Manager as may be required from time to time. As a minimum the consultant will conduct the following:-

• Material Inspection and testing as defined in Section 10.0 of this CAMP.

• Develop a detailed SAQP.

• Review progress reports and unexpected finds records.

• Provide advice for non-asbestos unexpected finds in relation to Environmental monitoring and/or characterisation.

• Prepare the site validation reports.

• Complete waste classification documents if required.

10.1.3 EPA Accredited Site Auditor

The EPA Accredited Site Auditor has been appointed to provide a Section A Site Audit Statement under the CLM Act at completion of the Stage 1 works. During the works the EPA Accredited Auditor will undertake an on-going review of:-

• Cradle-to-grave records.

• Progress reports.

• Unexpected finds records.

• Validation reports.

10.2 Reference Material

To ensure asbestos contamination is managed in an appropriate manner, the following guidelines are referenced and should be reviewed prior to disturbance of known or suspected asbestos impacted soil:

• Guidelines for the Assessment, Remediation, and Management of Asbestos-Contaminated Sites in Western Australia – May 2009.


• Working with Asbestos Guidelines 2008, WorkCover NSW.

• Code of Practice “How to Manage and Control Asbestos in the Workplace" (Safe Work Australia 2016)”.

• NSW Work Health and Safety Regulations 2011 (WHS, 2011).

Under the WHS Regulation 2011, a person conducting a business or undertaking that commissions the removal of asbestos must ensure that the asbestos removal work is carried out by a licensed asbestos removal Contractor unless the asbestos to be removed is:

(a) 10 square metres or less of non-friable asbestos or asbestos contaminated dust or debris (ACD) associated with the removal of that amount of non-friable asbestos, or

(b) ACD that is not associated with the removal of friable or non-friable asbestos and is only a minor contamination.

Friable asbestos materials must not be removed by a person who does not have a Class A asbestos licence.

A worker carrying out asbestos removal work, including a self-employed person conducting a business or undertaking, must be trained in the identification and safe handling of asbestos prior to carrying out asbestos removal work without a licence. An asbestos awareness course or the non-friable removal unit of competency would be considered appropriate training.

A licensed asbestos removal Contractor must give written notice to the regulator at least 5 days before the asbestos removal Contractor commences licensed asbestos removal work.

The Site Manager will consult with the Occupational Hygienist on an on-going basis to determine the licensing required prior to earthwork in areas of the bund wall where asbestos is known or suspected to be present.

Under this CAMP a Class A Contractor shall be appointed to oversee works that will disturb the known areas of asbestos in the bund material.

10.3 Asbestos Awareness Training

Training is an essential element of any comprehensive management plan, to ensure personnel have adequate knowledge to maintain the management plan efficiently and effectively. In addition to an increased knowledge and awareness, one of the many benefits of training is to demonstrate to staff the commitment of senior management to health and safety in the workplace.

As a minimum the Proponent is to ensure all persons entering the Project are briefed on the presence of ACM at the Project. The site induction programme will include detailed asbestos awareness training specific to the Project site contextualised to the Paton's RRC.. The Asbestos Awareness Training Agenda is outlined below.


1. Introduction – outline of the training session: structure, purpose and proposed outcomes.

2. What is asbestos - origins - types (chrysotile, amosite, crocidolite) - mineralogy and structure

3. Properties of asbestos - fibrous nature - high tensile strength - high resistance to heat and fire - low thermal conductivity (good thermal insulation properties) - chemical resistance - acoustic absorbance - high electrical resistance

4. Asbestos containing materials with respect to the construction industry - thousands of different products manufactured incorporating asbestos up to the

early 1980’s - thermal and acoustic insulation materials - fireproofing materials - fillers or binders in other products - asbestos cement products

5. Health effects - Asbestosis - Lung cancer - Mesothelioma - biological significance of structure and mineralogy - dose response relationships - asbestos related disease – legacy of past high exposures - one fibre theory

6. Patons Lane RRC - History of the site - Environmental investigations - Presence of asbestos contamination

7. Site Procedures - Unexpected Finds Procedure - Review of safe work procedures - Significance of small quantities of bonded asbestos

8. Questions

Asbestos Awareness Training is to be provided by a Registered Training Organisation (RTO) and is to be presented to all workers, which may include the Site Manager, Site Staff, maintenance staff, and contractors.

Training staff will help allay fears in regards to dealing with asbestos materials and the health risks they pose.


At the end of each training session, personnel who attend will be issued with a certificate confirming that the training took place. Records of personnel who undertake the training will be kept by the Proponent and be available to regulatory authorities (if required).

10.4 Asbestos Records

The current extent of known asbestos impacts are illustrated in Appendix 3, Figure 1.

During the Project Works, an Asbestos Register will be maintained by the Site Manager to record any unexpected finds and/or asbestos identified during sampling. The Asbestos Register will be located on site at the main office and also available on the site notice board. The following details provide the information that is supplied in the Asbestos Register: - the location of the asbestos containing materials identified. - the type and description of the material i.e. flat asbestos cement sheet, etc. - the date the materials were identified. - references to photographs and samples. - approximate quantity, condition and accessibility of the material (i.e. depth, is the

material capped?). - recommendations to remove the items prior to any earthworks.


11.0 BUND WALL MATERIAL CHARACTERISATION AND VALIDATION

11.1 Current Site Characterisation

Based on the results from the previous investigations, for the purposes of this CAMP the bund wall area has been defined into the following categories:

1. Special Waste (Asbestos) 2. General Solid Waste Likely to be present – C&D which may contain minor traces

of asbestos 3. General Solid Waste Likely to be present - C&D

Excavated naturally-derived material Appendix 3, Figure 1 illustrates the anticipated extent of the material categories based on interpretation of the DP 2009 and DP2010 reports.

Based on the previous DP investigations all chemical contaminants were found to be within the SAC thresholds taking into account statistical assessment of the results. As such asbestos is the only material of concern identified to date.

11.2 Known Area of Asbestos Contaminated Soil (Special Waste)

According to the previous DP report, the dimension of the area classified as special waste (asbestos waste) is approximately 25 m x 100 m x 1.5 m.

Following excavation of the known area of impact, a qualified occupational hygienist will be required to visually inspect the exposed bund wall face. The occupational hygienist will either issue an asbestos clearance certificate if no suspect asbestos material, construction debris, or other indicators of potential asbestos contamination is identified, or may suggest further excavation and/or implementation of a capping layer.

Following completion of the remedial excavations, validation samples will be collected across the face of the excavation on a 15 m grid. Individual samples (minimum of 10L) will be collected from a depth range of 0mm to 300mm and manually screened onsite through a 7mm sieve. The material retained on the 7mm sieve will be visually examined for evidence of asbestos containing material (ACM) and/or suspect material. If ACM or suspect material is identified, it will be retained for laboratory analysis. A 500 gram sample of the <7mm fraction will be collected for further laboratory processing and analysis.

11.3 Onsite Relocation of Excavated Natural Materials

Approximately 540,000 t (60%) of the bund material is anticipated to comprise of excavated naturally-derived material originating from Cell 1 within the Project. Based on the limited extent of investigation undertaken to date, the following additional material inspection / characterisation is proposed:-


• A suitably qualified Environmental Consultant shall be appointed to progressively monitor and sample movement of excavated naturally-derived material from the bund walls. The Environmental Consultant shall be provided with a schedule of the proposed bund wall earthworks. During earth movements across the bund wall areas the Environmental Consultant will be responsible for collecting samples of the material. Systematic sampling should be undertaken at a minimum rate of 1 sample per 1000 m3 (either in-situ or through a process of temporary stockpiling), unless visual evidence of contamination or a significant amount of foreign contaminants is identified (including potential ACM fragments, odours, staining). If visual evidence of contamination or significant foreign contaminants (>2%, including construction and demolition waste) are identified then the sampling frequency and analytical suite will be reviewed, as follows:

• The new sampling rate should be increased with consideration for the data quality objectives for the Project, the requirements of ‘The excavated natural material order 2014’ and the ASC NEPM (2013) Schedule B2, Site Characterisation National Environment Protection (Assessment of Site Contamination) Measure.

• Samples will be analysed for the suspected contaminants, such as asbestos or any other known or perceived contaminants for the Project.

Individual samples (minimum of 10L) will be collected for visual inspection and manually screened onsite through a 7mm sieve. The material retained on the 7mm sieve will be visually examined for evidence of asbestos containing material (ACM) and/or suspect material. If ACM or suspect material is identified, it will be retained for laboratory analysis. A soil sample of the sieved material will also be retained and analysed for asbestos fibres at a NATA-accredited laboratory, should the fragments return a positive result for asbestos. These soil samples will be analysed for presence and % w/w.

Notwithstanding the above, all bund wall deconstruction works must be undertaken with full time supervision by a competent person, i.e. an environmental consultant.

11.4 Onsite Relocation of General Solid Waste (non-putrescible)

Approximately 355,000 t (40%) of the bund material is anticipated to comprise general solid waste (non-putrescible), being general builder’s rubble including largely demolition waste and waste concrete and similar materials.

A suitably qualified Environmental Consultant shall be appointed to progressively monitor and sample movement of waste material from the bund walls. The Environmental Consultants shall be provided with a schedule of the proposed bund wall earthworks. During earth movements across the bund wall areas the Environmental Consultant will be responsible for collecting samples on a systematic grid pattern at a rate of 1 sample per 500 m3 (either in-situ or through a process of temporary stockpiling). The sampling will be completed prior to final re-location of the bund materials.


Individual samples (minimum of 10L) will be collected for visual inspection and manually screened onsite through a 7mm sieve. The material retained on the 7mm sieve will be visually examined for evidence of asbestos containing material (ACM) and/or suspect material. If ACM or suspect material is identified, it will be retained for laboratory analysis. A 500 gram sample of the <7mm fraction will be collected for further laboratory processing and analysis.


11.5 Investigation for Areas in the Vicinity of Test Bores 6, 7, 8, 9, 17, and 18.

In the previous DP report, asbestos was detected, but below the Reporting Limit, in samples recovered from bores 6, 7, 8, 9, 17, and 18.

A suitably qualified Environmental Consultant shall be appointed to progressively monitor and sample movement of waste material from the bund walls. The Environmental Consultants shall be provided with a schedule of the proposed bund wall earthworks. During earth movements across the bund wall areas in the vicinity of the DP bores 6, 7, 8, 9, 17, and 18 the Environmental Consultant will be responsible for collecting samples on a systematic grid pattern at a rate of 1 sample per 250 m3 (either in-situ or through a process of temporary stockpiling). The sampling will be completed prior to final re-location of the bund materials.

Individual samples (minimum of 10L) will be collected for visual inspection and manually screened onsite through a 7mm sieve. The material retained on the 7mm sieve will be visually examined for evidence of asbestos containing material (ACM) and/or suspect material. If ACM or suspect material is identified, it will be retained for laboratory analysis. A 500 gram sample of the <7mm fraction will be collected for further laboratory processing and analysis.


11.6 Surplus Material for Off-site Reuse

Surplus material visually assessed as natural material, will be further assessed against Resource Recovery Order, the excavated natural material (ENM) order 2014 made under Part 9, Clause 93 of the Protection of the Environment Operations (Waste) Regulation 2014.

The sampling frequencies required under the ENM 2014 and are shown below:

• <500 - 3 samples • 500 – 1,000 - 4 samples • 1,000 – 2,000 - 5 samples • 2,000 – 3,000 - 7 samples • 3,000 – 4,000 - 10 samples


Excavated natural material does not include material located in a hotspot, that has been processed or that contains asbestos, Acid Sulphate Soils (ASS), Potential Acid Sulphate Soils (PASS) or sulfidic ores.

11.7 Waste Classification

Any material requiring off-site disposal shall be assessed for off-site disposal in accordance with the Waste Classification Guidelines Part 1: Classifying waste (NSW EPA, 2014). Waste classifications are to be documented in reports meeting NSW EPA requirements prepared by a competent environmental consultant.

If treatment of excavated material is required to facilitate off-site disposal, an Immobilisation Approval shall be sought from the NSW EPA prior to off-site disposal.

Waste materials removed from the perimeter bunds and taken off-site are to be only disposed to properties that are legally allowed to accept the material. Records are to be kept of the types, volumes, and disposal locations of waste materials removed from the perimeter bunds and disposed off-site.

11.8 Validation of Final Bund Surfaces

A visual validation for ACM will be conducted for the bund walls and the footprint of the bund wall where removed. The validation will be conducted at the following project stages:-

• Completion of Site Establishment. • Completion of Final Landform.

The validation will be completed prior to placement of topsoil for the proposed revegetation program.

The validation program will involve a visual observation of the ground surfaces within the Subject Area. A competent environmental consultant will conduct a slow traverse of the area on a grid pattern. The surfaces will be viewed closely to detect evidence of asbestos debris or fragments. Colour, size and shape will be used as indicators. Observations from the walkover will be documented in a validation report, validation will be considered complete where “No visible asbestos for surface soil” can be demonstrated.

11.9 Validation Plan for End of Project Life

At the end of the Project a final validation report will need to demonstrate the following:-

• The movement of C&D waste (including ACM) from the bund walls has been completed in accordance with this CAMP.

• Appropriate capping in accordance with this CAMP has been installed in areas where ACM remains in-situ.

• A validation walkover has been completed which demonstrates “No visible asbestos for surface soil”.


• Unexpected finds have been remediated and/or characterised in consultation with the EPA Accredited Site Auditor.

• Unexpected finds have been appropriately validated.

• The remaining bund wall material does not present an unacceptable risk to either the on-site or off-site environments.

The validation program will be documented in a report that will be reviewed by the EPA Accredited Site Auditor so that a Section A Site Audit Report can be prepared.


12.0 ASBESTOS AND ENVIRONMENTAL MANAGEMENT DURING EARTHWORKS

The following protocols will be applied when working in areas of known or suspected ACM contamination. A waste classification will be required for any soils to be disposed off-site. Waste Classification will be undertaken by an Environmental Consultant based on previous analytical data, field observation, and if required, additional testing results.

All Contractors working on the Project will be vigilant during earthworks across the development site and stop works to inform the Site Owner, Site Manager, or Construction Manager if suspected ACM is observed outside of the asbestos controlled areas, refer Unexpected Finds Protocol in Section 12.13.

12.1 Control of Earthworks Activities and Dust Management

The following information is provided as a guide to control dust during asbestos impacted earthwork activities in areas of known or suspected asbestos impacted soil:

• An Asbestos Work Area (restricted area) is to be established. The extent of the area will be defined on a Traffic Management Plan.

• The restricted area (proposed excavation/stockpile zone) will be demarcated with appropriate warning signs to prevent unauthorised access. Only workers directly involved with the bund deconstruction activities will be allowed access. Asbestos awareness training will be a pre-requisite for accessing the area.

• Several standard signs will be provided (as per SafeWork NSW requirements) which indicate:-

o Access by authorised personnel only; and o Asbestos Work Area.

These signs will be approximately 500mm (wide) by 300mm (d) and attached to the fence at a minimum frequency of 2 per boundary.

• ACM affected soil will be sufficiently dampened down to minimise the emission of dust and fibres.

• Prior to the first removal of the sub surface, dampening with water of the proposed excavation area.

• Prior to movement of stockpiled soils, dampening with water across the stockpile surface.

• During soil movement continuous water fogging/ misting will occur over the excavated materials.

• The wheels of the dump truck/haulage truck and the sides of the body will be washed down before the truck leaves the restricted area.

The excavation surface will be continually monitored and the surface re-saturated with water as drying occurs. This process will continue until the asbestos containing materials from the marked zone have been excavated.


The above method relies on the following factors:

• Use of water fogging nozzle (not high pressure hoses).

• Constant vigilance of trained operators/Contractor.

Where access allows the use of a water cart will be the preferred method for dampening the soils. Alternatively hand-held sprays or hoses will be employed.

Works will be temporarily ceased if any of the following conditions prevail:

• Excessive dust is being generated.

• Dust is observed to be leaving the Project boundary.

• High wind conditions that will make dust management difficult.

• Site flooding.

12.2 On-site Movement of Asbestos Waste

Transport of asbestos waste from the bund area to the designated disposal cell shall be via a clearly delineated, pre-defined haul route. The proposed transport route will be notified and approved by the Site Manager. The vehicle/container used for transport of asbestos waste before leaving the bund wall area will be wetted down and covered.

Upon the completion of works, vehicles/containers used for the transportation of asbestos waste will be decontaminated.

12.3 Excavation and Material Handling Procedure

The following procedures will be applied to all excavations associated with the bund walls:

• Inspection and validation will be undertaken in accordance with the procedures documented in Section 11.

• Unexpected finds will be reported/managed as per Section 12.13

• If suspected non-asbestos soil contamination is encountered (i.e. as indicated by odours or staining), the suspect materials will be segregated and placed into uniquely-identified stockpiles and appropriately bunded to prevent spreading of materials.

• Stockpiles of suspected soil contamination will be covered with plastic sheeting to prevent rainfall infiltration and/or soil migration during windy conditions.

• Actual or suspect contamination will not be mixed with other materials.

• Appropriate personal protective equipment (PPE) will be worn to prevent exposure to suspected contaminated soils and appropriate hygiene protocols adopted. The PPE and adopted hygiene requirements will be specified in a task-specific safe work method statement (SWMS).


• Soils suspected to be contaminated will be tested prior to on-site reuse or off-site disposal for waste classification. Records of the analysis, waste classification and waste disposal dockets will be recorded and retained.

All material from the bund walls will be tracked from cradle to grave. The tracking information will include original location, material description, unexpected finds, temporary stockpile storage, soil test results where applicable and final destination of the material.

12.4 Burial into Containment Cell

Any asbestos waste (special waste) identified when the bunds are shaped or partially deconstructed will be wetted down and transported in a covered and leak proof vehicle to an active waste emplacement cell. Material will then be disposed of in a manner to prevent the generation of dust. Material will be placed at the toe of the active cell’s batter and covered initially with 0.15 m and by at least 0.5 m of waste or cover at the end of the day. By disposing of the asbestos at the toe of the active cell’s batter, asbestos will not be exposed when the daily cover is scraped back from the top of the emplacement bench in the future. This is in accordance with the Aquaterra 2010 Cell Design report.

The Proponent is required to emplace any special waste (asbestos) in a clearly signposted and segregated area of the active cell. The segregated areas must be designed to ensure that asbestos will not be exposed by daily activities.

The Proponent will need to demonstrate to the EPA how they will ensure accurate records documenting the amount of special waste from the bunds emplaced in landfill before this activity commences.

12.5 Stockpiling

ACM impacted soils requiring temporary stockpiling on site shall be placed in suitable location(s) and shall be surrounded by star pickets and marking tape or other suitable material to clearly delineate their boundaries. The stockpiles are to have appropriate asbestos warning signs affixed to the boundaries to identify the material as asbestos containing.

Stockpiles shall be lightly conditioned by water spray or covered by geotextile or similar cover to prevent dust generation. The contractor shall ensure that the material is stockpiled with adequate angle of repose to ensure stability.

The maximum period for stockpiling ACM impacted soils will be 28 days.

12.6 Environmental Asbestos Air Monitoring

The requirement for asbestos fibre air monitoring will be determined on site by the occupational hygienist based on the findings risk assessment incorporating: site conditions, analytical results, indicators of potential asbestos contamination, or evidence of actual asbestos contamination.


12.6.1 Environmental Asbestos Air Monitoring Programme

12.6.2 Baseline and Source Control Monitoring Prior to commencement of the bund deconstruction works asbestos monitoring will be undertaken to establish the background baseline air quality for the Project. During the first planned ACM disturbance additional source control monitoring will be undertaken in addition to the works monitoring described in Section 12.6.3 below. The additional monitoring will comprise:-

• Set up a minimum 2 monitoring locations inside the asbestos exclusion zone (as close to the face of the excavation as practicable). Additional monitors will be set up as required to ensure that the data collected is representative of the potential source emissions.

• Set up an additional monitoring location at each work area boundary. • Analysis of the samples on a same day turnaround. • Monitor at the additional locations for a period of 3 days.

The results of the baseline and source control monitoring will be considered satisfactory if the results demonstrate that the adopted control measures will minimise emissions to the atmosphere of asbestos to the maximum extent achievable in accordance with the “Approved methods for the sampling and analysis air pollutants in NSW” to demonstrate. Additional source control monitoring may be required to address any unexpected finds.

12.6.3 Works Monitoring

The following presents an overview of the air monitoring program for the bund deconstructions works to be implemented where ACM is known or suspected:

• A minimum of 4 locations will be set up around the asbestos work area.

• Sample collection and analysis will be conducted in accordance with the National Occupational Health and Safety Commission (NOHSC) “Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Dust [NOHSC: 3003 (2005)].

• Sampling will be done with portable asbestos air monitoring pumps.

• The samples will be analysed in accordance with the requirements of the NOHSC method and the results reported on NATA Endorsed Certificates of Analysis.

• The sampling parameters will be selected such that the detection limit of <0.01 fibres/ml is achieved.

12.6.4 Asbestos Air Monitoring Action Levels / Emergency Response

The action levels and required control measures for air monitoring results are outlined in the SafeWork Australia Code of Practice 2016 “How to Safely Remove Asbestos”.

Action is required following air monitoring results at 0.01 fibres/ml or more.

The table below lists the action levels required for elevated air monitoring results.


Table 6: Response Levels & Actions

Action level Control Action

Less than 0.01 fibres/ml No new control measures are necessary

Continue with control measures

At 0.01 fibres/ml or more than 0.01 fibres/ml but less than or equal to 0.02 fibres/ml

1. Review Review control measures

2. Investigate Investigate the cause

3. Implement Implement controls to eliminate or minimise exposure and prevent further release

More than 0.02 fibres/ml 1. Stop removal work Stop removal work

2. Notify regulator Notify the relevant regulator by phone followed by fax or written statement that work has ceased and the results of the air monitoring

3. Investigate the cause Conduct a thorough visual inspection of the enclosure (if used) and associated equipment in consultation with all workers involved with the removal work

4. Implement controls to eliminate or minimise exposure and prevent further release

Extend the isolated/barricaded area around the removal area/enclosure as far as reasonably practicable (until fibre levels are at or below 0.01 fibres/ml, wet wipe and vacuum the surrounding area, seal any identified leaks (e.g. with expandable foam or tape) and smoke test the enclosure until it is satisfactorily sealed.

5. Do not recommence removal work until further air monitoring is conducted

Do not recommence until fibre levels are at or below 0.01 fibres/ml

12.7 Decontamination and PPE

Where personnel are required to work on the ground within the designated asbestos areas and are required to handle, or are likely to come into direct contact with asbestos material the following minimum PPE is required:

• Safety boots with rubber soles.

• Disposable coveralls (asbestos approved). Orange disposable overalls are recommended when working in close proximity to excavators.


• Suitable respiratory protection, i.e. minimum P1 or P2 half face respirators.

• Gloves are optional.

A decontamination area will be established at the entrance/exit of all Asbestos Work Areas for the use of the personnel conducting the asbestos related works. The decontamination area will comprise a segregated area where the contaminated work clothing and respirators are removed and discarded. Contaminated overalls and PPE is to be disposed of in appropriately labelled waste bins or bags.

The above mentioned PPE is required every time personnel enter the Asbestos Work Area. This PPE is only for use in the work area and will not be used outside of this area. Decontamination procedures are required every time personnel leave the work area. This will result in several sets of PPE used daily.

The decontamination area must not be used for purposes other than decontamination. It must not be used as a materials storage area. Personnel will remove disposable protective clothing prior and will be required to ensure that no asbestos soiled clothes or PPE leave the decontamination area.

12.8 Decontamination of Trucks and Equipment

Excavator and truck windows are to be closed and air conditioning systems set to recycle (not fresh air intake) during all asbestos impacted earthworks.

Trucks and equipment leaving the Project are to be inspected and decontaminated in accordance with Roads and Maritime Services (RMS) and other relevant governmental regulations to ensure soil is not tracked off-site.

The wheels and the sides of the body of the dump truck/haulage truck and excavator will be washed down before the truck leaves the restricted area.

12.9 Air Quality Appropriate mitigation measures will be put in place during bund deconstruction works to minimise the production generation of dust. Dust minimisation measures will include:

• use dust suppression measures to minimise dust generation.

• if weather conditions are assessed to be adverse (high winds) works would temporarily cease until conditions ease.

• the length of time that segregated soil stockpiles are stored on site will be minimised.

Dust levels for particulate matter <10µm (PM10) should not exceed 50 µg/m3 over a 24 hour averaging period. Any indicators of odour encountered during the works will be recorded and appropriate odour suppressants utilised if required.


12.10 Surface Water Mangement

The following surface water management measures will be implemented at the Project during the proposed works.

• All sections of existing bund walls which are being deconstructed and known to contain waste that could generate leachate will have an earthen bund and/or silt fence installed around their lower points to contain run-off from rainfall. Management of water from this circumstance has been included in the site leachate modelling for the Project.

• If suspected chemically contaminated soils (i.e. odours or staining observed) are encountered during the excavations works the potentially contaminated materials will be segregated and stockpiled on plastic sheeting.

• Where any stockpiled soil materials require wetting down for dust suppression, the stockpile will be bunded with hay bales or silt fences prior to wetting, to prevent sediment-laden runoff.

12.11 Sediment and Erosion Control

Sediment controls will be installed and maintained in accordance with the Blue Book (Landcom Managing Urban Stormwater: Soils and Construction 2004) and the procedures as outlined the Soil, Water and Leachate Management Plan.As a minimum all sections of existing bund walls which are being deconstructed and known to contain waste that could generate leachate will have an earthen bund and/or silt fence installed around their lower points.

12.12 Noise Management

Noise requirements will be managed under a different management plan.

12.13 Unexpected Finds Protocol

An unexpected finds protocol is to be adopted and will apply to presently unknown contamination of all forms (asbestos and non-asbestos) that may be encountered during work on the perimeter bunds.

All unexpected finds will be recorded with the records included in the annual validation / tracking reports.

Based on the existing site characterisation no chemical testing has been proposed. Potential chemical contaminations which could be encountered might be indicated by:

• Discoloured soils.

• Oil sheen or staining.

• Odorous soils.

• Evidence of ash material.


• The presences of other foreign materials, such as drums, waste, or building rubble which could be a source of contamination.

If any areas of suspect contamination not previously identified are encountered during the remediation work they will be managed under an Unexpected Finds Protocol. The Unexpected Finds Protocol is documented in Appendix 9.

The unexpected finds protocol for ACM is described below and summarised in the flow chart in Appendix 9.

During the earthworks, the machine operators or spotters will watch the materials being excavated for evidence of building spoil, other indicators of anthropogenic input, and/or possible asbestos contamination. If unknown building materials, or materials suspected to contain asbestos are exposed, the following will be implemented:

(1) Is the suspect material friable? Friable materials are defined as those materials that can be crushed by hand pressure when dry. Friable materials include: pipe-lagging, asbestos millboard and woven insulating materials. Non-friable (bonded) materials are harder and less likely to release asbestos fibres. Bonded materials include: asbestos cement sheet materials, vinyl asbestos floor tiles and other asbestos composites.

If the suspect material is judged to be friable:

− works will cease in immediate area of the find;

− cover the friable materials so they are not exposed to the elements;

− the subject area will be barricaded off and access restricted to authorised personnel; and

− the suspect material will be assessed by an Occupational Hygienist.

(2) If the suspect materials are judged to be ‘bonded’ (non-friable), the area is to be treated as an Asbestos Work Area, refer Section 12.1. The identification of additional ACM may require additional investigation works to delineate the extent of the ACM.

12.14 Contingency Risk Management

Should unexpected conditions arise, contingency measures will be required to resolve the resulting problems. A summary of the conditions that might reasonably be encountered, the resulting problems they may cause, and how these problems may be resolved within the context of the upgrade works, is presented in Table 7.


Table 7: Risk Management Actions

Potential Issues

Evidence / Signs Corrective Action

Excessive dust Dust on-site and/or off-site

Complaints from neighbours

Results of dust monitoring indicate levels above those acceptable

Increase wetting of excavation and/or stockpile surfaces;

Cover excavation and stockpile surfaces where appropriate;

Minimise exposed surfaces;

Review materials handling procedures;

If required cease dust-generating activity until better dust control can be achieved; and

Install dust deposition gauges to monitor effectiveness of dust controls implemented at the Project.

Breach of sediment fencing

Discoloured water and/or sediment in stormwater

Stop work and repair.

Release of fuel/oil from machinery

Oily sheen on ground Remove source, use absorbent booms, to remove oil and make repairs as required.

Unexpected asbestos containing materials identified

Asbestos sheeting / lagging material observed

Follow Unexpected Finds Protocol.

Record in cradle to grave tracking records.

Encounter drums or other previously unknown impacted objects and materials

Encountered on-site by site personnel.

Follow Unexpected Finds Protocol.

Record in cradle to grave tracking records.

If object is drum, contact disposal specialists. Do not open drum if swollen or bulging. Material will be assessed appropriately by a suitably qualified expert.

Excessive odour Complaints from neighbours

Olfactory observations by personnel on site.

Follow unexpected finds protocol.

Minimise working area within odorous soils.

Excavation works would take advantage of the prevailing winds to minimise the dispersal of nuisance odours to any neighbouring properties; and

Use of odour suppressant such as Biosolve™ or suitable alternative may be applied to stockpiled excavated material to reduce odour.


13.0 RESTORATION AND CAPPING

13.1 Containment of Asbestos Waste

Clause 80 of the Protection of the Environment (Waste) Regulation 2014 stipulates the depth of final cover above emplaced asbestos waste. The occupier of a landfill site must ensure that asbestos waste disposed of at the site is covered with virgin excavated natural material or (if expressly authorised by an environment protection licence held by the occupier) other material:

(1) initially (at the time of disposal), to a depth of at least 0.15 metre, and

(2) at the end of each day’s operation, to a depth of at least 0.5 metre, and

(3) finally, to a depth of at least 1 metre (in the case of bonded asbestos material or asbestos-contaminated soils) or 3 metres (in the case of friable asbestos material) beneath the final land surface of the landfill site.

13.2 Materials to Remain in the Bund Walls

DP (2009) identified small concentrations of asbestos in a bonded matrix and the soil within some areas of the bunds. The bunds which will not be fully deconstructed and contain materials with low concentrations of asbestos will have a final capping and rehabilitation layer placed over them with a depth greater than 1 m. This would ensure compliance with Clause 80.

13.3 Landscaping

All areas of the final landform will be progressively revegetated soon after the areas are shaped and covered with topsoil.

Revegetation will commence during the site establishment phase to stabilise the northern and eastern faces. Emphasis will be placed upon rapid stabilisation using hydromulch and a pasture mix with native grass.

Following initial stabilisation, the entire northern face and eastern fence will be revegetated with native trees and shrubs.

13.4 Survey

A record must be kept of the volume of asbestos waste placed into an on-site containment cell, days on which it was placed, interim and final capping layers.

A survey of the final reshaped bund walls will be undertaken by an Accredited Surveyor before and after capping, showing the location, elevation and contours of the bund walls.


13.5 Record Keeping

Records of the Works will need to be kept by the Proponent (or their delegation), and will include:

• Excavation volumes. • Stockpile assessment and management information. • Air monitoring information. • Disposal/ re-use locations. • Transport and landfill dockets (for any materials taken off-site). • Containment cell details. • Survey plans. • Any issues managed under the unexpected finds protocol. • Photographic records.

13.6 Reporting

Following completion of Stage 1 works an Operational Environmental Management Plan (OEMP) shall be prepared. The OEMP will detail the ongoing management requirements for the residual contamination at the Project during its operations as a waste and resource management facility. The OEMP would include the following information:

• Details of any contaminated materials contained at the Project, including containment construction details and survey plans.

• Requirements for ongoing management of the contained contaminated materials.

• Requirements for any future works which may be conducted in the containment areas, including the need for Occupational Health Safety Plans.

• An Asbestos Register detailing all contained asbestos.

The OEMP will be reviewed and assessed by the EPA Accredited Site Auditor and the results of the review documented in a Section A SAS/SAR, as required by Condition 7(l) on the Development Consent. The OEMP will need to be approved in writing by Penrith City Council prior to the Section A being issued, as required by Section 3.4.5 of the EPA Site Auditor Guidelines.

13.7 Community Consultation

Community Consultation will be managed under a different management plan.


14.0 REFERENCES

The Contamination and Asbestos Management Plan references the following documents:

(i) NSW Work Health and Safety Act 2011

(ii) NSW Work Health and Safety Regulation 2011

(iii) NSW Protection of the Environment Operations Act 1997

(iv) NSW Protection of the Environment (Waste) Regulation 2005

(v) Safe Work Australia “How to Safely Remove Asbestos – Code of Practice 2016”

(vi) Safe Work Australia, “How to Manage and Control Asbestos in the Workplace - Code of Practice 2016”

(vii) Safe Work Australia, “Guidance Note on the Membrane Filter Method for Estimating Airborne Asbestos Fibres 2nd Edition [NOHSC:3003(2005)]”

(viii) SAI Global, Australian Standard “AS 1319-1983 Safety Signs for the Occupational Environment”

(ix) SAI Global, Australian Standards AS1715-2009 “Selection, use and maintenance of respiratory protective devices”

(x) SAI Global, Australian Standards AS1716-2012 “Respiratory protective devices”

(xi) SAI Global, Australian Standard AS 3544-1988 “Industrial vacuum cleaners for particulates hazardous to health”

(xii) SAI Global, Australian Standard AS4260-1997 “High efficiency particulate air (HEPA) filters – Classification, construction and performance”

(xiii) SAI Global, Australian Standard AS4801-2001 “Occupational health and safety management systems - Specification with guidance for use”

(xiv) SAI Global, Australian Standard, “AS 31000-2009 Risk Management – Principles and guidelines”

(xv) SAI Global, HB9-1994 “Occupational Personal Protection”



APPENDIX 1: SITE LOCATION PLAN AND SITE SURVEY

Sydney

PenrithParramatta

Liverpool

CampbelltownCamden

Patons Lane

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ORCHARD HILLS

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Patons Lane Resource Recovery Centre

ARCADIS AUSTRALIA PACIFIC PTY LTDABN 76 104 485 289Level 16, 580 George Street, Sydney | NSW 2000P: +61 (0) 2 8907 9000 | F: +61 (0) 2 8907 9001

Created by : NSQA by : RB

Date: 22/03/2019 Path: \\HC-AUS-NS-FS-01\jobs\10027296\L-GIS\A_Current\B_Maps\ProjectDescription\G10027296_PD_003_SiteLocation_A4P_v2.mxd

SITE LOCATION

Coordinate System: GDA 1994 MGA Zone 56Date issued: March 22, 2019

0 500m

LEGEND

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1:20,000 at A4

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SP 8

STOCKPILE 6

SP

STOCKPILE 1

STOCKPILE 2

SP

STOCKPILE 3

STOCKPILE 7

RL 20.16

STOCKPILE 4

34,110m3

SP 9

38,820m3

4,113m3

63,400m3

30,571m3

STOCKPILE 5

2,480m3

11,135m3

1,217m3

544m35,094m3

BUNDWALL 2 69m3 CUT

BUNDWALL 1 382,557m3 FILL

PART BUNDWALL 1

STOCKPILE VOLUMES ARE CALCULATED

USING THE EXISTING GROUND LEVELS

AT THEIR BASE & INTERPOLATING

CONTOURS UNDER THEM.

QUARRY AREA 117,094m3 CUT SINCE 18.12.06

QUARRY AREA 25,459m3 FILL SINCE 18.12.06

14,189m3BUNDWALL 3

BUNDWALL 1446,947m3

PART BUNDWALL 1

105,924m3BUNDWALL 2

BUNDWALL 4373,110m3

QUARRY AREA 1 INCLUDS5,094m3 OF WATER IN POND No2

QUARRY AREA 2 INCLUDS1,252m3 OF WATER IN POND No2

QUARRY AREA 2 131,622m3 CUT

QUARRY AREA 1 236,608m3 CUT



CURRENT VOLUMES O BUNDWALLS

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MORE WATER THAN 06

MORE WATER THAN 06

105,924m3

12,316m3

1,252m3

14,189m3

MORE WATER THAN 06

4,707m3 FILL SINCE DEC 02

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APPENDIX 2: CONSULTATION WITH AGENCIES The Project Approval Schedule 4 Condition 7 requires that the Contamination and Asbestos Management Plan be prepared in consultation with WorkCover NSW (now Safework NSW), NOW and EPA. Attached is a summary of issues raised following a review of the draft CAMP by these agencies and responses from the proponent resulting from this consultation.

Consultation Document

Comment/Query Hibbs & Associates Response

EPA DP&E Letter Dated 3 May 2017

Section 5.1 Douglas Partners 2009 Report Section 5.1.1 of the CAMP refers to the DP 2009 Report which states that Test Bores 6-9, 17 and 18 may contain minor traces of asbestos and would require further investigations to determine the extent of asbestos contamination in the fill. Section 5.1.2 - DP 2010 Report, however, makes no mention of further investigation being conducted at test bores 6-9, 17 and 18. The EPA requires the proponent to provide justification as to why further investigation and sampling has not been conducted in these test bores.

Asbestos was detected in Test Bores 6, 7, 8, 9, 17, and 18 but was below the laboratory Reporting Limit. Additional investigations were commissioned by the Proponent to delineate asbestos at levels above the laboratory reporting limit in Test Bore 12. The logs for Test Bores 6, 7, 8, 9, 17, and 18 do not indicate the presence of substantial C&D waste. Based on field observations and given: (i) that where asbestos identified in Test Bores 6, 7, 8, 9, 17, and 18, it was below the laboratory Reporting Limit (and well below levels which can be observed by the naked eye); and (ii) the limited accessibility of the bund soils by bore drilling; the most appropriate and robust method for conducting additional inspection and investigation of asbestos contamination in the vicinity of these test bores is during the bund movement associated with Stage 1 activities. The CAMP includes a program of additional material characterisation investigation to be undertaken during Stage 1 activities (Section 10). Sub-section 10.4 includes increased investigation for areas in the vicinity of Test Bores 6, 7, 8, 9, 17, and 18.

Section 6.3.2 General Bund Re-profiling The proponent will need to provide robust methodology to the EPA showing how the volume of waste removed from the bunds and emplaced in the landfill cell will be accurately measured and monitored.

The Section has been updated to include the test below. “The following procedures will be employed in respect of keeping records of any asbestos containing materials found on site which are transported to the landfill for disposal: Any materials containing asbestos required to be landfilled will be isolated in separate stockpiles. These materials will then be loaded into dump tracks with a front end loader equipped with a computerised weighing/scale system. This will allow the tonnages for materials dispatched to the landfill to be accurately recorded with daily tonnages being printed off for record keeping. As an additional safeguard, the dump trucks to be utilised for this task will also have an internal weighing system.”



Section 8.3 Estimated Quantities The EPA notes that Schedule 4 Condition 8 of the project approval states “the proponent shall ensure that all material to cover and cap waste is Virgin Excavated Natural Material, or excavated natural material provided the use of the excavated natural material is approved in writing by the EPA”. Any general support of the CAMP does not include written approval to use ENM from the bund walls as daily cover. Written approval will need to be subsequently sought by the Proponent and a testing regime to use this material may be required that is different to that outlined in the CAMP.

Section 8.3 has been updated to include a statement that ’Schedule 4 Condition 8 of the project approval states “the proponent shall ensure that all material to cover and cap waste is VENM, or ENM provided the use of the ENM is approved in writing by the EPA’’. The Proponent shall obtain approval in writing by the EPA prior to re-use of ENM to cover and cap waste.’

Section 8.3 Estimated Quantities The first paragraph on page 35 of the CAMP includes the text ‘The north eastern and eastern bunds would be capped with on-site clay and revegetated in accordance with the FMPPR and subsequent joint conference agreements’. The EPA requires clarification on what the proponent means by ‘subsequent joint conference agreements’.

Term ‘subsequent joint conference’ has been removed.

Section 10.2 Known Area of Asbestos Contaminated Soil (Special Waste) The CAMP proposed that should an unexpected find of asbestos be identified in the bunds, the asbestos may be capped within the bund. Should this approach be undertaken, the EPA reminds the Proponent that they must comply with clause 80 of the Protection of the Environment Operation (Waste) Regulation 2014 relating to the requirements for the disposal of asbestos waste.

It is highlighted to the Proponent that they must comply with Clause 80 of the Protection of the Environment Operation (Waste) Regulation 2014 relating to the requirements for the disposal of asbestos waste. See also CAMP Sections 13.1 and 13.2.



Section 10.3 Onsite relocation of excavated materials The proposed sampling density is well below what’s required in the Excavated Natural Material Resource (ENM) Recovery Order. The EPA recommends that the text in this section be amended to read: A suitably qualified and experienced Environmental Consultant shall be appointed to continually monitor and sample movement of ENM material from the bund walls. The Environmental Consultants shall be provided with a schedule of the proposed bund wall earthworks. During earth movements across the bund wall areas, the Environmental Consultant will be responsible for collecting samples of the material. Systematic sampling should be undertaken at a minimum rate of 1 sample per 1000 m3 , unless visual evidence of contamination or a significant amount of foreign contaminants is identified (including potential ACM fragments, odours, staining). If visual evidence of contamination or significant foreign contaminants (>2%, including construction and demolition waste) are identified then the sampling frequency and analytical suite will be reviewed, as follows:

• The new sampling rate should be increased with consideration for the data quality objectives for the site, the requirements of ‘The excavated natural material order 2014’ and the ASC NEPM (2013) Schedule B2, Site Characterisation National Environment Protection (Assessment of Site Contamination) Measure.

• Samples will be analysed for the suspected contaminants, such as asbestos or any other known or perceived contaminants for the site.

As per the current version, if no evidence of contamination is identified during the excavation and inspection of the material, then individual samples (minimum of 10L) will be collected. If ACM or suspect material is identified, it will be retained for laboratory analysis. A soil sample of the sieved material will also be retained and analysed for asbestos fibres at a NATA-accredited laboratory, should the fragments return a positive result for asbestos. These soil samples should be analysed for presence and % w/w.

Section 10.3 has been updated with the recommended text.



Section 11.1 Control of Earthworks Activities and Dust Management The EPA recommends that the CAMP be amended to require that ACM affected soil be sufficiently dampened down to minimise the emission of dust and fibres.

Section 11 has been updated to include this requirement.

Section 11.4 Burial into Containment Cell Condition 8A of Schedule 4 of the project approval states “the proponent may emplace up to 7,500m³ of special waste (asbestos) identified under Condition 7 Schedule 4 in the landfill. All other special waste (asbestos) shall be disposed of off-site at a licenced facility unless agreed to by the Director-General and EPA”. The management plan proposes that “any asbestos waste (special waste) identified when the bunds are shaped or partially deconstructed will be placed at the toe of the active cell’s batter and covered initially with 0.15 m and by at least 0.5 m of waste or cover at the end of the day. By disposing of the asbestos at the toe of the active cell’s batter, asbestos will not be exposed when the daily cover is scraped back from the top of the emplacement bench in the future”. Page 3 The EPA requires the proponent to emplace any special waste (asbestos) in a clearly signposted and segregated area of the active cell. This segregated area must be designed to ensure that asbestos will not be exposed by daily activities. As documented above the proponent will need to demonstrate to the EPA how they will ensure accurate records documenting the amount of special waste from the bunds has been emplaced in the landfill before this activity commences.

Section 11.4 has been updated to note the following: “The Proponent is required to emplace any special waste (asbestos) in a clearly signposted and segregated area of the active cell. The segregated areas must be designed to ensure that asbestos will not be exposed by daily activities. The Proponent will need to demonstrate to the EPA how they will ensure accurate records documenting the amount of special waste from the bunds emplaced in landfill before this activity commences.”



Section 11.5 Stockpiling Whilst the proposed management of stockpiled ACM impacted soils appears satisfactory, the EPA requires the proponent to define the maximum time period this material will be stockpiled

Section 11.5 has been updated to note:

The maximum period for stockpiling ACM impacted soils will be 28 days.

Consistency with Air Quality and Greenhouse Gas Management Plan prepared by Todoroski Air Sciences 28 March 2017 (AQGGMP) Section 11.9 Air Quality Section 11.9 of the Contamination & Asbestos Management Plan states “Any indicators of odour encountered during the works will be recorded and appropriate odour suppressants utilised if required. A photo ionisation detector (PID) will be used as a screening tool on site to monitor the presence of volatile organic compounds (VOCs) if indicators of chemical contamination are observed (unexpected finds). The EPA notes that the Air Quality and Greenhouse Gas Management Plan prepared by Todoroski Air Sciences 28 March 2017 makes no mention of a photo ionisation detector being used to monitor the presence of VOCs. The EPA requires that the proposed management methods are consistent throughout the management plans submitted to meet conditions of the Project Approval.

We acknowledge that the EPA requires consistency across the different management plans. Reference to PID monitoring has been removed from Section 11.9.

Use of the term ENM The EPA advises that until material has been appropriately tested and meets the requirements of the Excavated Natural Material Order 2014 (including minimal sampling density) it cannot technically be called ENM.

The description used in the CAMP for natural material that has not been tested has been changed to - excavated naturally-derived material.



NSW Department of Primary Industries/Water email dated 24/4/2017

Email requested – 1)the data collected during the first 12 months of the site establishment works 2.) a copy of the Annual Environmental Management Review (AEMR)

This requirement has been added to; Table 2: Consent Conditions Summary in Section 1.5.

Safework NSW email dated 19/1/17

1. The training requirements for workers refers to the bonded asbestos removal training or Asbestos awareness, given the likelihood of disturbing asbestos at this location our preference would be for all workers to undertake bonded asbestos removal training with site specific information provided to workers prior to undertaking work. 3 I am interested in how the plan including the unexpected finds protocol will be communicated to workers prior to its implementation.

A thorough agenda for the proposed asbestos awareness training has been developed and is presented in Section 9.3.

The proposed training will include information about the CAMP including the unexpected finds protocol.

2. In definitions Asbestos Removal Contractor: the Class A licensed asbestos removal contractor experienced in the large-scale removal of friable asbestos-containing material. I would like to confirm that the asbestos removal contractor is going to be a Class A Contractor and that the class A contractor will oversee all works that may disturb asbestos.

The following note has been added to Section 9.2:

Under this CAMP a Class A Contractor shall be appointed to oversee works that will disturb the known areas of asbestos in the bund material.

EPA Department of Planning and Environment

Update Sections 1.3, 8.5 and 12.7.1 to reflect current timing and approvals.

Sections 1.3, 8.5 and 12.7 have been updated in the revised CAMP to reflect the current project status including timing and approvals.

Include a description of Stage 1 works.

Additional background project information and description has been included in the revised CAMP.

Summarise the outcome of consultation with agencies including how comments and recommendations were/will be addressed (including the site auditor’s recommendations).

Consultation records are provided in Appendix 2 in the updated CAMP.



The Plan is to contain measures that will be undertaken, rather than those that ‘should’ be. Please reword to reflect the measures that will be undertaken to manage asbestos and other contamination.

This change has been applied to the updated CAMP where applicable

The Further Modified Preferred Project Report commits to the emplacement of asbestos waste, from the vicinity of hole 12, within 3 months from the emplacement activities on Cell 1A. Please include in the plan.

The following has been added to Section 8.5 (now9.5)

• The emplacement of asbestos waste from the vicinity of hole 12 will be completed within 3 months from the emplacement activities on Cell 1A.



APPENDIX 3: PREVIOUS BUND WALL INVESTIGATION

Patons LanePatons Lane

Sto

ckd

ale

Ro

ad

Sto

ckd

ale

Ro

ad

CELL 1CELL 2

RRA PLATFORM

CELL 3

Sediment Dam 5location under review

Contingency stockpilearea

Northeastern bund

Additional trimming forNortheastern bund

Northeastern bundexcavation - delayed works

East/west bund boundary

Sediment dam 4 relocation

Additional trimming forNorthwestern bund

Initial leachateevaporation dam

Intercell bund excavation

Inte

rcel

l bun

dex

cava

tion

Intercell b

und excava

tion

Southern RRA bund

South and Southwestern bund

Northwestern bund

Northern RRA bund

1414

1515

1616

1717

1818

1919

11

22 3344

5566

77

99

1010

1111

2020

88

1212

1313

Site boundaryPerimeter bunds (GHD)

(RRA)

Proposed extent of landfillingContingency stockpile area (GHD)Recycling and re-processing area

Special waste (asbestos) surface to approximately 1.5mbglMay contain minor traces of asbestosConstruction and demolition waste (likely present)Limit of extraction (FMPPR)Douglas Partners (2009) sample locations

Source: GHD 24-25736 SK001 10/10/2016Note: Based on survey provided by Matthew Freeburn Land, Engineering & Mining Surveyors (August 2007 & September 2016)Source: GHD 24-25736 SK001 10/10/2016Note: Based on survey provided by Matthew Freeburn Land, Engineering & Mining Surveyors (August 2007 & September 2016)

00 100100 200m200m

NEW

SOUTH WALES

SITE SYDNEY

Canberra!

!

Pacific

Ocean

Tasman

Sea

Date: 07/11/2016HIBBS & Associates Pty Ltd Australia do not warrant the accuracy or completeness of information in this publication and any person using or relying upon such information does soon the basis that this company shall bear no responsibility or liability whatsoever for any errors, faults, defects or omissions in the information

FIGURE 7 - PREVIOUS BUND WALL INVESTIGATION

N



APPENDIX 4: AQUATERRA GROUNDWATER TABLES

SPECIALIST CONSULTANT STUDIES 2 - 15 DELLARA PTY LTD Part 2: Cell Design and Groundwater Assessment Orchard Hills Waste and Report No. 582/04 Resource Management Facility

Aquaterra Consulting Pty Ltd

Table 2.1

Summary of Hydraulic Testing – Horizontal Hydraulic Conductivity

Kh (m/d) Kh (m/s)

Solution NE Piezometer NW Piezometer NE Piezometer NW Piezometer

CRT Drawdown (Jacob) 0.0022 0.09 2.6E-08 1.04E-06

Recovery (Thies) 0.0006 0.14 6.94E-09 1.62E-06

Slug test (Hvorslev) 0.001 - 1.16E-08 -

Geometric mean1 0.001 0.11 1.3E-08 1.3E-06 1 Geometric mean is used to evaluate data covering several orders of magnitude. Geometric mean is a log-transformation of data

to enable meaningful statistical evaluations.

2.4.3 Groundwater Levels

Groundwater levels in the shale were measured in the two piezometers on 17 June 2009, 28 July 2009 and 16 November 2009 and were found to be consistent between all dates. This time period was sufficient to ensure that the groundwater levels had stabilised after the piezometers were installed and tested.

The standing water level was also measured in June 2009 in the abstraction bore. The bore log for the abstraction bore indicates that it is an open hole for the lowest 33 m of shale and extends a further 118 m into the underlying Hawkesbury Sandstone.

The groundwater levels are presented in Table 2.2.

Table 2.2

Standing Water Level

Ground elevation (mAHD)

Standpipe height (magl)

DTW (mbsp) DTW (mbgl)

Groundwater Level

(mAHD)

NW Bore 17/06/2009 35.5 0.92 5.58 4.66 30.8

28/07/2009 35.5 0.92 5.55 4.63 30.9

16/11/2009 35.5 0.92 6.06 5.14 30.4

NE Bore 17/06/2009 42.0 0.92 4.9 3.98 38.0

28/07/2009 42.0 0.92 4.68 3.76 38.2

16/11/2009 42.0 0.92 5.05 4.13 37.9

Abstraction Bore 17/06/2009 45.0 0.2 17.36 17.16 27.8 magl = metres above ground level / mbsp = metres below standpipe / DTW = metres below ground level (mbgl)

Figure 2.2 is a schematic depicting the Site’s geology, groundwater levels in the Bringelly Shale and Hawkesbury Sandstone. The level of the interface between Ashfield Shale and Hawkesbury Sandstone has been inferred from the abstraction bore’s log.

SPECIALIST CONSULTANT STUDIES 2 - 17 DELLARA PTY LTD Part 2: Cell Design and Groundwater Assessment Orchard Hills Waste and Report No. 582/04 Resource Management Facility

Aquaterra Consulting Pty Ltd

2.4.4 Groundwater Sampling

During the CRTs for the Site’s two piezometers, field measurements of temperature, pH and EC were continuously recorded and a water sample collected once consecutive readings stabilised to within 10% of the previous reading and at least 3 bore volumes had been purged. Also the Site’s groundwater abstraction bore was pumped and when temperature, pH and EC stabilised within 10% of the previous reading and at least several bore volumes had been purged a sample was collected. At this time, groundwater samples were collected in laboratory prepared containers, stored on ice and submitted with a chain of custody to ALS Environmental Pty Ltd (ALS) for analysis of the following analytes (ALS is a NATA accredited laboratory for the analyses undertaken):

• General:

• pH, EC, total dissolved solids (TDS) and alkalinity.

• Major ions:

• Sulfate, chloride, calcium, magnesium, sodium, potassium, fluoride, and carbonate (as CaCO3).

• Dissolved metals:

• Aluminium, arsenic, barium, cadmium, chromium, cobalt, copper, lead, manganese, mercury and zinc.

• Nutrients:

• Nitrite (as N), nitrate (as N) and nitrite + nitrate (as N), ammonia, total organic carbon

• Pesticides and Hydrocarbons:

• Organochlorine pesticides (OC), organophosphorus pesticides (OP), polynuclear aromatic hydrocarbons, total petroleum hydrocarbons and BTEX.

The results of field measurements and laboratory testing of the shale groundwater collected from the NW and NW piezometers are presented in Appendix 1.

A summary of the Site’s groundwater chemistry is presented in Table 2.3.

Table 2.3

Summary of Groundwater Chemistry

Compound Unit NW NE Abstraction Bore

pH Value pH Unit 6.56 6.28 6.99

Total Dissolved Solids mg/L 8930 13000 –8300

Total Alkalinity as CaCO3 mg/L 599 353 –897

Total Ammonia as N mg/L 2.73 0.36 1.02

Organophosphorus Pesticides (OCP) µg/L BLD BLD BLD

Polynuclear Aromatic Hydrocarbons (PAH) µg/L BLD BLD BLD

Total Petroleum Hydrocarbons (TPH) µg/L BLD 200 BLD

BLD = Below Level of Detection



APPENDIX 5: SITE ASSESSMENT CRITERIA

Table 1. Site Assessment CriteriaHibbs Job: S9171

AnalyteHIL (C) -

Recreational/Open Space

HIL (D) - Commercial/

Industrial

HSL C Soil - Vap Int (Recreational / Open Space) Sand

0 m to <1 m


1 m to <2 m


2 m to <4 m


+ 4 m

HSL D Soil - Vap Int (Commercial /

Industrial) Sand 0 m to <1 m

HSL D Soil - Vap Int (Commercial / Industrial) Sand 1

m to <2 m

HSL D Soil - Vap Int (Commercial / Industrial) Sand 2

m to <4 m

HSL D Soil - Vap Int (Commercial / Industrial) Sand +

4 m

EILs - Urban Residential and

Open Space

ESLs Urban Residential and Open Space -

Coarse

ESLs Urban Residential and Open Space -

FineTRH - NEPM 2013C6 - C10 Fraction minus BTEX (F1)

- - NL NL NL NL 260 370 630 NL - 180# 180#

>C10 - C16 Fraction - - - - - - 120# 120#>C10 - C16 Fraction minus Naphthalene (F2)

- - NL NL NL NL NL NL NL NL - - -

>C16 - C34 Fraction - - - - - - - - - - - 300 1300>C34 - C40 Fraction - - - - - - - - - - - 2800 5600BTEXNBenzene - - NL NL NL NL 3 3 3 3 - 50 65Toluene - - NL NL NL NL NL NL NL NL - 85 105Ethylbenzene - - NL NL NL NL NL NL NL NL - 70 125m&p-Xylene - - - - - - - - - - - - -ortho-Xylene - - - - - - - - - - - - -Total Xylenes - - NL NL NL NL 230 NL NL NL - 105 45Sum of BTEX - - - - - - - - - - - - -Naphthalene - - NL NL NL NL NL NL NL NL 170 - -MetalsArsenic 300 3000 - - - - - - - - 100 - -Cadmium 90 900 - - - - - - - - - -Chromium 300 3600* - - - - - - - - 190 - -Copper 17000 240000 - - - - - - - - 60 - -Lead 600 1500 - - - - - - - - 1100 - -Nickel 1200 6000 - - - - - - - - 30 - -Zinc 30000 400000 - - - - - - - - - - -Mercury 80 730 - - - - - - - - - - -PAHsSum of polycyclic aromatic hydrocarbons

300 4000 - - - - - - - - - - -

Benzo(a)pyrene TEQ (zero) 3 40 - - - - - - - - - 0.7 0.7Phenolic CompoundsPhenol 40000 240000 - - - - - - - - - - -Total Cresol 4000 25000 - - - - - - - - - - -Pentachlorophenol 120 660 - - - - - - - - - - -

LegendTRH: Total recoverable hydrocarbons

BTEXN: Benzene, toluene, ethylbenzene, xylenes and naphthalene

PAHs: Polycyclic aromatic hydrocarbons

OCPs: Organochlorine pesticides

PCBs: Polychlorinated biphenyl

LOR: Limit of reporting

All values in mg/kg: milligrams per kilogram

NL: Not limiting

- : no guideline

*Guideline for Chromium VI

#moderate reliability

National Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Environmental Screening Levels (ESL)- Urban Residential and Open Space (Coarse)National Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Environmental Screening Levels (ESL)- Urban Residential and Open Space (Fine)

National Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Health-based Investigation Levels (HIL) 'C' Recreational/Open SpaceNational Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Health-based Investigation Levels (HIL) 'D' Industrial/ CommercialNational Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Health Screening Levels (HSL) C for Vapour Intrusion - Recreational/Open Space (Sand) 0 m to <1 mNational Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Health Screening Levels (HSL) C for Vapour Intrusion - Recreational/Open Space (Sand) 1 m to <2 mNational Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Health Screening Levels (HSL) C for Vapour Intrusion - Recreational/Open Space (Sand) 2 m to <4 m

National Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Health Screening Levels (HSL) C for Vapour Intrusion - Recreational/Open Space (Sand) 4 m +National Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Health Screening Levels (HSL) D for Vapour Intrusion - Commercial/Industrial (sand) 0 m to <1 mNational Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Health Screening Levels (HSL)D for Vapour Intrusion - Commercial/Industrial (sand) 1 m to <2 mNational Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Health Screening Levels (HSL) D for Vapour Intrusion - Commercial/Industrial (sand) 2 m to <4 mNational Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Health Screening Levels (HSL) D for Vapour Intrusion - Commercial/Industrial (sand) 4 m +National Environmental Protection Council (NEPC) 2013 Amendment of the National Environmental Protection Measure (NEPM) 1999. Soil Ecological Investigation Levels (EIL) - Urban Residential and Open Space

EnvironmentHuman Health



APPENDIX 6: SAMPLING ANALYSIS QUALITY PLAN

REFERENCE NO. APP 6 - SAQP V2 HIBBS & ASSOCIATES PTY LTD © 2019 SAMPLING ANALYSIS QUALITY PLAN PAGE: 1 OF 10.

1.0 INTRODUCTION

A Contamination and Asbestos Management Plan (CAMP) has been developed for the Patons Lane Resource Recovery Centre. The proposed facility is located at 123-179 Patons Lane, Orchard Hills, NSW referred to as Lot 40 DP738126 (the ‘Project’). The Project area is approximately 60 hectares.

The CAMP has been prepared to address the present and potential Construction and Demolition (C&D) Waste associated with the existing perimeter bund walls at the Project.

This Sampling, Analytical and Quality Plan (SAQP) defines the works to be carried out at the Project and presents the quality assurance and quality control (QA/QC) details to be employed during the perimeter bund sampling works. The SAQP covers the following aspects of the works:

• Data quality objectives (DQOs).

• Investigation criteria.

• Investigation methodology.

• Field QA/QC.

• Analytical QA/QC.

• Data validation.

The SAQP has been developed to document the steps required to complete field sampling to manage the disturbance of material located in the perimeter site bunds.

The field sampling programme should be undertaken in accordance with Section 10 of the CAMP.


2.0 DATA QUALITY OBJECTIVES All sampling at the Project should be undertaken in general accordance with the National Environmental Protection (Assessment of Site Contamination) Measure 1999 (amended April 2013).

As stated in Appendix B of Schedule B Guidelines on Site Characterisation (NEPC 1999, amended 2013), the Data Quality Objectives (DQO) process is used to “define the type, quantity, and quality of data needed to support decisions relating to the environmental condition of a site”. The seven-step DQO process that was adopted for this investigation is outlined in Table 1.

Table 1: Data Quality Objectives

DQO Process Details of Process

1. State the Problem

It is known that the former owner of the Project illegally imported a range of C&D materials and incorporated those materials within sections of the existing bund walls (5m to 19m high) around the perimeter of the Project. The Proponent at that time (Dellara Pty Ltd) commissioned Douglas Partners Pty Ltd (DP) to undertake investigation works to characterise the materials within the existing perimeter bund walls.

A Contamination and Asbestos Management Plan (CAMP) has been prepared to address the present and potential Construction and Demolition (C&D) Waste associated with the existing bund walls at the Project. Section 10 of the CAMP defines a programme of bund wall material characterisation and validation.

2. Identify the Goals of the Investigation

The principal study questions that arise from Step 1 are: • Has the material in the bund walls been managed

in accordance with the CAMP?




3. Identify the Information Inputs

The primary inputs to assessing the presence of contamination in soil will be as follows:

• Relevant background data and any relevant data obtained from previous investigations. Based on the previous investigations summarised in Section 5 of the CAMP asbestos is the only material of concern identified to date.

• Visual inspection of stockpiles generated during the bund re-profiling works.

• Visual surface inspection of the completed bund surfaces to determine if visual asbestos containing material (ACM) if present.

• Asbestos soil analysis.

• Chemical assessment for any material to be disposed off-site.

• Chemical assessment of any unexpected contamination finds.

4. Define the Study Boundaries

All works involving disturbance of the perimeter bund walls or management of the materials removed from the perimeter bund walls are referred to herein as the Works.

5. Develop an Analytical Approach

The soil analytical data generated shall be compared with the adopted assessment guidelines (CAMP, Section 7) and against background concentrations, where available and relevant.

Asbestos in soil is non-homogenous therefore duplicate QA/QC samples for asbestos content provides no useful information and can be misleading (i.e. a fragment or fibre identified in one sample but not in the duplicate). Consequently duplicate samples will not be collected for asbestos sampling.




6. Specify Limits on Decision Errors

Assessment of the suitability of new data for the purposes of environmental assessment will be conducted through application of data quality indicators (DQIs), namely precision, accuracy representativeness, completeness, and comparability (PARCC) parameters. Specific limits for this project will be in accordance with the appropriate guidance made or endorsed by the NSW EPA, appropriate indicators of data quality, and standard procedures for field sampling and handling. The step also examines the certainty of conclusive statements based on the available site data collected. This should include the following points to quantify tolerable limits:

• A decision can be made based on a probability that 95% of the data will satisfy the given criteria. This follows the guidance given in NSW, EPA (1994 & 1995) guidelines for comparing 95% Upper Confidence Limits (UCL) to the relevant site criteria for a specific population of samples. Therefore a limit on the decision error will be 5% that a conclusive statement may be incorrect.

7. Optimise the Design

The sampling locations will be determined using both a systematic and targeted approach. Based on the large volume of material present in the bund walls the Environmental Consultant shall be provided with a schedule of the proposed earthworks on an on-going basis. Based on the programme the Environmental Consultant will determine whether in-situ sampling or a process of temporary stockpiling will be the most optimal approach.

As the project progresses, statistical assessment of the data will be undertaken and sampling frequencies will be reviewed on an on-going basis.


3.0 FIELD QUALITY PROCEDURES

3.1 General Sampling Methodology Sampling will primarily be undertaken using the on-site excavator equipment.

Samples should be collected as grab samples directly from the centre of the excavator bucket using a shovel. Nitrile gloves should be worn during sampling and changed between each sample.

Soil should be described in accordance with the Unified Soil Classification System (USCS), with soil type descriptive properties (colour, particle size, moisture content, sorting), as well as discoloration, staining, odours and other indications (if any) being noted. The information should be recorded on field logs completed for each location.

All samples containers should be clearly labelled with information such as sample number, sample location, depth, date collected, and sampler’s identification. After filling, sample containers should be transferred to a chilled esky for sample preservation prior to and during shipment to the testing laboratory.

3.2 Field Quality Control Samples

With materials such as soils, asbestos contamination occurs in discrete/isolated pieces or individual fibrils and is not homogeneously distributed throughout the sample. Additionally asbestos contamination is not dispersed through soil matrices in the same manner as chemical contaminants (i.e. spread by the movement of ground water following pathways of permeability).

During the analytical process for the detection of asbestos in bulk samples, suspected asbestos fibres identified during the initial stereo microscope phase of analysis are extracted and mounted for analysis by polarised light microscopy. After fibres have been removed from the sample and mounted for analysis, they cannot be returned to the sample or reanalysed. Thus, no two soil samples are alike with respect to asbestos content and fibres identified and removed from a sample cannot be analysed twice.

The objective of the QA/QC programme is to ensure that the sample data on which the conclusions are based is reliable. However, for reasons related to the analysis of asbestos in non-homogenous samples stated above, the analysis of split and duplicate QA/QC samples for asbestos content provides no useful information and can be misleading (i.e. a fragment or fibre identified in one sample but not in the split or duplicate). Consequently, split samples and duplicate samples will not be collected for asbestos sampling.

Where soil samples are to be submitted for chemical analysis quality control samples should be collected as outlined below:

• Intra-laboratory / Inter-laboratory duplicate samples will be collected by splitting the nominated sample into the primary and duplicate sample containers. In accordance with the amended NEPM (NEPM, 2013) both intra- and inter-laboratory samples will be collected at a minimum rate of 1 in 20 primary samples.


• Trip blank samples, comprising of laboratory prepared blank soil will be included in the analytical suite for any batch of samples containing three (3) or more primary soil samples.

• Rinsate blanks will be collected by running distilled water over the selected item and decanting directly into the sample bottle. One rinsate blank will be collected per day of sampling for any batch of samples containing three (3) or more primary soil samples.

3.3 General Field Documentation

Field data and observations should be recorded on field data sheets or in field logbooks. Field logbooks and field data sheets should be prepared in blue or black permanent ink. Errant entries in field logbooks and on field data sheets will be marked with a single slash and initialled. All field data and observations should be recorded daily. Items that should be recorded will include:

• Bund/Stockpile tracking reference.

• Lithological information gathered during bund/stockpile sampling.

• Sample names, locations, types, and chain of custody (COC) information for all samples.

• Field measurements.

• Equipment calibration documentation.

3.4 Sample Labelling

Each sample container should be clearly labelled with the following information:

• Job number

• Sampling date

• Unique sample number

• Sample point number/designation

3.5 Chain of Custody Documentation

A COC record should be utilised by field personnel to document possession of samples collected for chemical analysis. The COC record must include, but is not limited to, the following information:

• Project name and number

• Name(s) of sampler(s)

• Sample type, identification number and location

• Date and time of collection

• Number, type and size of containers


• Required analyses

Copies of the chain of custody documents should be reproduced in the validation report.

3.6 Sample Storage and Transportation

Samples should be transported to the laboratories under chain of custody documentation. Prior to transportation, the eskies should be security-sealed with plastic tape.

3.7 Calibration of Field Equipment

Equipment used to perform testing or data recording should be calibrated prior to use. The equipment should be calibrated using manufacturers calibration standards and reagents prior to use each day. Calibration checks and adjustments, if necessary, should be performed both before equipment goes into the field and during the field operation during the day.

3.8 Methodology for Asbestos Sampling

Individual samples (minimum of 10L) should be collected for asbestos analysis and manually screened onsite through a 7mm sieve. The material retained on the 7mm sieve should be visually examined for evidence of asbestos containing material (ACM) and/or suspect material. If ACM or suspect material is identified, it should be retained for laboratory analysis. A bulk 500 gram wetted sample of the <7mm fraction will be collected for further laboratory processing and analysis.

3.9 Additional Requirements for Chemical Analysis

On-site screening of samples for volatile organic compounds (VOCs) should be undertaken in the field using a portable photo-ionisation detector PID). The PID should be calibrated at least once daily (at the start of each sampling day) with a known concentration of isobutylene. Calibration records should be kept on file and be available on request.

Soil samples should be placed into laboratory supplied glass jars as soon as practicable after collection. The jar size will be sufficient to meet the laboratory requirements for the requested analysis. All samples containers should be filled completely using a method such that the loss of volatile components is minimised.

Once each sample is collected, it should immediately be placed into an ice filled esky. Samples should be kept secure and chilled in ice filled eskies during the field program and subsequent transportation to the laboratory.


4.0 LABORATORY ANALYSIS PROGRAM

4.1 General

All primary and duplicate samples are to be submitted to laboratories who are NATA-accredited for the analysis performed.

An independent assessment of the laboratory QA procedures and performance should be conducted which includes a review of the following:

• Method Blanks.

• Laboratory control samples.

• Matrix Spike and Matrix Spike Duplicates.

• Laboratory Duplicates.

• Surrogates.

4.2 Sampling Handling, Preservation & Storage

This section outlines the general procedures necessary for sample custody that are to be performed by the laboratory. It is understood that in addition to the sample custody and management procedures described, the laboratory will act in full accordance with the terms of its NATA Registration for Asbestos and Chemical Testing.

The selection of the appropriate sample containers, preservation procedures, sample storage requirements, and holding times will be in accordance with those recommended by the amended NEPM (NEPM, 2013). Samples and associated QA samples, will be transported to the laboratory within the specified holding times. The laboratory will be notified to be prepared to receive a shipment of samples. Samples will be packed in bubble wrap or equivalent to minimise the potential for sample breakage.

4.2.1 Laboratory Receipt of Samples

Field samples for this project will be delivered to the laboratory in containers and preservatives in accordance with laboratory procedures. Sample containers used for the collection of field samples are, wherever possible, to be supplied by the relevant analytical laboratory, pre-cleaned and inspected. A Chain of Custody (COC) record will accompany each delivery of samples.

The following items are checked and performed by the laboratory upon receipt of samples with the COC:

• The signature on the external custody seal matches one of the sampler(s) signature(s) on the internal COC.

• An examination by the laboratory is made to assess if samples have been maintained at the appropriate temperature during shipment.

• The sample containers within the esky are intact.


• The identification on the sample containers correspond to the entries on the COC.

• The number of sample containers received is equal to the number of samples listed on the COC.

• If sample custody is valid, the samples are logged in by the laboratory using standard operating procedures.

• A copy of the COC is delivered to the Project Manager within one working day.

Should COC discrepancies exist, appropriate notes (signed and dated) will be made on the COC with the Project Manager notified by the laboratory. In the event that the laboratory Sample Custodian judges the sample custody (or part thereof) to be invalid (e.g. samples arrive damaged or custody seals are broken), the Project Manager will be advised as soon as possible and the samples will not be analysed until authorised by the Project Manager.

4.2.2 Pre-analysis Storage

After the Sample Custodian has logged in the samples, they will be placed in temporary refrigerated storage, and maintained at a temperature of 4oC or less until analyses are performed. Sample analyses are scheduled based on project needs and are consistent with relevant analyte holding times.

4.2.3 Post-analysis Storage

After analysis, the samples will be stored by the laboratory for a period of not less than three months. The samples will remain refrigerated, where storage room permits.

4.3 Analytical Quality Assurance / Quality Control

To ensure that data quality objectives are met, specific mechanisms for checking the accuracy and precision of analytical data are in place. The following laboratory and field QA check samples are analysed.

4.3.1 Blanks

Blanks are contaminant free samples designed to monitor the introduction of artefacts into a process. Reagent blanks or method blanks are analysed to assess the level of contamination which exists in the analytical system and which might lead to the reporting of elevated concentrations or false positive data. A reagent/method blank consists of reagents specific to the method that are carried through clean-up and analysis.

4.3.2 Laboratory Duplicates

Laboratory Duplicates - are samples prepared by dividing a field sample into two or more aliquots, then analysing separately. Hence the samples are considered to be two replicates. Replicate samples should ideally be representative of the originating sample, but in many cases this is not practical due to the nature of the sample; hence the analysis


of replicate samples provide an indication of the effect of sample matrix variability on precision, in addition to assessing analytical precision.

This assessment is conducted by calculating the relative percent difference (RPD) between original and duplicate results.

4.3.3 Laboratory Control Samples

Laboratory Control Samples (or Quality Control Check Samples) are samples prepared within the laboratory by spiking an aliquot of an appropriate clean matrix reagent with known concentrations of specific analytes. The check sample is then analysed and the results are used to assess the laboratory performance on sample preparation and the analysis procedure.

Laboratory control sample results are evaluated in terms of accuracy by calculating a percent recovery (%R) between the observed and spiked concentrations:

All calculated %R and RPD values should be within acceptance limits established for control samples by the laboratory and/or the analytical method. In the event that control limits are exceeded, professional judgement is used to assess the extent to which such results may affect the overall usability of field sample data.

4.3.4 Matrix Spikes

Laboratories prepare matrix spike samples by spiking aliquot of a field sample with known concentrations of specific target analytes. The matrix spike (MS) samples are then independently analysed and the results are used to assess the effects of the sample matrix on the accuracy and precision of analyses. MS analyses should be conducted at a minimum frequency of one per analytical batch (20 samples).

Like laboratory control sample analyses, matrix spike sample accuracy is evaluated in terms of a percent recovery between the observed and expected spiked compound concentrations; however, since the field sample may contain concentrations of the spiked analyte prior to spiking, the field sample result must be subtracted from the observed concentration of the spiked analyte obtained by MS analysis:

All calculated %R values should be within acceptance limits established for MS samples by the laboratory and/or US EPA data validation guidance documents. If reported %R values are not within control limits, professional judgement is used to assess the extent to which such results may affect the overall usability of field sample data. No action is typically taken on the basis of MS data alone.

Surrogates - are organic compounds which are similar to analytes of interest in chemical composition, extraction, and chromatography, but which are not normally found in field samples. These compounds are spiked into all sample aliquots prior to preparation and analysis. Percent recoveries are calculated for each surrogate, providing an indication of analytical accuracy including potential matrix effects.



APPENDIX 7: BUND LAYOUT STAGE 1

CH 0

CH 200CH 400

CH 500CH 600

CH 700

CH 800

CH 900

CH 1000

CH 1100

CH 0CH 100

CH 200

CH 300

CH 400

CH 500

CH 700

CH 800

CH 100

CH 300

CH 1200

CH 600

CH 0

CH 100

CH 200

CH 300

NORTHERN BUNDREFER SK003 - SK005

NORTHERN BUNDREFER SK003 - SK005

SOUTHERN BUNDREFER SK006 - SK008

SOUTHERN BUNDREFER SK006 - SK008

RRA BUNDREFER SK009

datefor A1

rev no.job no.scale

approved (PD)

Conditions of Use: This document may only be used by GHD's client (and any otherperson who GHD has agreed can use this document) for the purpose for which it wasprepared and must not be used by any other person or for any other purpose.

rev description app'd date

SK

Level 15, 133 Castlereagh Street, Sydney NSW 2000 AustraliaT 61 2 9239 7100 F 61 2 9239 7199E [email protected] W www.ghd.com

Plot Date: Cad File No:11 October 2016 - 4:23 PM N:\AU\Sydney\Projects\21\25736\CADD\Drawings\21-25736-SK002.dwgPlotted by: Alison Horlyck

SRC PROPERTIES PTY LTDPATONS LANE RRCREVISED PERIMETER BUNDS

002C21-25736

PRELIMINARY

1:2000OCT 2016

A INITIAL ISSUE AD 14.09.16

C REVISED AD 10.10.16

N LEGEND

EXISTING CONTOURS (1 m INCREMENT)

NOTES1. BASED ON SURVEY PROVIDED BY MATTHEW FREEBURN

LAND, ENGINEERING & MINING SURVEYORS, DATEDAUGUST 2007 AND SEPTEMBER 2016

2. SUBJECT TO CHANGE BASED ON DETAILED DESIGNWORKS

PERIMETER BUNDS (GHD)

LIMIT OF EXTRACTION (FMPPR)

PROPERTY BOUNDARY

PROPOSED EXTENT OF LANDFILLING

CONTINGENCY STOCKPILE AREA (GHD)

RRA PLATFORM (FMPPR)

0

SCALE 1:2000 AT ORIGINAL SIZE

4020 80 100m60



APPENDIX 8: FINAL DESIGN SURFACE

35

35

35

35

35

35

40

40

40

45

45

45

45

50

50

50

55

55

55

55

50

50

20

20

25

25

30

30

30

30

3030

3030

30

30

30

30

30

30

3030

30

30

30

30

30

3030

30

35

35

35

35

35 35

35

35

3535

35

35

35

35

3535

35

35

35

35

35

35

35

35

3535

35

35

40

40

40

40

40

40

40

40

45

45

45

45

30

35

35

35

40

40

40

40

404040

40

4045

45

45

45

45

45

45

4545

45

4545 45

45

5050

50

50

50

5050

50

5050

50

5050

50

50

50

50

5555

55

55

55

5555

5540

45

4545

45

50

5050

50

40

50

50

50

55

55

55

55

50

55

55

55

5050

50

50

50

5555

55

50

50

5050

55

55

5555

45

45

45

50

50

50

50

50

ASK021

BSK021

CSK022

DSK022

ESK023

EXTENT OF TRANSMISSION LINE EASMENT

30m PYLON EXCLUSION ZONE



datefor A1

rev no.job no.scale

approved (PD)



SK


Plot Date: Cad File No:11 October 2016 - 4:26 PM N:\AU\Sydney\Projects\21\25736\CADD\Drawings\21-25736-SK020.dwgPlotted by: Alison Horlyck

SRC PROPERTIES PTY LTDPATONS LANE RRCREVISED DESIGN SURFACE

020A21-25736

PRELIMINARY

1:2000SEP 2016


N LEGEND

DESIGN CONTOURS (1 m INCREMENT)

NOTES1. BASED ON SURVEY PROVIDED BY MATTHEW

FREEBURN LAND, ENGINEERING & MININGSURVEYORS, DATED AUGUST 2007 AND SEPTEMBER2016

2. SUBJECT TO CHANGE BASED ON DETAILED DESIGNWORKS

PERIMETER BUNDS (GHD)

LIMIT OF EXTRACTION (FMPPR)

PROPERTY BOUNDARY

PROPOSED EXTENT OF LANDFILLING

CONTINGENCY STOCKPILE AREA (GHD)

RRA PLATFORM (FMPPR)

0


4020 80 100m60

SECTIONASK020 2000SCALE 1 :

SECTIONBSK020 2000SCALE 1 :

032

.632

.632

.39

2035

.6335

.6334

.47

4036

.9536

.9535

.45

6037

.6437

.6436

.32

8037

.5937

.5937

.06

100

37.6

37.6

37.9

120

39.08

45.93

44.46

140

34.4

5346

.28

160

33.83

46.35

47.23

180

32.79

40.25

48.13

200

26.6

32.35

48.79

220

20.16

24.27

49.01

240

20.16

1849

.1

260

20.16

1849

.02

280

23.15

24.09

48.93

300

23.74

27.83

49.27

320

23.55

28.04

49.67

340

28.24

28.3

49.97

360

43.95

28.5

50.02

380

51.37

28.96

49.78

400

52.25

35.67

49.21

420

54.06

45.83

48.65

440

60.07

50.33

48.17

460

63.74

57.25

48

480

53.46

53.46

48.37

498.8

649

.3649

.3649

.06

CHAINAGE

EXISTING SURFACE LEVEL

DESIGN SURFACE LEVEL

FINAL LANDFORM

DATUM RL. -103.0 0

39.91

39.91

39.88

2042

.541

.3141

.41

4046

.1245

.8442

.67

6048

.2653

43.65

8041

.3644

.6144

.66

100

40.38

40.67

45.66

120

31.16

32.69

46.65

140

30.88

30.17

47.63

160

29.62

29.94

48.62

180

28.89

29.72

49.62

200

28.62

29.5

50.62

220

28.58

29.28

51.61

240

28.75

29.22

52.51

260

30.25

29.44

53.39

280

31.62

29.66

54.19

300

40.13

29.88

54.55

320

44.14

30.08

54.79

340

44.88

30.3

54.9

360

44.61

30.52

54.98

380

45.14

32.49

55.09

400

46.01

33.33

55.2

420

45.92

34.43

55.16

440

46.09

44.8

54.98

460

46.5

49.24

54.72

480

47.15

56.41

54.44

500

47.77

47.68

54.06

520

48.38

47.8

53.51

540

50.09

47.9

53.16

560

51.79

4853

.2

580

52.75

48.1

53.23

600

53.03

48.2

53.27

620

49.59

48.3

53.74

640

47.8

48.4

54.2

660

49.6

48.5

54.53

680

51.57

48.6

54.87

700

53.19

48.7

55.21

720

50.69

48.8

55.55

740

49.75

48.9

55.9

760

50.02

51.50

56

780

61.43

56.7

56

800

64.27

57.29

56

820

64.69

57.93

56

840

57.21

57.21

5684

8.86

57.46

57.46

56

CHAINAGE



FINAL LANDFORM

DATUM RL. -92.0

FMPPR EXTENT OF EXTRACTION




CLAY / SHALE INTERFACE

NORTHWEST BUND

CELL 1

CELL 1 SUMP TOP OF WASTECLAY / SHALE INTERFACESOUTHERN BUND

FINAL LANDFORM


NORTHWEST BUND

CELL 1

TOP OF WASTECLAY / SHALE INTERFACE

NORTHERN RRA BUND

FINAL LANDFORM

RRA PLATFORM

SOUTHERN RRA BUND

INDICATIVE TEMPORARY EXCAVATION BATTER

datefor A1

rev no.job no.scale

approved (PD)



SK


Plot Date: Cad File No:11 October 2016 - 3:28 PM N:\AU\Sydney\Projects\21\25736\CADD\Drawings\21-25736-SK021-23.dwgPlotted by: Alison Horlyck

SRC PROPERTIES PTY LTDPATONS LANE RRCREVISED DESIGN SURFACELONG SECTIONS

021A21-25736

PRELIMINARY

1:2000SEP 2016


N

0


4020 80 100m60

SECTIONESK020 2000SCALE 1 :

042

.1342

.1342

.1

2044

.6244

.6243

.03

4036

.0436

.1645

.63

6034

.7328

.7348

.8

8035

.2228

.0850

.22

100

34.16

28.65

50.67

120

32.82

29.27

51.12

140

34.93

29.88

51.57

160

35.15

30.03

52.02

180

35.63

29.43

52.47

200

35.73

29.57

52.92

220

37.18

30.14

53.37

240

39.34

30.64

53.82

260

40.7

31.22

54.26

280

44.34

30.68

54.7

300

44.77

30.48

55.14

320

44.95

33.23

55.58

340

45.4

31.61

56.01

360

45.96

31.45

56.29

380

47.01

31.24

56.51

400

46.84

31.11

56.63

420

46.91

30.94

56.62

440

47.13

30.77

56.42

460

48.9

30.6

56.17

480

50.41

30.44

55.95

500

51.14

30.27

55.52

520

51.48

30.1

55.08

540

51.78

29.94

54.64

560

52.23

29.77

54.2

580

52.88

29.6

53.77

600

54.39

29.44

53.33

620

52.01

29.27

52.89

640

47.95

29.09

52.45

660

47.88

28.91

52.01

680

47.74

36.04

51.54

700

47.78

46.37

51.08

720

54.6

50.82

50.61

740

55.98

56.65

50.15

760

51.22

51.3

48.09

780

47.26

47.38

47.38

790.7

47.18

47.18

47.08

CHAINAGE



FINAL LANDFORM

DATUM RL. -92.0

FMPPR EXTENT OF EXTRACTION FMPPR EXTENT OF EXTRACTION

CELL 1


FINAL LANDFORM

CELL 3

NORTHEAST BUNDINDICATIVE TEMPORARY EXCAVATION BATTER


datefor A1

rev no.job no.scale

approved (PD)



SK


Plot Date: Cad File No:11 October 2016 - 11:41 AM N:\AU\Sydney\Projects\21\25736\CADD\Drawings\21-25736-SK021-23.dwgPlotted by: Alison Horlyck


023A21-25736

PRELIMINARY

1:2000SEP 2016


N

0


4020 80 100m60

SECTIONCSK020 2000SCALE 1 :

SECTIONDSK020 2000SCALE 1 :

041

.0641

.0641

.25

2041

.6441

.6442

.27

4045

.9845

.1143

.2

6046

.8551

.0544

.14

8043

.1448

.5945

.1

100

44.02

43.79

46.08

120

44.19

36.29

47

140

45.09

30.18

47.94

160

44.41

30.77

48.89

180

44.76

31.37

49.83

200

49.69

31.97

50.8

220

50.59

32.31

51.78

240

45.4

31.71

52.58

260

45.68

31.7

53.31

280

46.05

32.3

53.63

300

46.53

32.9

53.88

320

54.49

34.98

53.94

340

54.67

29.94

53.96

360

4829

.3653

.96

380

48.86

29.51

53.86

400

49.34

29.98

53.6

420

54.86

30.41

53.29

440

55.04

30.24

53.02

460

49.28

30.82

52.62

480

49.62

31.4

52.14

500

50.05

31.21

51.58

520

50.14

30.6

50.91

540

50.07

36.27

50.36

560

49.86

46.63

49.92

580

49.58

49.58

49.53

600

48.71

48.71

49.13

620

48.16

48.16

48.82

640

47.97

47.97

48.62

660

47.1

47.1

48.72

680

47.1

47.1

48.8

700

47.1

47.1

48.98

720

47.1

47.1

49.12

740

47.1

47.1

49.04

760

47.04

47.04

48.95

780

47.1

47.1

48.85

800

47.1

47.1

48.67

820

47.1

47.1

48.16

840

47.16

47.16

47.61

848.8

647

.3247

.3247

.76

CHAINAGE



FINAL LANDFORM

DATUM RL. -91.0 0

38.68

38.68

38.76

2042

.7942

.7939

.92

4033

.0233

.0243

.44

6020

.1618

47.41

8020

.1618

50

100

20.16

1850

.38

120

23.43

18.29

50.79

140

25.13

26.7

51.19

160

27.03

28.74

51.58

180

27.22

28.33

51.97

200

27.62

28.61

52.15

220

28.46

28.83

52.5

240

28.76

29.05

52.62

260

28.93

29.27

52.73

280

28.88

29.49

52.86

300

29.08

29.56

53

320

30.87

30.03

53.12

340

36.81

30.74

53.26

360

44.56

31.59

53.4

380

44.5

29.87

53.53

400

44.5

29.92

53.6

420

46.55

29.98

53.63

440

45.39

30.18

53.56

460

45.03

30.37

53.49

480

45.13

30.56

53.41

500

45.27

30.76

53.26

520

45.33

30.95

53.14

540

45.36

31.15

53.06

560

45.53

31.34

52.9

580

45.6

31.53

52.92

600

45.8

31.73

52.59

620

45.96

31.92

52.34

640

45.93

32.14

52.08

660

45.92

32.4

51.84

680

46.36

40.82

51.41

700

46.41

49.16

50.96

720

53.32

55.82

50.5

740

54.66

53.17

50.05

760

51.1

49.01

47.32

780

45.38

45.38

45.86

790.7

45.3

45.3

45.66

CHAINAGE



FINAL LANDFORM

DATUM RL. -103.0

FMPPR EXTENT OF EXTRACTIONFMPPR EXTENT OF EXTRACTION

FMPPR EXTENT OF EXTRACTIONFMPPR EXTENT OF EXTRACTION

NORTHEAST BUND

CELL 2


FINAL LANDFORM

CELL 3

CELL 1


FINAL LANDFORM

CELL 2

CELL 1 SUMP NORTHEAST BUNDINDICATIVE TEMPORARY EXCAVATION BATTER


INDICATIVE TEMPORARY EXCAVATION BATTER

datefor A1

rev no.job no.scale

approved (PD)



SK


Plot Date: Cad File No:11 October 2016 - 11:41 AM N:\AU\Sydney\Projects\21\25736\CADD\Drawings\21-25736-SK021-23.dwgPlotted by: Alison Horlyck


022A21-25736

PRELIMINARY

1:2000SEP 2016


N

0


4020 80 100m60



APPENDIX 9: UNEXPECTED FINDS PROTOCOL

Suspected asbestos material or other indicators of potential

asbestos contamination.

Is the suspect material friable?

Are there significant quantities of suspected AC fragments?

Stop work, cover material and isolate the area for assessment by

the Occupational Hygienist.

Yes

No

Yes

Soil to be treated as asbestos (Special) waste. Material to be managed in accordance with

Section 10 and 11.Fragments are to be removed and placed in a labelled asbestos waste bag to be disposal of as asbestos

waste.

No

Soil to be managed as general solid waste. (Note 1)

UNEXPECTED FINDS PROTOCOLASBESTOS FLOW CHART

Update Asbestos Register

Characterise and record extent of impacts

Investigate surrounding area. Is contamination localised?

Yes

No

Note 1 – If AC fragments are observed in a stream of material proposed to be sent off site as ENM the measures described in the NSW EPA (July 2014)3 “Draft Protocol for managing asbestos during resource recovery of construction and demolition waste” should be applied.

Suspected contamination (odours, discoloration, buried drums or other

indicators of potential contamination).

Testing to be conducted by an Environmental Consultant. Is the

material of concern?

Is the contaminated material localised?

Proceed with bund earthworks.

No

Yes

No

Remediation Plan to be prepared by the Environmental Consultant.

Isolate material, excavate and dispose off-site (subject to waste

classification by the Environmental Consultant).

Proceed with bund earthworks.

UNEXPECTED FINDS PROTOCOLOTHER CONTAMINANTS FLOW CHART

Stop work, cover material and isolate the area for assessment by

the Occupational Hygienist.

Yes

Remediation Plan to be reviewed and endorsed by a NSW EPA

Accredited Site Auditor.



APPENDIX 10: PART B SITE AUDIT STATEMENT

Page 1 of 8 Version: November 2012

NSW Site Auditor Scheme SITE AUDIT STATEMENT

A site audit statement summarises the findings of a site audit. For full details of the site auditor’s findings, evaluations and conclusions, refer to the associated site audit report. This form was approved under the Contaminated Land Management Act 1997 on 31st October 2012. For more information about completing this form, go to Part IV.

PART I: Site audit identification Site audit statement no. 269 ......... ..... ..............

This site audit is a statutory audit/non-statutory audit* within the meaning of the Contaminated Land Management Act 1997. Site auditor details (as accredited under the Contaminated Land Management Act 1997)

Name Dr Ian C Swane ...... . Company Ian Swane & Associates ..... ........

Address PO Box 359, Mortdale NSW .. .................. . .. .............. Postcode 2223 .. ...

Phone 0418 867 112 ..................... .. Email [email protected] .. ............. .

Site details

Address 123 – 179 Patons Lane, Orchard Hills NSW ................................................... .... ......................................................................................................................... Postcode 2748 ........

Property description (attach a list if several properties are included in the site audit)

Orchard Hills Waste and Resource Management Facility at Lot 40 DP738126 (Figure 1)

Local Government Area Penrith City Council .. ...................................... ... ...... ..

Area of site (e.g. hectares) 60.31 ha .................. Current zoning Zone RU2 – Rural landscape ....

To the best of my knowledge, the site is/is not* the subject of a declaration, order, agreement, proposal or notice under the Contaminated Land Management Act 1997 or the Environmentally Hazardous Chemicals Act 1985. .................................................................................................................................. ..

Site audit commissioned by

Name Lee Smith ................ . Company Patons Lane Resource Recovery Centre .............

Address 123 Patons Lane, Orchard Hills NSW ................................ . ................. ..

.................. Postcode 2748 .. ....

Phone 0417 408 088 ............. .... .. Email [email protected] .................

Name and phone number of contact person (if different from above)

Not applicable ...........................................................................................................................................


Purpose of site audit

� A. To determine land use suitability (please specify intended use[s])

........................................................................................................................................... OR

� B(i) To determine the nature and extent of contamination, and/or

; B(ii) To determine the appropriateness of an investigation/remedial action/management plan*, and/or

� B(iii) To determine if the land can be made suitable for a particular use or uses by implementation of a specified remedial action plan/management plan* (please specify intended use[s])

. ............................................................ . .. ..

Information sources for site audit

Consultancy(ies) which conducted the site investigation(s) and/or remediation

Douglas Partners, Aquaterra Consulting, Hibbs & Associates ...........................................

Title(s) of report(s) reviewed .............. .. ..

1. Douglas Partners (September 2009) “Preliminary In-situ Waste Classification, Orchard Hills Waste and Resource Management Facility”. Document No: 582/04 prepared for Dellara Pty Ltd

2. Aquaterra Consulting (March 2010) “Cell Design and Groundwater Assessment, Orchard Hills Waste and Resource Management Facility”. Report No 582/04

3. Douglas Partners (May 2010) “Report on Asbestos Management Plan, Erskine Park Quarry, Patons Lane Orchard Hills”. Document No: 71102.01 prepared for Dellara Pty Ltd

4. Douglas Partners (19 July 2010) “Factual Letter Report, Supplementary Asbestos Management Assessment, Waste and Resource Management Facility, Orchard Hills”. Document No: 71102.02 prepared for Dellara Pty Ltd

5. GHD (September 2011) “Report for Modifications to Modified Preferred Project, Overview Report”. Document No: 21/20649/173517 prepared for Dellara Pty Ltd

6. Douglas Partners (February 2012a) “Report on Stage 1 – Investigation and Contamination Assessment, Bundwalls at Lot 40, Deposited Plan 738126, Patons Lane Orchard Hills”. Document No: 71102.05 prepared for Dellara Pty Ltd

7. Douglas Partners (February 2012b) “DRAFT Bund Deconstruction Management Plan, Orchard Hills Waste and Resource Management Facility, Patons Lane Orchard Hills”. Document No: 71102.05 prepared for Dellara Pty Ltd

8. Hibbs & Associates (November 2016) “Contamination & Asbestos Management Plan, Stage 1 Works, Orchard Hills Waste & Resource Management Facility”. Document No: S9171 prepared for Patons Lane RRC

Other information reviewed (including previous site audit reports and statements relating to the site) 50. Land and Environment Court of NSW (29 August 2012) “Order for Case Number 10928

of 2010, Annexure A Conditions of Consent, Orchard Hills Waste and Resource Management Facility”

51. RW Corkery & Co & Design Collabrative (April 2010) “Environmental Assessment, Orchard Hills Waste and Resource Management Facility”. Two volumes. Project Application No: MP 09_0074 prepared for Dellara


52. RW Corkery & Co & GHD (September 2011) “Further Modified Preferred Project Report for the Orchard Hills Waste and Resource Management Facility”. Project Application No: MP 09_0074 prepared for Dellara

53. Penrith City Council (March 2015) “Penrith Development Control Plan 2014” 54. Geoff Cunningham Natural Resource Consultants (September 2009) “Flora

Assessment”. Part of Ref [51] 55. Aquila Ecological Surveys (September 2009) “Fauna Assessment”. Part of Ref [51] 56. GSS Environmental (February 2010) “Surface Water Assessment”. Part of Ref [51] 57. PAEHolmes (February 2010) “Air Quality Assessment”. Part of Ref [51]

Site audit report

Title Site Audit Report, Site Audit 269 by Dr Ian Swane, Review of Contamination & Asbestos Management Plan for Stage 1 Works at Orchard Hills Waste & Resource Management Facility, Orchard Hills NSW 2748 ............................................................................

Report no. 269 . ......... .. Date 23 December 2016 ............. ..........

PART II: Auditor’s findings Please complete either Section A or Section B, not both. (Strike out the irrelevant section.) Use Section A where site investigation and/or remediation has been completed and a conclusion can be drawn on the suitability of land use(s). Use Section B where the audit is to determine the nature and extent of contamination and/or the appropriateness of an investigation or remedial action or management plan and/or whether the site can be made suitable for a specified land use or uses subject to the successful implementation of a remedial action or management plan.

Section A � I certify that, in my opinion, the site is SUITABLE for the following use(s) (tick all

appropriate uses and strike out those not applicable): � Residential, including substantial vegetable garden and poultry � Residential, including substantial vegetable garden, excluding poultry � Residential with accessible soil, including garden (minimal home-grown produce

contributing less than 10% fruit and vegetable intake), excluding poultry � Day care centre, preschool, primary school � Residential with minimal opportunity for soil access, including units � Secondary school � Park, recreational open space, playing field � Commercial/industrial � Other (please specify) .

subject to compliance with the following environmental management plan (insert title, date and author of plan) in light of contamination remaining on the site:

........................................................................................................ OR

� I certify that, in my opinion, the site is NOT SUITABLE for any use due to the risk of harm from contamination.


Overall comments

........................................................................................................

Section B

Purpose of the plan1 which is the subject of the audit To manage asbestos and other types of contamination present in soil bund walls surrounding the Orchard Hills Waste & Resource Management (OHWRM) Facility. ............................................................................ ..

I certify that, in my opinion: � the nature and extent of the contamination HAS/HAS NOT* been appropriately

determined AND/OR

; the investigation/remedial action plan/management plan* IS/IS NOT* appropriate for the purpose stated above

AND/OR

� the site CAN BE MADE SUITABLE for the following uses (tick all appropriate uses and strike out those not applicable): � Residential, including substantial vegetable garden and poultry � Residential, including substantial vegetable garden, excluding poultry � Residential with accessible soil, including garden (minimal home-grown produce

contributing less than 10% fruit and vegetable intake), excluding poultry � Day care centre, preschool, primary school � Residential with minimal opportunity for soil access, including units � Secondary school � Park, recreational open space, playing field � Commercial/industrial � Other (please specify) .......................................................................

if the site is remediated/managed* in accordance with the following remedial action plan/management plan* (insert title, date and author of plan)

Hibbs & Associates (November 2016) “Contamination & Asbestos Management Plan, Stage 1 Works, Orchard Hills Waste & Resource Management Facility” (Hibbs 2016 Plan - Ref [8])

subject to compliance with the following condition(s):

1. The Hibbs 2016 Plan shall be implemented in accordance with the Land and Environment Court of NSW (29 August 2012) order (L&E 2012 Order) in Ref [50] and all other regulatory requirements. ............................................................

2. No change shall be made to the Hibbs 2016 Plan unless prior written approval is given by the Site Auditor and the Director-General is advised of the change and Site Auditor approval. .......................................................................................

1 For simplicity, this statement uses the term ‘plan’ to refer to both plans and reports.


Overall comments

1. This site audit statement (SAS) should be read in conjunction with the Site Audit Report (SAR). ..................................................................................................................

2. While the Project considered by the L&E 2012 Order involved the construction and operation of the OHWRM Facility, it is assumed for the purpose of this site audit that the Contamination and Asbestos Management (CAM) Plan relates only to the four bund walls that exist at the Site (Figure 2) and require management throughout the life of the Project. ...........................................................................

PART III: Auditor’s declaration I am accredited as a site auditor by the NSW Environment Protection Authority under the

Contaminated Land Management Act 1997 (Accreditation No. 9821).

I certify that:

x I have completed the site audit free of any conflicts of interest as defined in the Contaminated

Land Management Act 1997, and

x with due regard to relevant laws and guidelines, I have examined and am familiar with the

reports and information referred to in Part I of this site audit, and

x on the basis of inquiries I have made of those individuals immediately responsible for making

those reports and obtaining the information referred to in this statement, those reports and that

information are, to the best of my knowledge, true, accurate and complete, and

x this statement is, to the best of my knowledge, true, accurate and complete.

I am aware that there are penalties under the Contaminated Land Management Act 1997 for wilfully

making false or misleading statements.

Signed ............ Date 23 December 2016 ........... ..


PART IV: Explanatory notes To be complete, a site audit statement form must be issued with all four parts. How to complete this form Part I identifies the auditor, the site, the purpose of the audit and the information used by the auditor in making the site audit findings. Part II contains the auditor’s opinion of the suitability of the site for specified uses or of the appropriateness of an investigation, or remedial action or management plan which may enable a particular use. It sets out succinct and definitive information to assist decision-making about the use(s) of the site or a plan or proposal to manage or remediate the site. The auditor is to complete either Section A or Section B of Part II, not both. In Section A the auditor may conclude that the land is suitable for a specified use(s) OR not suitable for any beneficial use due to the risk of harm from contamination. By certifying that the site is suitable, an auditor declares that, at the time of completion of the site audit, no further remediation or investigation of the site was needed to render the site fit for the specified use(s). Any condition imposed should be limited to implementation of an environmental management plan to help ensure the site remains safe for the specified use(s). The plan should be legally enforceable: for example a requirement of a notice under the Contaminated Land Management Act 1997 (CLM Act) or a development consent condition issued by a planning authority. There should also be appropriate public notification of the plan, e.g. on a certificate issued under s.149 of the Environmental Planning and Assessment Act 1979. Auditors may also include comments which are key observations in light of the audit which are not directly related to the suitability of the site for the use(s). These observations may cover aspects relating to the broader environmental context to aid decision-making in relation to the site. In Section B the auditor draws conclusions on the nature and extent of contamination, and/or suitability of plans relating to the investigation, remediation or management of the land, and/or whether land can be made suitable for a particular land use or uses upon implementation of a remedial action or management plan. By certifying that a site can be made suitable for a use or uses if remediated or managed in accordance with a specified plan, the auditor declares that, at the time the audit was completed, there was sufficient information satisfying guidelines made or approved under the CLM Act to determine that implementation of the plan was feasible and would enable the specified use(s) of the site in the future. For a site that can be made suitable, any conditions specified by the auditor in Section B should be limited to minor modifications or additions to the specified plan. However, if the auditor considers that further audits of the site (e.g. to validate remediation) are required, the auditor must note this as a condition in the site audit statement. Auditors may also include comments which are observations in light of the audit which provide a more complete understanding of the environmental context to aid decision-making in relation to the site. In Part III the auditor certifies his/her standing as an accredited auditor under the CLM Act and makes other relevant declarations. Where to send completed forms In addition to furnishing a copy of the audit statement to the person(s) who commissioned the site audit, statutory site audit statements must be sent to: EPA (NSW) Contaminated Sites Section PO Box A290, SYDNEY SOUTH NSW 1232 [email protected] AND the local council for the land which is the subject of the audit.


Figure 1 Project Site Setting (Source: Figure 2.2, Ref [51])

Site


Figure 2 Plan of Bund Walls, Stockpile & Quarry Areas (Source: Appendix 1, Ref [6])

Documents

ATONS LANES RRC · 2019-09-11 · 5.4.1 General Definition 31 5.4.2 Exposure Standards – Asbestos 32 ... (Any building product or material that contains asbestos. AF Asbestos Fines