Re: Site Audit Report for Rose Bay Marina · LPAH Light Molecular Weight PAHs HPAH Heavy Molecular Weight PAHs PCBs Polychlorinated Biphenyls PID Photo-ionisation Detector PQL Practical

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

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

9 July 2008 Our Ref: AS120699

Ned O’Neil Addenbrooke Pty Ltd Unit 401, King Street Wharf 55 Lime Street, Sydney

Dear Ned

Re: Site Audit Report for Rose Bay Marina

I have pleasure in submitting the Site Audit Report and Site Audit Statement for the Rose Bay Marina.

This Site Audit Report and Site Audit Statement report was originally prepared as part of the DA 766/2006/1 for the combined redevelopment of the Rose Bay and Point Piper Marinas. The conclusions of Site Audit Report and the validity of the Site Audit Statement are not affected by minor redesign of the marinas and the submission of separate DAs for each marina.

Yours faithfully ENVIRON Australia Pty Ltd

Michael Hayter EPA Accredited Site Auditor 0001 Enc:

Site Audit Report

Development of Rose Bay and Point Piper Marinas

for

Addenbrooke Pty Ltd

November 2007

Ref: AS120699

Audit MH26

Lvl 3, 100 Pacific Highway, PO Box 560, North Sydney, NSW 2060 Tel: +61.2.9954.8100 Fax: +61.2.9954.8150 ENVIRON Australia Pty Ltd (ACN 095 437 442; ABN 49 095 437 442)

www.environcorp.com

8 November 2007 Our Ref: AS120699

Ned O’Neil Addenbrooke Pty Ltd Unit 401, King Street Wharf, 55 Lime Street, Sydney

Dear Ned,

Re: Site Audit Report – Sediment Investigations for Rose Bay and Point Piper Marina Development

I have pleasure in submitting the Site Audit Report for the Rose Bay and Point Piper Marina Development. The Site Audit Statement, produced in accordance with the NSW Contaminated Land Management Act 1997, follows this letter. The Audit was commissioned by Addenbrooke Pty Ltd. This Site Audit Report is currently required by regulation or legislation and is, therefore, a statutory audit.

The Audit was initiated to comply with a condition of the DA 766/2006/1 - Redevelopment of Rose Bay and Point Piper Marinas, in a request by Woollahra Council issued on 8 June 2007.

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

Yours faithfully, ENVIRON Australia Pty Ltd

Mike Hayter EPA Accredited Site Auditor 0001

Addenbrooke Pty Ltd November 2007 Redevelopment of Rose Bay and Point Piper Marinas Page 1

Z:\Projects\Addenbrooke\SAR_Addenbrooke_Nov07.doc ENVIRON

Table of Contents 1. INTRODUCTION ..............................................................................................................1

2. SITE DETAILS ..................................................................................................................2

2.1. Location ....................................................................................................................2

2.2. Zoning .......................................................................................................................2

2.3. Adjacent Land Uses ..................................................................................................3

2.4. Site Condition ...........................................................................................................3

2.5. Proposed Development .............................................................................................3

3. SITE HISTORY .................................................................................................................5

4. CONTAMINANTS OF CONCERN ..................................................................................7

5. STRATIGRAPHY AND HYDROGEOLOGY..................................................................8

5.1. Stratigraphy...............................................................................................................8

5.2. Hydrodynamics .........................................................................................................8

6. EVALUATION OF QUALITY ASSURANCE AND QUALITY CONTROL.................9

7. ENVIRONMENTAL QUALITY CRITERIA..................................................................14

8. EVALUATION OF SEDIMENT ANALYTICAL RESULTS ........................................15

8.1. Rose Bay Marina Slipway.......................................................................................15

8.2. Point Piper Marina Slipway ....................................................................................16

8.3. Marina Footprints and Background Areas ..............................................................16

8.4. Comparison against Background Levels in Port Jackson .......................................17

9. EVALUATION OF BIOAVAILABILITY ANALYTICAL RESULTS .........................19

10. CONTAMINATION MIGRATION POTENTIAL..........................................................22

11. ASSESSMENT OF RISK.................................................................................................23

12. ONGOING SITE MANAGEMENT ................................................................................25

13. COMPLIANCE WITH REGULATORY GUIDELINES AND DIRECTIONS..............28

14. CONCLUSIONS AND RECOMMENDATIONS ...........................................................29

15. OTHER RELEVANT INFORMATION..........................................................................30



List of Tables and Figures Table 2.1 Site Details .................................................................................................................2

Table 3.1 – Site History Point Piper Marina ..............................................................................5

Table 3.2 – Site History Rose Bay Marina.................................................................................5

Table 4.1 – Contaminants of Concern........................................................................................7

Table 5.1 – Stratigraphy .............................................................................................................8

Table 6.1 – QA/QC – Sampling and Analysis Methodology Assessment .................................9

Table 6.2 – QA/QC – Field and Lab Quality Assurance and Quality Control .........................11

Table 8.1 – Evaluation of Sediment Analytical Results – Rose Bay Slipway (mg/kg)............15

Table 8.3 – Evaluation of Sediment Analytical Results – Marina Footprints and Background Areas (mg/kg)...........................................................................................................................16

Table 8.4 – Summary of Background Concentrations in Port Jackson ....................................17

Table 9.1 – Evaluation of Bioavailability Testing Analytical Results – Summary Table........20

List of Appendices Appendix A Attachments (Site Location and Sample Location Plans)

Appendix B Sediment and Surface Water Guidelines

Appendix C EPA Approved Guidelines and Additional References

Appendix D Analytical Lists and Methods

Appendix E Environmental Management Plans



List of Abbreviations AHD Australian Height Datum ALS Australian Laboratory Services ASET Australian Safer Environment and Technology Pty Ltd. (Laboratory) ANZECC Australian and New Zealand Environment and Conservation Council AVS Acid Volatile Sulfides BaP Benzo(a)pyrene BGL below ground level BTEX Benzene, Toluene, Ethylbenzene & Xylenes (Monocyclic aromatic Hydrocarbons) DP Deposited Plan DQO Data Quality Objectives EPA Environment Protection Authority (NSW) ESA Environmental Site Assessment report ha Hectare ISQG Interim Sediment Quality Guidelines km Kilometres LOR Limit of Reporting m Metres Mercury Inorganic mercury unless noted otherwise Metals As: Arsenic, Cd: Cadmium, Cr: Chromium, Cu: Copper, Fe: Iron, Ni: Nickel, Pb: Lead,

Zn: Zinc, Hg: Mercury, Se: Selenium mg/kg Milligrams per Kilogram mg/L Milligrams per Litre m BGL Metres below ground level µg/L Micrograms per Litre µmol/g Micromoles per gram NATA National Association of Testing Authorities NC Not Calculated ND Not Detected n Number of Samples ng/L Nanograms per Litre NEHF National Environmental Health Forum NEPM National Environment Protection Measure NHMRC National Health and Medical Research Council NODGDM National Ocean Disposal Guidelines for Dredged Material OCPs Organochlorine Pesticides OH&S Occupational Health & Safety OPPs Organophosphorus Pesticides PAHs Polycyclic Aromatic Hydrocarbons (TPAH, total PAHs) LPAH Light Molecular Weight PAHs HPAH Heavy Molecular Weight PAHs PCBs Polychlorinated Biphenyls PID Photo-ionisation Detector PQL Practical Quantitation Limit pH a measure of acidity, hydrogen ion activity QA/QC Quality Assurance/Quality Control RPD Relative Percent Difference SEM Simultaneously Extractable Metals SILs Soil Investigation Levels SVOCs Semi Volatile Organic Compounds TBT Tributyltin TOC Total Organic Carbon TPHs Total Petroleum Hydrocarbons UCL Upper Confidence Limit VENM virgin excavated natural material VOCs Volatile Organic Compounds - On tables is "not calculated", "no criteria" or " not applicable"



1. INTRODUCTION

A site contamination audit has been conducted in relation to redevelopment of the Rose Bay Marina (594 New South Head Road, Rose Bay) and the Point Piper Marina (5 Wunulla Street, Point Piper). Under the development, the owner of the marinas (Addenbrooke Pty Ltd) proposes to replace the existing fixed marina berths and commercial swing moorings with modern floating pontoons.

The audit was conducted to provide an independent review by an EPA Accredited Auditor under Section 47 of the NSW Contaminated Land Management Act 1997 (the CLM Act) of:

The nature and extent of contamination;

The suitability and appropriateness of a plan of remediation, long term management plan, a voluntary investigation proposal or a remediation proposal.

The Audit was initiated to comply with a condition of the DA 766/2006/1 - Redevelopment of Rose Bay and Point Piper Marinas, in a request by Woollahra Council issued on 8 June 2007. Consequently the audit is a Statutory Audit as defined under the CLM Act.

Details of the audit are:

Requested by: Ned O’Neil on behalf of Addenbrooke Pty Ltd

Request/Commencement Date: 2 July 2007

Auditor: Mike Hayter

Accreditation No.: 0001

The scope of the audit included review of the following reports:

“Rose Bay Marina – November 2005 Sediment Sampling and Testing”. December 2005, by Patterson Britton and Partners (PBP);

“Rose Bay and Point Piper Marinas – March 2006 Sediment Sampling and Testing”. March 2006, by PBP (PBP, 2006a);

“Rose Bay and Point Piper Marinas – October 2006 Sediment Sampling and Testing”. October 2006, by PBP (PBP, 2006b); and

“Environmental Impact Statement – Redevelopment of Rose Bay and Point Piper Marinas, submitted to Woollahra Municipal Council on behalf of Addenbrooke Pty Ltd”. November 2006, prepared by JBA Urban Planning Consultants and Patterson Britton Partners Pty Ltd.

Rose Bay Marina draft Environmental Management Plan (EMP), Advanced Marina Management, May 2007;

Point Piper Marina draft Environmental Management Plan (EMP), Advanced Marina Management, May 2007;



Installation of the Rose Bay and Point Piper Marinas, Construction Management Plan for Environmental Management, Rose Bay and Point Piper Marinas Pty Ltd, October 2007.

The following correspondence in letter format prepared for the Auditor was also reviewed:

Letter Re: Comments on Rose Bay Sediment Investigations, dated 31 August, 2007; prepared by Greg Britton, Patterson Britton and Partners.

Letter Re: Addenbrooke Pty Ltd – Request for Additional Information, dated 8 June 2007 by Peter Kauter on behalf of Woollahra Municipal Council prepared for the Waverley Woollahra Process Plant Joint Committee.

A site inspection was performed by the Auditor on 25 July 2007. Discussions were also held with Ned O’Neil (Addenbrooke) and Greg Britton (PBP) who undertook the investigations.

2. SITE DETAILS

2.1. Location

The focus of investigations has been on marine sediments in the areas occupied by the marinas. As such, the area covered by this audit (the “site”) is defined by and limited to the areas of marine sediments in Rose Bay on the seaward side of the sea wall at Rose Bay and foreshore at Point Piper Marinas that are covered by the existing and proposed marina facilities and berths as indicated in Appendix A, Attachment 2. Site details are summarised as follows:

Table 2.1 Site Details

Detail Rose Bay Marina Point Piper Marina

Street address 594 New South Head Road, Rose Bay 5 Wunulla Street, Point Piper

Identifier Lot 1 DP 1014298 Lot 10 DP1021479

Local Government Woollahra Municipal Council

Owner Addenbrooke Pty Ltd

Marina Area 0.11 ha 0.11 ha

Footprint of Berths 3.5 ha 1.4 ha

2.2. Zoning

The marinas are zoned under the Sydney Regional Environmental Plan (Sydney Harbour Catchment 2005). The seaward area (including sediment) adjacent to each of the marinas is zoned W5 Water Recreation (JBA, 2006).



2.3. Adjacent Land Uses

The marinas are located on the foreshore of Sydney Harbour (Attachment 1). The surrounding area to the south consists of residential housing which is separated from the site by New South Head Road, and in the case of Point Piper, by Rose Bay Park.

The sensitive receptors at the site include the sediments and the surface water of Sydney Harbour. It is noted that there are numerous sources of contaminants to the sediments and waters of Sydney Harbour. Background conditions in Sydney Harbour have been documented (Birch 1996; Irvine and Birch 1998).

2.4. Site Condition

The current site facilities at the marinas consist of:

Marina buildings mounted on timber piles containing offices, restaurants, toilets/changing rooms, chandleries, boat sheds, fuelling facilities, sewage pump out facilities, fuelling facilities and slip ways. The slipway at Rose Bay has not been used for about 10 years and will be removed as part of the development;

Various fixed and floating timber wharves and berths extending into Rose Bay, with attached fuel bowsers and associated pipe work.

At Rose Bay, petrol is stored in a 4,500 L above ground tank mounted under the existing marina building. At Point Piper, petrol is stored in a 5,200 L under ground storage tank which is located to the south of the foreshore and is outside the audit area.

At Rose Bay, the intertidal foreshore is narrow and is separated from the land by a 3 to 4 m high concrete sea wall. At Point Piper, the foreshore is wider and there is no sea wall. The sediments at the site are predominantly sandy. Abundant worm and crustacean burrows were evident on the surface of the sediment. Kelp and bivalve molluscs were present on the pilings at the site.

The sites are high quality commercial marinas which are well maintained. At the time of site inspection there was no evidence of leakage of fuel, fuel slicks on the water, waste materials, drums or odours.

2.5. Proposed Development

The marinas are to be redeveloped by Addenbrooke Pty Ltd. The redevelopment will include:

Removal of the existing fixed berths at Point Piper and Rose Bay marinas and removal of the disused slip way at Rose Bay marina;

Removal of commercial swing moorings;

Installation of floating berths and walkway at both marinas;

Construction of a new hardstand at Rose Bay marina in place of the slip way;



Installation of new electricity substations and upgrade of fuel pumping and sewage pump out facilities at both marinas;

Installation of a new 75,000 L above ground fuel tank at the Rose Bay marina.

There will be no change to the existing marina buildings and no dredging will be required. There will be no change to the existing slipway and fuel storage at Point Piper marina.

There will be a net reduction in boat storage of 50 boats in the bay, 157 swing moorings will be removed, however, the area occupied by foxed berths at the two marinas will increase from 52 to 159 (with 124 at Rose Bay Marina and 35 at Point Piper Marina).



3. SITE HISTORY

PBP (PBP, 2007) provided a site history based on aerial photographs, site photographs and/or Certificates of Title and is summarised in Table 3.1.

Table 3.1 – Site History Point Piper Marina

Date Activity

Prior to June 1914 The earliest record of the marina was from the Maritime Services Board in 1914 and showed a cottage, boat shed, boat jetty and a slip.

1914 to 1932 An extension to both the boatshed and the jetty was undertaken in prior to a survey plan dated 1932.

1934 to 1942 The property was owned by Malcolm Campbell who made further alterations (additions) to the site buildings and structures.

1942 to current PBP reported that the marina had changed ownership a further 6 times between 1942 and the present. The site currently contains a slipway, a boatshed, 23 fixed berths and 100 commercial swing moorings. The slipway is still in use for purposes of boat maintenance and cleaning. The EIS (prepared by JBA and PBP, 2006) indicated that a separate DA approval has been obtained by Addenbrooke for upgrade of the slipway, including the installation of two drains to intercept runoff from the slipway.

Table 3.2 – Site History Rose Bay Marina

Date Activity

1857 to 1871 Early paintings of the site from 1857 and 1871 indicate the presence of a pier or slip at the site.

1882 to 1900 Map references for the Point Piper Estate in 1882 show the presence of the pier. It is understood that the boatshed was constructed between 1893 and 1900.

1900 to 1920’s In 1908 a refreshment room was constructed between the boatshed and the jetty. The Pier restaurant was constructed in the 1920s on the street frontage of the property.

1960’s In the 1961 extensions to the wharf were undertaken. At this time, the site infrastructure is understood to have included a wharf, a boatshed, a shop, a restaurant, a deck and a slipway.

In 1962/3 the existing jetty was demolished. This was replaced with a marina and catwalk and a



Date Activity new jetty. Extensions to the restaurant were undertaken at this time.

1971 By 1971, the activities on the site included boat hire and maintenance, sale of fishing gear and bait, slipway services, restaurant and sale of fuel. The site contained 25 fixed berths and 72 commercial swing moorings.

1974 In 1974, the old marina shed was demolished and replaced with a new construction including new decking, new workshops, new offices, chandlery, restaurant and a small slipway.

Current The site currently contains the facilities associated with the marina shed, 29 fixed berths and 72 commercial moorings. The slipway and workshop at Rose Bay marina have not been used since 2001.

The site history provides an adequate indication of past activities and identifies the primary land use at each of the sites as marina operations. The activities at the marinas with the potential for contamination have included the slipways and associated maintenance of vessels, the workshops and storage of fuels. The primary sources of contamination at both marinas are considered to be the slipways. Secondary source of contamination would include the fuel storage, pumping and distribution facilities, former workshops and moorings. The likely contaminants would include tributyltin (TBT), polycyclic aromatic hydrocarbons (PAHs), petroleum hydrocarbons (TPH) and heavy metals.

Off-site sources of contamination at the site include stormwater drains that discharge to the harbour from the seawall on the eastern and western sides of the site. Contamination associated with these stormwater drains would be expected to include a variety of contaminants derived from the urban catchments including heavy metals, petroleum hydrocarbons and polycyclic aromatic hydrocarbons.

Auditor’s Comments: The information on site history and site activities provides a satisfactory basis for identifying potential sources of contamination and chemicals of concern.



4. CONTAMINANTS OF CONCERN

The contaminants of concern identified by the Auditor are listed in Table 4.1.

Table 4.1 – Contaminants of Concern

Activities Potential Contaminants

Tributyltin

Petroleum hydrocarbons (TPH) and monoclyclic aromatic hydrocarbons (BTEX)

Polycyclic Aromatic Hydrocarbons (PAHs)

Polychlorinated Biphenyls (PCBs)

Fuel storage, boat maintenance and repair

Heavy Metals (copper, mercury and lead)

Additional potential background contaminants derived from urban runoff and atmospheric deposition would include a range of other heavy metals including zinc and nickel, TPH, BTEX, PAHs and Organochlorine (OC) pesticides.

The PBP 2005 sediment investigations included the following analytes:

An extensive suite of heavy metals (Sb, As, Cd, Cr, Cu, PB, Hg, Ni, Ag, Zn, Sn, Mn, Se, Be);

TPH, BTEX, PAHs, PCBs, OC pesticides, TOC and tributyltin.

Following assessment in the November 2005 report, some of these analytes were eliminated as contaminants of concern and were therefore not included in subsequent investigations. The PBP investigations in March and October 2006 focussed on the following critical analytes which are elevated in the marina areas and particularly associated with the marina operations:

Tributlytin, PAHs and PCBs

Heavy metals – copper, mercury and lead

Auditor’s Comments: The Auditor considers that the analytes assessed by PBP were appropriate for the sources of contamination and the chemical of concern at the sites.



5. STRATIGRAPHY AND HYDROGEOLOGY

Following a review of the provided reports, a summary of the sediment stratigraphy and hydrodynamics was compiled as follows.

5.1. Stratigraphy

The stratigraphy of the sediments is summarised in Table 5.1.

Table 5.1 – Stratigraphy

Depth (m) Stratigraphy

0.0 –6.0 SAND and SILTY SAND

This stratum of estuarine deposits consists of alternating bands of sands and silty sands. Colouration varied from grey to brown to orange/brown. Sands were generally fine to medium grained with varying fines content. Shells were present throughout the profile.

6.0 – 9.0 CLAYEY SAND

Sands were generally fine to medium grained and grey to brown in colour. Occasional shell fragments. The depth of this layer varied from 5.5 m to 7.5 m.

> 9.0 SANDSTONE

Sandstone bedrock was not encountered in the investigations undertaken at the site. The EIS (2007) indicated that the piling at the adjacent RMYC encountered sandstone bedrock.

The EIS indicated that the sea bed topography has not changed significantly over the past 35 years. Localised east to west longshore movement of sediment was reported in the EIS, demonstrated by accretion of sediment on the eastern sides of stormwater drains to the immediate east of the marina. Overall Port Jackson estuary is infilling from the action of longshore sediment transport (littoral drift) of sandy sediments. There is net migration of fine fraction sediments from the upper reaches of the estuary.

5.2. Hydrodynamics

The hydrodynamics at the site are important because of its impact upon the erosion and deposition of sediments at the site.

PBP (2007) reported that the dominant wave conditions at the site are locally generated wind waves, with little ocean swell affecting the site. Tidal currents are insufficient to suspend sediments at the site.

PBP (2007) indicated that there is no evidence of erosion on shoreline structures and given the contamination present at depth at the site, this is consistent with net deposition at the site.



6. EVALUATION OF QUALITY ASSURANCE AND QUALITY CONTROL

Three sediment investigations have been undertaken by Patterson Britton and Partners (PBP) for these sites. An initial investigation in November 2005 was undertaken to assess sediment quality at the base of the Rose Bay slipway to support a dredging proposal for installation of a fuel storage tank (since withdrawn). Further investigations were then performed in March 2006 and September 2006. The March 2006 investigation was a ‘pilot’ scale investigation that assessed sediment contamination across the entire footprints of the proposed floating berths at each of the marinas. The September 2006 investigation was undertaken in areas of known contamination to enable bioavailability and elutriate testing required to assess the need for remediation or management of the sediments. The Auditor has assessed the overall quality of the data by review of the information presented in the referenced reports, supplemented by field observations. Sample locations are shown in Attachments 2, 3 and 4.

The Auditor’s assessment follows in Tables 6.1 and 6.2 and includes review of all three investigations.

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

Sampling and Analysis Plan and Sampling Methodology

Auditor Comments

Sampling pattern and locations Investigation locations were spaced to gain coverage of the majority of the site. Samples were taken close to the source of contamination (the slip way) at Rose Bay in the 2005 investigation. Additional samples were taken near the Point Piper slipway and the wider marina footprint in the March and October 2006 investigations.

In the Auditor’s opinion these investigation locations adequately target the main areas of concern. Some samples were collected through the sediment profile, however, the majority of samples targeted surface sediments, which are considered to be of most relevance to the current investigation and proposed development.

Sampling density The sampling density of 7 locations over approximately 120 m2 in the vicinity of the Rose Bay slipway in the November 2005 investigation greatly exceeded the EPA (1995) “Sampling Design Guidelines” density.

Sampling in March 2006 covered the whole of both marina footprints. The density was approximately 20% of the guideline density. This is acceptable as the area is distant from potential sources (slipways and stormwater drains) and it is expected that patterns of contamination will be diffuse. Based on the diffuse nature of the contamination the Auditor considers that the density was consistent with the objectives of the investigation and the site conditions. The September 2006 investigation was targeted toward areas of the highest known contamination for assessment of bioavailability and elutriates testing. This approach is considered satisfactory by the Auditor.

Sample depths Samples were collected and analysed from a range of depths near the slipway (to a maximum of 3.0 m) and surface samples (0.0 m to 0.1 m) were collected across the remainder of the site.




Auditor Comments

In the Auditor’s opinion, these sampling depths were appropriate and adequate to characterise the relevant material types present on site. The surface samples collected target the biologically active zone and also the sediments with the greatest potential for resuspension and migration.

Sample collection method Surface samples in November 2005 were collected using a piston sampler. Deeper samples (>1.0 m) were collected using a drill rig using solid flight augers and an SPT hammer. Sample collection via a SPT split spoon is considered adequate. Samples collected to 1.0 m depth with the piston sampler may have led to some mixing and therefore, depths may be indicative only. This is not considered to be significant as some mixing of sediment in near shore areas would be expected.

Samples were collected in March 2006 using a stainless steel Van Veen grab sampler. Given the sandy nature of the sediments, this is considered acceptable.

Samples were collected in September 2006 by diver using a stainless steel push core. This is considered acceptable.

Decontamination procedures All sampling equipment was cleaned with harbour water and detergent (Decon™ 90) and then rinsed in harbour water prior to sampling and between sampling events to prevent cross contamination.

Sample handling and containers All samples for chemical and physical analysis were placed into prepared and preserved sampling bottles provided by the laboratory and chilled during storage and subsequent transport to the labs.

Samples for bioavailability testing (AVS/SEM, dilute acid extraction and elutriates) were collected in zip-lock plastic bags (double bagged) and filled with zero headspace before being chilled during storage. This is considered acceptable.

Chain of Custody Completed chain of custody forms were provided in the report.

Description of field screening protocols

Field screening for volatiles was not undertaken using a PID as sediments were wet and volatile hydrocarbons were not a contaminant of concern at the site for sediments.

No screening of sediment pH and redox potential was undertaken. In the Auditor’s opinion, the disturbed nature of the samples and the high sand content mean that minimal information would be gained from ex-situ measurement of these parameters. This is therefore considered acceptable.

Sampling logs In the November 2005 report documentation included a sample register including a description of each sample and the borelogs from the drilling undertaken. The logs included the samples collected and description of the lithology. No indications of contamination were reported in the logs.

In the March 2006 and October 2006 reports, sampling logs were




Auditor Comments

not provided. As COCs and tabulated results were provided, the Auditor considers that this is acceptable.

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

Field and Lab QA/QC Auditor Comments

Field quality control samples Field quality control samples including field duplicate (intra-laboratory) were taken at a rate of approximately 1 in 20 samples. However, they were only undertaken for metals and not organics. In the March 2006 investigation, one sample was collected and analysed in triplicate. No inter laboratory analysis was undertaken.

No trip blanks or trip spikes were analysed in November 2005 or September 2006. A Trip Blank was analysed in March 2006. This was not considered to affect the usability of the data since volatile compounds (BTEX and TPH C6-C9) are not considered to be critical contaminants for these investigations.

Wash blanks were not undertaken between sampling locations in any of the three sampling programs. The Auditor considers that the potential for cross contamination is minimal.

Field quality control results The results from all field quality control samples were within appropriate limits.

The field duplicates samples indicated a high degree of precision with RPD values of generally <30% (less than the 50% limit specified in NODGDM (2002)). Individual RPD values varied from 0% to 97% exceeded the accepted criteria for trace metals in the November 2005 investigation.

The triplicate samples indicated that there was a high level of precision with RPD values varying from 4% to 43% (average 15%).

NATA registered laboratory and NATA endorsed methods

A number of laboratories were used during the investigations. These included Advanced Analytical (for most inorganic and trace metal analyses and elutriates) and Ecowise Environmental (for TOC). These laboratories are both NATA Accredited and laboratory certificates from these laboratories were NATA stamped.

Acid Sulfate soil analysis was undertaken at Bio-Track. Bio-Track is not a NATA accredited laboratory. Grain size analyses were undertaken by Vibrosed Analytical. Although Vibrosed Analytical is not a NATA Accredited laboratory, the principal of the company is Dr Ed Frankel, a former Associate Professor at the University of Technology in Sydney with 30 years of experience in sediment analysis.

Analyses for AVS/SEM, dilute acid extraction and porewater were undertaken at CSIRO Centre for Environmental Contaminants Research. This is not a NATA Accredited Laboratory, however, the laboratory has been responsible for deriving the test



Field and Lab QA/QC Auditor Comments methodologies and is recognised as a world leader in this field.

These laboratories are considered to be suitable and reliable.

Analytical methods In-house analytical methods were included in the laboratory test certificates. While, references to the USEPA methods for extraction and analysis were given for the laboratory methods, the exact methods used have not been detailed.

Holding times Review of the COCs and laboratory certificates indicate that the holding times had been met in sampling undertaken in November 2005, March 2006 and September 2006.

Practical Quantitation Limits (PQLs)

PQLs were all less than the threshold criteria for the contaminants of concern with the exception of some organochlorine pesticides in the November 2005 Investigation:

NODGDM (2002) notes that the currently available PQL for these compounds exceeds the ISQG Low value. As there are no identified sources of OCPs from the marinas and any OCPs present would likely be ambient concentrations from diffuse sources no further monitoring or action is required.

Laboratory quality control samples

Laboratory Control Samples were not generally undertaken in the investigations. Certified reference materials were analysed with sediment batches by CSIRO. Matrix spikes and surrogate spikes were undertaken for each analyte suite. Laboratory duplicates were undertaken at a rate of approximately 1 in 10 samples. Laboratory blanks were also undertaken by the laboratory at appropriate frequencies.

Laboratory quality control results

The results from all laboratory quality control samples were within appropriate limits. RPDs for laboratory duplicates were within control limits. Surrogate recoveries were within control limits.

Matrix spike recoveries were generally within control limits. However, some analytes were not detected including mercury (in one matrix spike) and PAHs (in one sample) where the concentrations in the sample were higher than the spike, obscuring the recoveries. The spike concentrations were not available for review. Surrogates were within the accepted limits.

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

PBP did not define DQOs and did not undertake a formal QA/QC data evaluation against the five category areas. They did, however, conclude that the field and laboratory quality assurance for this investigation were acceptable.

Auditor’s Comments:

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

There is a satisfactory degree of confidence that data is comparable for each sampling and analytical event. The same consultant and laboratory were used for each investigation but



the use of different sample collection techniques in each of the three investigations may have introduced some variability. Given that the sediment is relatively homogenous sand, this is considered unlikely to affect the comparability of the data.

The samples were appropriately handled and stored and no artefacts appear to have been introduced in the sampling. The data are therefore considered to be representative.

The generally low RPDs in the duplicate and triplicate samples indicate a satisfactory level of precision. The data are likely to be accurate, with most QAQC within the accepted limits and likely to represent the concentrations in sediment at the site.

In conjunction with field observations, the dataset is sufficiently complete to draw reliable conclusions concerning the need for remediation or management of the sediments. Although there is some uncertainty as to the precise boundaries of the contaminated areas, this is not critical because the sediment management procedures for the marina redevelopment will extend well beyond the immediate areas of contamination associated with the slipways at each of the marinas.



7. ENVIRONMENTAL QUALITY CRITERIA

The identified receptors are the sediments and surface waters of Rose Bay in the lower reaches of Sydney Harbour (Port Jackson). The Auditor has assessed the sediment data against the ANZECC (2000) Australian and New Zealand Guidelines for Fresh and Marine Water Quality Sediment quality guidelines (Section 3.5). ANZECC (2000) provides Interim Sediment Quality Guideline (ISQG)-Low (indicating less than 10% probability of effects) and ISQG-High concentrations (indicating > 50% probability of effects). The criteria apply to ‘slightly to moderately’ and highly disturbed ecosystems.

Where relevant, the Auditor has assessed the porewater and elutriate water data with reference to ANZECC (2000) Australian and New Zealand Guidelines for Fresh and Marine Water Quality for marine waters. Trigger values (TVs) provided are concentrations that, if exceeded, indicate a potential environmental problem and ‘trigger’ further investigation. Low reliability ANZECC (2000) TVs have been used where they exist for the individual PAHs (Appendix B). However, a trigger level for total PAHs in water is not provided within the ANZECC (2000) guidelines. As such, the threshold level of 3µg/L from the EPA (1994) Guidelines for Assessing Service Station Sites has been adopted.

The ANZECC (2000) Australian and New Zealand Guidelines for Fresh and Marine Water Quality provides a decision process allowing for incorporation of background concentrations and consideration of bioavailability into the decision tree. Such measures of bioavailability include AVS/SEM testing, analysis of porewater and dilute acid extractions. These techniques are applicable for trace metals. Sediment quality assessment remains a dynamic area of scientific research. The techniques available for assessing bioavailability of trace metals are relatively new. Techniques for assessing bioavailability of organic contaminants are limited. Porewater investigations of organic contaminants are not currently possible for organic contaminants due to the prohibitively large volumes of porewater required for low detection limit organic analyses.

PBP also reference the National Ocean Disposal Guidelines for Dredged Material (NODGDM) (Department of the Environment and Heritage, 2002). These guidelines provide a framework for the assessment of contaminated sediments to assist in the classification of sediment for the purposes of dredging and disposal. The NODGDM provides guidance on elutriate and bioavailability testing. Although there is no proposal to dredge sediments in this project, elutriate testing, as recommended in NODGDM can provide information on potential partitioning between sediment and water phases.

Additional guidance for assessment of sediment quality is provided in the Handbook for Sediment Quality Assessment (Simpson et al., 2005). This document provides guidance on sediment quality assessment including assessment of bioavailability, toxicity testing and ecological assessment.

PBP (2006b) reference an additional technical document identified as Simpson, S.L. (2006) Copper Effects Thresholds of Saltwater (Estuarine/Marine) Benthic Biota, Report no. ET/IR885R, June 2006, CSIRO Internal Report. This document identifies a water quality guideline of 9.5 µg/L for copper in sediment porewater, higher than the ANZECC/ARMCANZ (2000) 95% Trigger Value of 1.3 µg/L. It is understood that this document and the analysis contained within will support revision of the ANZECC guidelines; however, this document has not been relied upon by the Auditor. Porewater concentrations of copper have also been screened by the Auditor against the existing ANZECC/ARMCANZ (2000) 95% Trigger Value of 1.3 µg/L.



8. EVALUATION OF SEDIMENT ANALYTICAL RESULTS

Across the three investigations, sediment samples were analysed by PBP for trace metals, TPH fractions, BTEX, PCBs, PAHs, OC pesticides and TBT. Results from organic analyses (PCBs, PAHs and TBT) were normalised by PBP to 1% total organic carbon (TOC) in accordance with the ANZECC/ARMCANZ (2000) Interim Sediment Quality Guidelines (ISQG). Concentrations of contaminant in sediment were screened by PBP against the ANZECC/ARMCANZ (2000) ISQG Low and High Values. Concentrations of contaminants presented in the summary table below are generally within the uppermost 10 cm of the sediment profile, in the biologically active zone. Sediment sampling locations are shown as Attachments 1 to 4, Appendix A.

8.1. Rose Bay Marina Slipway

Table 8.1 summarises the data for samples from BH101 to BH103, S201 to S204 and RBA4 to RBA7 collected adjacent to the slipway at Rose Bay Marina. These results would be expected to represent the highest levels of contaminants in the marina area.

Table 8.1 – Evaluation of Sediment Analytical Results – Rose Bay Slipway (mg/kg)

Analyte N Detections Maximum n > ISQG Low

N > ISQG High

Arsenic 17 17 9.6 0 0

Cadmium 17 2 0.36 0 0

Chromium 17 2 8.7 0 0

Copper 20 19 390 6 1

Mercury 20 19 7.8 11 5

Nickel 17 17 3.4 0 0

Lead 20 20 670 5 1

Zinc 17 17 320 1 1

PCBs 6 2 16.4 0 0

Total PAHs 10 10 132 6 2

TPH 2 2 720 -- --

BTEX 2 0 <PQL -- --

TBT (in µgSn/kg) 10 10 1070 4 6

OC Pesticides 2 0 - 0 0 n number of samples - No criteria available/used Concentrations are in mg/kg unless stated otherwise



Auditor’s comments are as follows:

Close to the Rose Bay slipway concentrations of copper, mercury, lead, PAHs and TBT exceeded the ISQG Low and High Values. One individual sample exceeded the ISQG Low value for zinc, however, the 95% UCL for zinc was less than the ISQG Low value and zinc was not assessed further.

Low to moderate concentrations of lower toxicity middle and heavy fraction petroleum hydrocarbons were detected in both of the samples analysed. No ISQG values applicable to sediments are available for petroleum hydrocarbons. Whilst not applicable to sediment toxicity, it is noted that the concentrations detected did not exceed the DECC human health risk based regulatory guidelines (NSW EPA Service Station Guidelines) for sensitive land uses.

Light fraction petroleum hydrocarbons, BTEX compounds and OC pesticides were not detected.

8.2. Point Piper Marina Slipway

One sample PPA1 was taken adjacent to the slipway at the Point Piper Marina. Concentrations of copper, mercury, lead, PAHs and TBT were elevated, although levels were lower than those observed at the Rose Bay slipway. The concentration of TBT (140 µgSn/kg), exceeded the ISQG High of 70 µgSn/kg.

8.3. Marina Footprints and Background Areas

Table 8.3 below summarises sediment data from the footprints of both of the existing marinas (excluding the slipway areas), the proposed marina extensions and background areas.

Table 8.3 – Evaluation of Sediment Analytical Results – Marina Footprints and Background Areas (mg/kg)

Analyte N Detections Maximum n > ISQG Low

N > ISQG High

Copper 18 18 47 0 0

Mercury 18 18 0.99 14 0

Lead 18 18 72 4 0

PCBs 13 0 NA 0 0

Total PAHs 13 13 3.0 0 0

TBT (in µgSn/kg) 18 15 9.6 4 0n number of samples - No criteria available/used Concentrations are in mg/kg unless stated otherwise

Comments are as follows:

Concentrations of metals (Cu, Pb and Hg) and PAHs within the existing and proposed marinas were similar to background concentrations;



Within the footprint of the existing marinas, in the area of proposed expansion and in background samples (OF1-OF3) collected north of the proposed marina footprint, the concentrations of mercury, lead and TBT exceeded the ISQG Low Values.

The concentrations of contaminants within the footprint of the existing marina were generally similar to the background concentrations with the exception of TBT at concentrations marginally exceeding the ISQG Low Value. Concentrations of TBT were marginally greater within the footprint of the existing marina than in the footprint of the proposed marina area or background samples.

8.4. Comparison against Background Levels in Port Jackson

Background levels of sediment contamination in Port Jackson were obtained by the Auditor from a review of available literature to provide a perspective on the sampling results for the marinas. The data are summarised in the Table 8.4 below. The literature reviewed indicated that mean concentrations of copper, lead, PAHs and PCBs in Port Jackson exceeded the ISQG Low Values whilst concentrations collected from the adjacent Rushcutters Bay exceeded the ISQG High Value for copper and lead. The source of the elevated background concentrations of trace metals and PAHs in Port Jackson has been attributed to stormwater contamination and particulate deposition (Birch and Taylor, 2004 and McCready et al., 2000). Stormwater drains are located adjacent to each of the marina sites.

Table 8.4 – Summary of Background Concentrations in Port Jackson1

Analyte N Min Mean Max Rushcutters Bay

Copper 18 9.3 188 1053 630

Lead 18 37.9 364.4 3604 3685

PCBs 13 <PQL 164 1921 --

Total PAHs 13 2.5 20.5 119 44 n number of samples - No criteria available/used * Low Molecular Weight PAHs ** High Molecular Weight PAHs 24 denotes that the concentration exceeds the ISQG Low Value 450 denotes that the concentration exceeds the ISQG High Value

The contaminants Total PAH, copper, mercury and lead were detected at concentrations exceeding sediment quality guidelines across the entire site. The Auditor notes that excluding the slipway areas the concentrations are consistent with background concentrations in other parts of the estuary. Most of the apparent localised elevated concentrations of these contaminants are probably driven by grain size effects or proximity to stormwater outlets.

1 Background sediment data for metals and PCBs was obtained from Birch, G.F. and Taylor, S.E. (2004). Background data for PAHs, was obtained from McCready et al., 2000.



Elevated concentrations of TBT were present within sediments in the immediate vicinity of the slipways at each of the marinas. Elevated concentrations exceeding the ISQG High Value were only reported adjacent to the slipways. Concentrations between the ISQG Low Value and ISQG High Value were reported within the footprint of the existing marinas, whilst concentrations in sediment within the footprint of the proposed marinas were generally less than the ISQG Low Value. The concentrations of TBT represent contamination arising from the historical use of the slipways at each site. Use of TBT has been discontinued since the late 1980’s and therefore, the slipways are no longer sources of TBT contamination.

In the Auditor’s opinion, the sediment analytical results are consistent with the site history and field observations. Excluding the slipway areas, the elevated concentrations of trace metals and PAHs are consistent with background concentrations of these contaminants. The sources of these contaminants are likely to be stormwater discharge to the harbour and particulate deposition. Elevated concentrations of TBT, exceeding ISQG-High values were observed in the vicinity of the slipways at both marinas. The slipways are the most likely sources of the observed TBT contamination.



9. EVALUATION OF BIOAVAILABILITY ANALYTICAL RESULTS

PBP performed additional assessment of bioavailability of trace metals, PAHs and TBT in accordance with ANZECC (2000). Samples from the Rose Bay marina (RBA6/7) and the Point Piper marina (PPA1/2) were selected to represent the most contaminated areas near the slipways and areas where sediments are more likely to be disturbed by vessel movements. Several techniques were used including:

Dilute Acid Extraction (using 1 M cold hydrochloric acid);

AVS/SEM analysis;

Porewater Testing; and

Elutriate Testing.

The Auditor’s comments are provided below:

The dilute acid extraction (with cold 1 M HCl) is a less aggressive extraction than is undertaken for total metals analysis (hot 10 M HNO3) and does not remove metals associated with mineralised phases of the sediment. This extraction is considered to better represent the potentially bioavailable fraction of metals than total metal analysis.

AVS/SEM analysis is undertaken to assess the quantity of acid volatile sulfides present in sediment for binding excess metals. Where AVS is greater than SEM, it indicates that metals are not bioavailable and therefore, the sediment sample is non-toxic. Where AVS is less than SEM, it indicates that metals are available in the sample. However, it does not indicate toxicity. AVS/SEM is predominantly undertaken for Cd, Pb and Zn. The applicability of the analysis for Cu and Ni is uncertain (ANZECC, 2000).

Porewater testing is analysis of the porewater contained within the sediments to determine the presence of compounds within the sediment porewater and therefore, bioavailable. Porewater testing is routinely undertaken for metals. However, due to the prohibitively large volumes of water required for analysis of organic contaminants, porewater analysis for organic contaminants is not possible.

Elutriate testing is commonly undertaken (as recommended in NODGDM, 2002) to assess the partitioning of contaminants from the sediment phase to the water phase during dredging and disposal. No dredging is proposed in the current development application. Although the elutriate methodology may not accurately represent the partitioning of contaminants, it does provide an indication of the potential partitioning of contaminants between sediment and water phases.



Table 9.1 – Evaluation of Bioavailability Testing Analytical Results – Summary Table

Total Concentration

Dilute Acid Extraction* Porewater* Elutriate*

Analyte ISQGLow

ISQGHigh

95%Trigger

mg/kg mg/kg µg/L µg/L

Copper 65 270 1.3 47 – 390 28 – 160 1.0 - 6.4 10 – 37

Mercury 0.15 1.0 0.1 0.77 - 3.2 <0.01 - 0.018 0.028 - 0.067 <0.1

Lead 50 220 4.4 36 – 170 25.5 - 117 0.6 - 4.0 2.2 – 10

Total PAH

4 45 -

<PQL – 131.6 NA NA <1

TBT 5 70 0.006 9.6 - 928.6 NA NA <0.005 n number of samples - No criteria available/used 920 Concentration exceeds criteria * Dilute acid extraction results are screened against ISQG-Low values. Porewater and elutriate results are screened against ANZECC (2000) 95 % Trigger Values.

Dilute Acid Extraction Results - concentrations of mercury following dilute acid extraction were less than the ISQG Low value, indicated that most of the mercury was likely bound to mineralised and non-bioavailable phases of the sediment and therefore, unlikely to cause adverse effects. The concentrations of copper and lead exceeded the IQSG Low Value, indicating that some of these analytes were not bound to mineralised phases of the sediment and may be bioavailable.

AVS/SEM - the results of the AVS/SEM testing indicated that the AVS would be insufficient to adequately bind the metals present in the sediment. This is consistent with the sandy nature of the sediments and the lack of an obvious anoxic layer. These results indicate that the metals are potentially bioavailable, but do not indicate whether the presence of these metals would be toxic.

Pore Water analysis - analysis of porewater indicated that neither mercury nor lead were present in the porewater. Copper, however, was present in the porewater at concentrations exceeding the ANZECC (2000) 95% Trigger Value. The criterion applied by PBP for copper in porewater was 9.5 µg/L and was derived from Simpson et al., 2006. This criterion was derived using toxicity data for benthic species only. It is understood that in CSIRO’s submission for revising the porewater criterion, a value of 4.5 µg/L has been proposed. The criterion is higher than the current ANZECC (2000) 95% Trigger Value of 1.3 µg/L. The pore water analysis results indicated a potential for toxicity to some aquatic organisms.

Elutriate Testing - the results of the elutriate testing were consistent with the porewater analysis and indicated that mercury did not partition into the aqueous phase, some lead partitioned into the aqueous phase (with some samples exceeding ANZECC 95% TV) and copper partitioned into the aqueous phase, (with most samples exceeding the ANZECC (2000) 95% TV). However, concentrations of copper in elutriates were lower than the ANZECC 95% TV after allowing for background copper in the elutriate water and water



column dilution, estimated to be approximately 40 fold by PBP (2006b). These results indicate a low potential for adverse effects as a result of copper concentrations, if sediments were resuspended. It is noted by the Auditor that exposure of organisms to resuspended sediments would be localised and temporary, whereas the ANZECC TVs are for chronic, long–term exposures.

The above analyses indicate that in some samples lead, and in most samples copper, are bioavailable and at concentrations exceeding ANZECC/ARMACANZ (2000) criteria for sediments and water. Although background concentrations of these contaminants are elevated within the estuary, the concentrations are generally higher closer to the shoreline. The activities undertaken at the marina, including the use of copper based antifoul on the slipway, may represent a source of these contaminants, however, the stormwater drain adjacent to the marina is also a likely source. The relative contribution of each of these sources cannot be determined with the current dataset.

Similarly, the presence of elevated concentrations of Total PAHs is also likely to be reflective of background sources in the estuary, including stormwater and atmospheric deposition rather than marina activities. No sources of PAHs were identified at the site, however, in the samples collected, concentrations were higher close to the slipway. These locations are also the closest to the stormwater drain. The relative contribution of each of these sources cannot be determined with the current dataset.

The presence of elevated concentrations of TBT is clearly attributable to the operation of the marinas. Assessments of bioavailability are not currently available for organic contaminants such as PAHs and TBT. Elutriate testing undertaken did not identify partitioning of either PAH or TBT into the aqueous phase. However, the applicability of elutriate testing to porewater concentrations or assessments of bioavailability is questionable. Simpson et al.,2005 also recommends assessment of porewater concentrations of organic contaminants using the predicted equilibrium partitioning. Assessment of predicted porewater TBT concentration by PBP using equilibrium partitioning indicated that PAHs and TBT were likely to be bioavailable and exceeding the ANZECC (2000) TV.

Auditor’s Comment:

TBT is the critical contaminant in the sediments near the slipways. The concentrations of TBT in the close vicinity of the Rose Bay and Point Piper slipways exceed the ISQG-High Values and have the potential to cause localised adverse effects on the benthic community near the slipways. These effects may have resulted in some localised changes in the diversity and abundance of the benthic community near the slipways. Consequently, in accordance with the ANZECC decision tree, in the absence of further toxicity testing, either remediation or management of sediments in the vicinity of the slipways must be considered. Factors influencing the approach to remediation or management include the potential for migration of the contaminated sediments and associated risks to human health and the environment (taking into account background conditions). The possibility of increased adverse effects if remedial works are initiated, is also a consideration.



10. CONTAMINATION MIGRATION POTENTIAL

Migration of the TBT contaminated contaminants from the slipway areas is controlled by the potential for erosion and transport of the sediments away from the slipways. The Auditor’s assessment of migration potential is as follows:

The site conditions indicate that the sediment in the area of the slipways is fairly stable and not subject to significant erosion or transport due to tidal or wave effects;

The source of TBT contamination at the slipways is historical and has now ceased. Deposition of sediment within the estuary is likely to lead to burial and gradual isolation of TBT contaminated sediments from the biologically active zone in the longer term. The presence of TBT and metal contamination below the sediment surface provides some evidence that gradual burial of contaminated sediments is occurring at the site;

The proposed floating marina structure will decrease wind generated wave energy and reduce its potential to suspend and transport sediments. In addition the proposed usage of the marina will result in decreased boat traffic in areas where contamination is present (i.e. adjacent to the slipway) and reduce the potential for suspension and transport of those sediments.

In the Auditor’s opinion, it is unlikely that significant migration of contaminated sediments from the slipway areas is occurring, and the proposed development will further reduce the potential for resuspension and migration of the sediments.



11. ASSESSMENT OF RISK

The Auditor’s assessment of risk takes into consideration risks to human health and risks to the environment. The assessment particularly focuses on the contaminated sediments in the vicinity of the slipways of the marinas.

Risks to Human Health - risks to human health depend on the potential for exposure to the contaminated sediments around the slipways. The contaminated sediments are submerged and the waters in the area of the slipways are not normally used for bathing. In the Auditor’s opinion, the potential for human exposure to contaminated sediments and associated risks to human health, at either the Rose Bay Marina or the Point Piper Marina, are low.

Risks to the Environment – the available data indicates that background contamination of sediments in Port Jackson is widespread. The site conditions indicate that significant migration of contaminated sediments away from the slipway areas is not occurring. In addition, the proposed development will further reduce the potential for re-suspension and migration of the sediments. Risks to the environment are therefore limited to possible localised adverse effects on the benthic community near the slipways, which are likely to reduce over time due to sedimentation.

PBP (2007) have considered the approach to remediation or management of the contaminated sediments. They note that the proposed redevelopment of the marinas will have a number of positive effects in relation to the contaminated sediments near the slipways:

Rose Bay marina slipway will be demolished and will not be rebuilt;

Environmental controls at Point Piper marina (subject to a separate approved DA) will be upgraded;

The floating marina structures will attenuate the incident wave climate at the slipway areas and thereby reduce potential for wave induced sediment disturbance and migration;

The berths and fuelling facilities at the marinas will be located more distant from the slipway areas than is currently the case, thereby reducing the potential for vessel disturbance of the sediments;

PBP (2007) consider that remediation of the sediments near the slipways is not necessary or desirable because:

The extent of contamination in excess of background levels, is localised in the vicinity of the slipways;

The development proposal will not involve any direct disturbance of the sediments such as dredging;

Migration of contaminated sediments away from the site is unlikely to be happening under existing conditions and any potential for migration will be further reduced as a consequence of the proposed development for the reasons stated above;



Attempts to remediate the sediments could cause greater adverse effects than leaving the site undisturbed;

A range of measures are available during the construction phase of the development to ensure that demolition and reconstruction activities are undertaken in an environmentally acceptable manner and the sediments are not disturbed.

Auditor’s Comments:

The Auditor considers that the risks to human health and the environment posed by localised sediment contamination at the marinas are low. The Auditor recognises the possibility of some greater adverse effects if remediation of the localised contaminated sediments were undertaken. Considering relative risks and benefits, the Auditor accepts the management approach proposed by PBP and agrees that that the risks associated with sediment disturbance should be addressed through the implementation of an environmental management plan (EMP). This EMP should address the potential mobilisation of contaminated sediments throughout the construction and subsequent operational phases at both of the marinas.



12. ONGOING SITE MANAGEMENT

PBP propose the ongoing management of identified contamination at the both the Rose Bay and Point Piper marinas through the following documents, which are attached in Appendix E:

“Construction Management Plan for Environmental Management, Installation of the Marina, Rose Bay and Point Piper Marinas”, prepared by Rose Bay Marina and Point Piper Marina;

“Environmental Management Plan, Point Piper Marina”, dated May 2007 by Advanced Marina Management Pty Ltd (AAM); and

“Environmental Management Plan, Rose Bay Marina”, dated May 2007 by AAM.

Table 11.1 presents an assessment of the EMPs. The construction EMP (CEMP) is to be implemented during the construction of the marinas, whereas the EMP will be implemented during the ongoing operation of the marinas.

Table 11.1 – Assessment of the EMP

Item Comments

Site Specific stand-a-lone document

The EMPs are site-specific stand alone documents.

The lot number and DP are not specified in the document, however, there is a location plan attached and the Rose Bay and Point Piper Marinas are clearly identified.

The plan is considered by the Auditor to be realistic and has been written in plain English for users of the site.

Plan Objectives The objectives of the plan are generally relevant to managing and mitigating potential environmental effects at the site. The sediment contamination and the requirement for management is identified in Section 4 (in Aims of the CMP).The plan does, however, identify the need to manage contaminated sediment and prevent migration of sediment in Section 6 Environmental Impacts.

The “Objectives” section of the ongoing (operational) EMPs for each of the Rose Bay and Point Piper Marinas clearly identify the need to manage contaminated sediments.

When does the EMP apply?

The construction EMP applies during the construction activities at the site. Once construction of the marinas is finished, the operational EMP will apply to the ongoing site operations.



Item Comments

Contamination Issues The ongoing (operational) EMPs for each of the marina sites contain a section which identifies the presence of contaminated sediments, the contaminants present, the location of the contaminated sediments and the actions required to manage the sediments.

Exposure pathways have not been discussed, as the sediments are not accessible to humans, this is considered acceptable.

The key receptor is the ecological community that may be exposed to contamination through suspension of contaminated sediments. The plan identified control measures to prevent the disturbance of contaminated sediments, thereby reducing exposure of marine organisms. The CEMP identifies the need to use turbidity barriers when undertaking works that may disturb sediments and the EIS identified a methodology for extracting pilings with minimal disturbance of the sediments. The ongoing (operational) EMPs refer to the CEMP for actions and management of contaminated sediments if undertaking works that may disturb contaminated sediments. The operational EMPs also identified the need for speed limits to be strictly enforced to prevent mobilisation of contaminated sediments.

Responsibilities The EMP identify that preventing migration of contaminated sediments is the responsibility of the Marina Owner. The Marina Manager and the Marina Dockmasters will assist the Marina Owner in preventing migration of contaminated sediments.

The EMP relates to all environmental aspects of the ongoing operations at the Marina site and not just the management of contaminated sediments. The management of contaminated sediments is therefore incorporated into the broader system for environmental management at the site.

The EMP was submitted for approval to Woollahra Municipal Council. The plan states that it will be updated every five years.

The EMP indicates that all contractors will be inducted into the environmental management system and establish a training program for marina employees and contractors.

Emergency contacts are not listed in the EMP, however, both sites are staffed by the Marina Manager and Marina Dockmasters.

Long-term management of sediment contamination

It is considered that following the development, access to the contaminated sediments and potential for their resuspension will be considerably less than in the current state. The ongoing EMP for the site is considered to be adequate to manage contaminated sediment at the site.

Compliant with Relevant Documentation?

The EMP is consistent with the EIS prepared for the marina redevelopment project.

The draft EMP has been reviewed by Council and compliance with the EMP has been included in the conditions of consent for the marina redevelopment project.



Item Comments

Occupational Health and Safety (OH&S )

It is not expected that people would be in contact with contaminated sediments as they are below the water surface. Given that the sediments are below the water level, it is expected that any contact with sediments would be minimal and temporary.

Public notification mechanisms to ensure potential purchasers or other interested parties are aware of the restrictions i.e. Section 149 or placing a covenant on the title of land under the CLM Act to require maintenance of remediation under the Act.

A copy if the Site Audit Report has been provided to Council for inclusion of a notification on the Section 149 Certificate.

Will be or can reasonably be made to be legally enforceable?

Compliance with the EMP will be a requirement of the development consent issued by Woollahra Council.

Are the Council in agreement with the EMP?

For the EMP to be enforceable, it needs to be accepted by the Council. A copy of the Draft EMP was provided to Council.

A copy of the SAR/SAS will be provided to Council. It is recommended that these documents be recorded on the S.149 Certificate for the Site.

The appropriate conditions for the implementation of an Environmental Management Plan stated under Section 3.4.6 of NSW EPA (2006) Contaminated Sites: Guidelines for the NSW Site Auditor Scheme (2nd Ed.) have been met, namely:

The EMP has been reviewed by the Auditor.

The provisions of the EMP can be made to be legally enforceable (i.e. Development Consent conditions) in site redevelopment.

There will be appropriate public notification of restrictions applying to the site through a notification on the Section 149 Certificate for the site.

The remnant contamination is not considered to pose an unacceptable risk to onsite or offsite environments.

Based on the above, the Auditor considers that the EMPs will provide an adequate framework for the management of the remnant sediment contamination at the site.



13. COMPLIANCE WITH REGULATORY GUIDELINES AND DIRECTIONS

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

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

JBA (2006) identified that the marina redevelopment is a local development and subject to assessment and determination under Part 4 of the EP&A Act. The proposed development is also:

Designated Development under Schedule 3 of the EP&A Regulation as it is a marina that would have an intended capacity of 15 or vessels having a length of 20 metres or more; and

An Integrated Development, as in addition to development consent, it requires permits or approvals under the Protection of the Environment Operations Act 1997 and Rivers and Foreshores Improvement Act 1948.

The development requires the following approvals and licences from Woollahra Municipal Council:

Land owners consent from Woollahra Municipal Council for works proposed on the balustrade, public walkway and dingy storage rack; and

Development consent for the redevelopment of Rose Bay and Point Piper Marinas.

The redevelopment requires the following approvals and licences from NSW Maritime:

Land Owners consent; and

a Part 3A permit issued by NSW Maritime under the Rivers and Foreshores Improvement Act 1948 as the proposed development “is in, or within, 40 m of the top of the bank or shore of ‘protected waters”.

Rose Bay Marina would be a ‘scheduled activity’ within the meaning of Schedule 1 of the Protection of the Environment Operations Act and requires a licence from the NSW Environment Protection Authority.



14. CONCLUSIONS AND RECOMMENDATIONS

The Auditor’s conclusions and recommendations are as follows:

Concentrations of contaminants, principally TBT, in sediments in the vicinity of the slipways at the Point Piper and Rose Bay marinas have a potential to cause localised adverse effects on the benthic community near the slipways.

The slipways are the main source of contamination. Other sources of contamination are stormwater discharges and atmospheric deposition. Levels of sediment contamination in the wider marina areas are consistent with background levels.

Although there is some uncertainty as to the boundaries of the contaminated areas, this is not critical because the sediment management procedures for the marina redevelopment will extend well beyond the immediate areas of contamination associated with the slipways at each of the marinas.

The source of TBT contamination is historical and has now ceased. Sediments in the affected areas are stable and not subject to erosion and transport. It is unlikely that contaminated sediments are migrating from the slipway areas. Proposed marina development will further reduce the potential for re-suspension and migration of the sediments.

Risks to human health and the environment posed by localised sediment contamination at the marinas are considered to be low. There is a possibility of some adverse effects if remediation of the localised contaminated sediments were undertaken. Considering relative risks and benefits, the Auditor accepts the management approach proposed by PBP and agrees that the risks associated with sediment disturbance should be addressed through the implementation of an environmental management plan (EMP).

Suitable EMPs have been prepared for construction management and ongoing operation of the marinas. The EMPs address the potential mobilisation of contaminated sediments throughout the construction and subsequent operational phases at both of the marinas.

In the Auditor’s opinion, the site can be made suitable for use as a marina subject to implementation of the EMPs. It is noted that:

The EMPs have been reviewed by the Auditor and are considered appropriate;

The provisions of the EMPs can be made to be legally enforceable (i.e. Development Consent conditions) in site redevelopment;

There will be appropriate public notification of restrictions applying to the site through a notification on the Section 149 Certificate for the site; and

The remnant contamination is not considered to pose an unacceptable risk to onsite or offsite environments.

Based on the above, the Auditor considers that the EMPs will provide an adequate framework for the management of the remnant sediment contamination at the site.



15. OTHER RELEVANT INFORMATION

The audit was conducted to provide an independent review of the nature and extent of contamination by an EPA Accredited Auditor i.e. an Audit under Section 47 (1) (b) (i) of the NSW Contaminated Land Management Act 1997 (the CLM Act).

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

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

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

Addenbrooke Pty Ltd November 2007 Rose Bay and Point Piper Marinas Redevelopment APPENDIX A


APPENDIX A Attachments

ATTACHMENT 1: Site Location Plan

ATTACHMENT 2: Sample Location Plan – Proposed Marina Footprints

ATTACHMENT 3: Sample Location Plan – Rose Bay Slipway

ATTACHMENT 4: Plan of TBT Concentrations – Rose Bay Slipway

ATTACHMENT 1: Site Location Plan (PBP, 2006b)

ATTACHMENT 2: Sample Location Plan – Proposed Marina Footprints, (PBP, 2006b)

ATTACHMENT 3: Sample Location Plan – Rose Bay Slipway (PBP, 2006a)

ATTACHMENT 4: Plan of TBT Concentrations – Rose Bay Slipway

Addenbrooke Pty Ltd November 2007 Rose Bay and Point Piper Marina Redevelopment APPENDIX B


APPENDIX B Sediment and Surface Water Criteria

Interim Sediment Quality Guideline (ISQG) Values (ANZECC 2000)

Trigger Values (TV) for Screening Marine Water Quality Data (µg/L) for Slightly to Moderately Disturbed Ecosystems (ANZECC 2000)

Contaminant Threshold

Concentration (µg/L))

Guideline Source

Metals and Metalloids

Arsenic – As (III/V) 2.3/4.5 Low reliability trigger values (95% level of protection) from Volume 2 of ANZECC (2000)

Cadmium – Cd 0.7

Nickel – Ni 7

Mercury – Hg 0.1

ANZECC (2000) 99% protection level due to potential for bio-accumulation or acute toxicity to particular species.

Manganese 80 Low reliability trigger values (derived from the mollusc figure) from Volume 2 of ANZECC (2000)

Chromium – Cr (III/VI) 27.4/4.4

Copper – Cu 1.3

Cobalt 1

Lead – Pb 4.4

Zinc – Zn 15

ANZECC (2000) 95% protection levels.

Aromatic Hydrocarbons

Benzene 500

Toluene 180

Ethylbenzene 5

o-xylene 350

m-xylene 75

p-xylene 200

Low reliability trigger values (95% level of protection) from Volume 2 of ANZECC (2000)

Polycyclic Aromatic Hydrocarbons

Naphthalene 50 ANZECC (2000) 99% protection level due to potential for bio-accumulation or acute toxicity to particular species.

Anthracene 0.01

Phenanthrene 0.6

Fluroanthene 1

Benzo (a) pyrene 0.1

Low reliability trigger values from Volume 2 of ANZECC (2000)

ANZECC (2000) 99% protection level due to potential for bio-accumulation or acute toxicity to particular species.

Chlorinated Alkanes

Tetrachloroethene - PCE 70

1,1,2 Trichlorothene- TCE 330

1,1,2 Trichlorothene- 1,1,2-TCE 330

Vinyl chloride (chloroethene) 100

1,1,1 Trichloroethane – 1,1,1-TCA (111-TCE) 270

1,1 Dichloroethene 700

1,1 Dichloroethane 250

1,2 Dichloroethane 1900

Low reliability trigger values (95% level of protection) from Volume 2 of ANZECC (2000)

1,1,2 - Trichloroethane 1900 Moderate reliability trigger values (95% level of protection) from Volume 2 of ANZECC (2000)

Chloroform 370 Low reliability trigger values (95% level of protection) from Volume 2 of ANZECC (2000)

Trigger Values (TV) for Screening Marine Water Quality Data (µg/L) for Slightly to Moderately Disturbed Ecosystems (ANZECC 2000)

Non-Metallic Inorganics

Ammonia Total – NH3 (at pH of 8) 910

Cyanide (Free or unionised HCN) 4 ANZECC (2000) 95% protection levels.

While the low reliability figures should not be used as default guidelines they will be useful for indicating the quality of groundwater migrating off-site.

Addenbrooke Pty Ltd November 2007 Rose Bay and Point Piper Marinas Redevelopment APPENDIX C


APPENDIX C EPA Approved Guidelines and Additional References

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

(as of 28 March 2007)

Guidelines made by the EPA

Contaminated Sites: Guidelines for Assessing Service Station Sites, December 1994 - servicestnsites.pdf, 1.3Mb Contaminated Sites: Guidelines for the vertical mixing of soil on former broad-acre agricultural land, January 1995 - vertmix.pdf, 149kb Contaminated Sites: Sampling Design Guidelines, September 1995 Contaminated Sites: Guidelines for Assessing Banana Plantation Sites, October 1997 - bananaplantsite.pdf, 586 kb Contaminated Sites: Guidelines for Consultants Reporting on Contaminated Sites, November 1997 Contaminated Sites: Guidelines on Significant Risk of Harm from Contaminated Land and the Duty to Report, April 1999 (revised July 2003) - sroh.pdf, 164kb Contaminated Sites: Guidelines for Assessing Former Orchards and Market Gardens, June 2005 - orchardgdlne05195.pdf, 172 kb Contaminated Sites: Guidelines for the NSW Site Auditor Scheme (2nd edition), April 2006 - auditorglines06121.pdf, 510kb Guidelines for the Assessment and Management of Groundwater Contamination, March 2007 - groundwaterguidelines07144.pdf 604 kb

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

Guidelines approved by the EPA

ANZECC publications

Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites, published by Australian and New Zealand Environment and Conservation Council (ANZECC) and the National Health and Medical Research Council (NHMRC), January 1992Australian and New Zealand Guidelines for Fresh and Marine Water Quality, Australian and New Zealand Environment and Conservation Council and Agriculture and Resource Management Council of Australia and New Zealand, Paper No 4, October 2000

EnHealth publications (formerly National Environmental Health Forum monographs)

Composite Sampling, by Lock, W. H., National Environmental Health Forum Monographs, Soil Series No.3, 1996, SA Health Commission, Adelaide Environmental Health Risk Assessment: Guidelines for assessing human health risks from environmental hazards, Department of Health and Ageing and EnHealth Council, Commonwealth of Australia, June 2002

National Environment Protection Council publications

National Environment Protection (Assessment of Site Contamination) Measure 1999

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

B(1) Guideline on Investigation Levels for Soil and Groundwater

B(2) Guideline on Data Collection, Sample Design and Reporting

B(3) Guideline on Laboratory Analysis of Potentially Contaminated Soils

B(4) Guideline on Health Risk Assessment Methodology

B(5) Guideline on Ecological Risk Assessment

B(6) Guideline on Risk Based Assessment of Groundwater Contamination

B(7a) Guideline on Health-Based Investigation Levels

B(7b) Guideline on Exposure Scenarios and Exposure Settings

B(8) Guideline on Community Consultation and Risk Communication

B(9) Guideline on Protection of Health and the Environment During the Assessment of Site Contamination

B(10) Guideline on Competencies & Acceptance of Environmental Auditors and Related Professionals

Other documents

Guidelines for the Assessment and Clean Up of Cattle Tick Dip Sites for Residential Purposes,NSW Agriculture and CMPS&F Environmental, February 1996 Australian Drinking Water Guidelines, NHMRC & Natural Resource Management Ministerial Council of Australia and New Zealand, 2004

Additional References Birch, G.F., 1996. Sediment bound metallic contaminants in Sydney’s estuaries and adjacent offshore, Australia. Estuarine, Coastal and Shelf Science, 42, pp 31-44.

Birch, G.F. and Taylor, S.E. (2004). The Contaminant Status of Sydney Harbour Sediments – A Handbook for the Public and Professionals. Environmental, Engineering and Hydrogeology Specialist Group (EEHSG) Geological Society of Australia, Public Education and Information Monograph No. 1.

Irvine, I., Birch, G.F., 1998. Distribution of heavy metals in surficial sediments of Port Jackson, Sydney, Australia. Australian Journal of Earth Sciences, 45/1, pp 169-174

McCready, S., Slee, D.J., Birch, G.F. and Taylor S.E. (2000) The distribution of Polycyclic Aromatic Hydrocarbons in Surficial Sediments of Sydney Harbour, Australia. Marine Pollution Bulletin, Vol. 40, No. 11 pp 999-1006. McCready et al., (2000) indicated that maximum concentrations of PAHs as 240 mg/kg and 380 mg/kg, however, these were attributed to point sources of PAH contamination and not reflective of background concentrations.

Simpson, S.,L., Batley, G.E. Chariton, A.A, Stauber, J.L., King, C.K., Chapman, J.C., Hyne, R.V., Gale, S.A., Roach, A.C. and Maher, W.A. (2005). Handbook for Sediment Quality Assessment.CSIRO, Bangor, NSW.

Simpson, S.L. (2006) Copper Effects Thresholds of Saltwater (Estuarine/Marine) Benthic Biota,Report no. ET/IR885R, June 2006, CSIRO Internal Report.

Taylor, S.E. (2000). The source and remobilisation of contaminated sediment in Port Jackson, Australia. Unpublished PhD Thesis, School of Geosciences, The University of Sydney, Sydney.

Addenbrooke Pty Ltd November 2007 Rose Bay and Point Piper Marinas Redevelopment APPENDIX D


APPENDIX D Analytical Lists and Methods

ADVANCED ANALYTICAL METHODS

TARGET COMPOUNDS ADVANCED ANALYTICALMETHOD ID METHODOLOGY SUMMARY

Extraction for Organic Compounds in Sediment 10g of sample (volatile 8g) extracted ultrasonically with methylene chloride for 30 minutes. Analysis undertaken using GC/MS for environmental samples.

POLYAROMATIC HYDROCARBONS

Naphthalene 04-022Acenaphthylene Acenaphthene Fluorene Phenanthrene Anthracene Fluoranthene PyreneBenz(a)anthracene Chrysene Benzo(b)&(k)fluorantheneBenzo(a)pyrene Indeno(1.2.3-c,d)pyreneDibenz(a,h)anthracene Benzo(g,h,i)perylene

After extraction, the sample is analysed by capillary column GC/MS. (based on US EPA 3550B, 8270)

HEAVY METALS

Arsenic Cadmium Chromium CopperNickel LeadZinc

04-001 US EPA 3050 & ICP/AES – US EPA 200.7

Mercury 04-002 US EPA 3050 & 7471A CVAAS

ORGANOTINS

Tributyltin 04-026 In-house method based on (Abalos et al., 1997 and Attar, 1996)

Dibutyltin Monobutyltin

ORGANOCHLORINE PESTICIDES

HCB 04-023 US EPA 3250B / 8270 GC/MS Dicloran g-BHC (lindane)BHC (other)HeptachlorAldrin Heptachlor Epoxide Chlordane (total)Dieldrin DDE Endrin DDDEndosulfan (total)DDT Methoxychlor

TARGET COMPOUNDS ADVANCED ANALYTICALMETHOD ID METHODOLOGY SUMMARY

BTEX COMPOUNDS

Benzene 04-021

Toluene

Ethylbenzene

Xylene

5mL of extractant or water samples introduced by direct purging and analysed. Analysis by capillary column purge and trap GC/MS, confirmation by secondary column technique. Reference US EPA 5030/ 5035 and 8260.

TOTAL PETROLEUM HYDROCARBONS

C6-C9 Fraction 04-021

5mL of extractant or water samples introduced by direct purging and analysed. Analysis by capillary column purge and trap GC/MS, confirmation by secondary column technique. Reference US EPA 5030/ 5035 and 8260.

C10-C14 Fraction 04-020

C15-C28 Fraction

C29-C36 Fraction

Analysis using a modified USEPA 3550B and 8015B methodology GC/FID.

POLYCHLORINATED BIPHENYLS

PCBs as congeners 04-029 Reference US EPA 3550B and 8270 GCMS.

PHENOLS

Phenol 04-022 2-chlorophenol 2-methylphenol

After extraction, the sample is analysed by capillary column GC/MS. (based on US EPA 3550B, 8270)

4-methylphenol 2-nitrophenol 2,4-Dmethylphenol 2,4-Dchlorophenol 4-chloro-3-methylphenol2,4,6-Ticholrophenol 2,4,5-Tichlorophenol Pentachlorophenol

Addenbrooke Pty Ltd November 2007 Rose Bay and Point Piper Marinas Redevelopment APPENDIX E


APPENDIX E Environmental Management Plans

Refer to Appendix P of the JBA Report for:Construction Management Plan

prepared by Advanced Marina Management

Refer to Appendix X of the JBA Report for:Rose Bay Marina Environmental Management Plan

prepared byAdvanced Marina Management

Documents

Re: Site Audit Report for Rose Bay Marina · LPAH Light Molecular Weight PAHs HPAH Heavy Molecular Weight PAHs PCBs Polychlorinated Biphenyls PID Photo-ionisation Detector PQL Practical