INFORMATION REGARDING ENVIRONMENTAL AUDIT REPORTS

August 2007

VICTORIA’S AUDIT SYSTEM AUDIT REPORT CURRENCY An environmental audit system has operated in Audit reports are based on the conditions encountered Victoria since 1989. The Environment Protection Act and information reviewed at the time of preparation 1970 (the Act) provides for the appointment by the and do not represent any changes that may have Environment Protection Authority (EPA Victoria) of occurred since the date of completion. As it is not environmental auditors and the conduct of possible for an audit to present all data that could be independent, high quality and rigorous environmental of interest to all readers, consideration should be audits. made to any appendices or referenced documentation An environmental audit is an assessment of the for further information. condition of the environment, or the nature and extent When information regarding the condition of a site of harm (or risk of harm) posed by an industrial changes from that at the time an audit report is process or activity, waste, substance or noise. issued, or where an administrative or computation Environmental audit reports are prepared by EPA- error is identified, environmental audit reports, appointed environmental auditors who are highly certificates and statements may be withdrawn or qualified and skilled individuals. amended by an environmental auditor. Users are Under the Act, the function of an environmental advised to check EPA’s website to ensure the currency auditor is to conduct environmental audits and of the audit document. prepare environmental audit reports. Where an environmental audit is conducted to determine the PDF SEARCHABILITY AND PRINTING condition of a site or its suitability for certain uses, an environmental auditor may issue either a certificate or EPA Victoria can only certify the accuracy and statement of environmental audit. correctness of the audit report and appendices as presented in the hardcopy format. EPA is not A certificate indicates that the auditor is of the opinion responsible for any issues that arise due to problems that the site is suitable for any beneficial use defined with PDF files or printing. in the Act, whilst a statement indicates that there is some restriction on the use of the site. Except where PDF normal format is specified, PDF files are scanned and optical character recognised by Any individual or organisation may engage appointed machine only. Accordingly, while the images are environmental auditors, who generally operate within consistent with the scanned original, the searchable the environmental consulting sector, to undertake hidden text may contain uncorrected recognition environmental audits. The EPA administers the errors that can reduce search reliability. Therefore, environmental audit system and ensures its ongoing keyword searches undertaken within the document integrity by assessing auditor applications and may not retrieve all references to the queried text. ensuring audits are independent and conducted with regard to guidelines issued by EPA. This PDF has been created using the Adobe-approved method for generating Print Optimised Output. To assure proper results, proofs must be printed, rather AUDIT FILES STRUCTURE than viewed on the screen. Environmental audit reports are stored digitally by This PDF is compatible with Adobe Acrobat Reader EPA in three parts: the audit report (part A), report Version 4.0 or any later version which is downloadable appendices (part B) and, where applicable, the free from Adobe’s Website, www.adobe.com. certificate or statement of environmental audit and an executive summary (part C). A report may be in colour FURTHER INFORMATION and black-and-white formats. Generally, only black- and-white documents are text searchable. For more information on Victoria’s environmental Report executive summaries, findings and audit system, visit EPA’s website or contact EPA’s recommendations should be read and relied upon only Environmental Audit Unit. in the context of the document as a whole, including Web: www.epa.vic.gov.au/envaudit any appendices and, where applicable, any certificate Email: [email protected] or statement of environmental audit.

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REPORT NO. 207026

ENVIRONMENTAL AUDIT REPORT FOR 160-162 COMMERCIAL ROAD, PRAHRAN, VICTORIA

EPA CARMS NO: 61732-1

ENVIRONMENTAL EARTH SCIENCES VIC REPORT TO ASIAN PACIFIC BUILDING CORPORATION PTY LTD DATE 7 NOVEMBER 2008

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AUDIT REPORT EXECUTIVE SUMMARY

This environmental audit report has been prepared in response to a request to issue a Certificate of Environmental Audit (CoEA) for 160-162 Commercial Road, Prahran, Victoria, 3181. The site is covered by Lot 1 on TP555135 Volume 01862 Folio 303, in accordance with Part IXD of the Environment Protection Act (1970). A summary of the environmental audit is presented below.

TABLE 1 SUMMARY OF AUDIT INFORMATION

EPA file reference No 61732-1 Auditor: Philip Mulvey Auditor term of appointment: 10 April 2007 to 10 April 2011 Name of person requesting audit: David Rogalsky Relationship to premises/location Construction Manager of Asian Pacific Building Corporation (Owner) Date of request 14 February 2007 Date EPA notified of audit 20 February 2007 Completion date of audit 7 November 2008 Reason for audit Planning Permit requirement Current land use zoning B1Z – Business 1 Zone EPA region Yarra Municipality Stonnington Dominant – Lot on plan Lot 1 on TP555135 Additional – Lot on plan(s) - Site/premises name o Street/Lot – Lower No. 160 o Street/Lot – Upper No. 162 o Street Name Commercial o Street type Road o Street suffix (North, South etc) - o Suburb Prahran o Postcode 3181 GIS coordinate of site centroid Longitude/Northing (GDA94) 37.5048 Latitude/Easting (GDA94) 144.5930 Site area (hectares) 0.1244 Members and categories of support Mark Stuckey (Soil Science, Hydrogeology, Contaminant transport, team utilised Assessment of exposure pathways and risk) Outcome of audit Statement Further work or requirements Groundwater Quality Management Plan (GQMP) Nature and extent of continuing risk None known

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TABLE 2 PHYSICAL SITE INFORMATION

No aquifer present in upper 12 metres, but groundwater located within the Site Aquifer Formation Red Bluff Sands of the Brighton Group

Average depth to groundwater 6.5m

Groundwater segment B

Groundwater flow direction North

Past use/site history Service station and/or mechanics garage from 1960 to approximately 2007

South: Grattan Gardens parkland, Senior citizens centre; East: Café’s, Surrounding land use retail, commercial; North: Café’s, retail, Prahran Market: Retail, commercial showrooms

High density residential and commercial use consisting of a Smart Hotel Proposed future use with single level underground car park, ground floor retail and bar and six floors of residential living apartments.

This summary must be read in conjunction with the full audit report and the Statement of Environmental Audit (SoEA) that has been issued for the site. The Audit report provides more data and discussions that are not in the above summary table for reasons of space and clarity. All owners of the site, all occupiers and those made responsible for the management of the site including any future sub divisions should be provided with a copy of this SoEA which includes a Clean Up to the Extent Practicable.

The SoEA is issued based on the site conditions at the time of issue. The Auditor cannot control future activities that may result in contamination of the site.

There are a number of abbreviations and acronyms throughout the report. Refer to Section 12 of the audit report for a list of these abbreviations and acronyms.

Distribution List

Copy No Distributed to

1 Asian Pacific Building Corporation Pty Ltd

2 Environment Protection Authority – Principal Auditor

3 City of Stonnington – CEO

4 Environmental Auditor – Phil Mulvey

5 Environmental Earth Sciences VIC (library)

6 Environmental Earth Sciences file (207026)

Revision List

Revision No Description of Revision Issued Date

0 Final issue 7 November 2008

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ENVIRONMENT PROTECTION ACT 1970

STATEMENT OF ENVIRONMENTAL AUDIT

I, Philip Mulvey of Environmental Earth Sciences VIC, a person appointed by the Environment Protection Authority (‘the Authority’) under the Environment Protection Act 1970 (‘the Act’) as an environmental auditor for the purposes of the Act, having: 1. been requested by David Rogalsky of Asian Pacific Building Corporation to issue a certificate of environmental audit in relation to the site located at 160-162 Commercial Road, Prahran, Victoria 3181 covered by Volume 01862 Folio 303, Lot 1 on TP555135 (‘the site”) owned by Asian Pacific Building Corporation Pty Ltd. 2. had regard to, among other things, (i) guidelines issued by the Authority for the purposes of Part IXD of the Act, (ii) the beneficial uses that may be made of the site, and (iii) relevant State environment protection policies/industrial waste management policies, namely State Environment Protection Policy (June 2002) – Prevention and Management of Contamination of Land and State Environment Protection Policy (1997) – Groundwaters of Victoria, in making a total assessment of the nature and extent of any harm or detriment caused to, or the risk of any possible harm or detriment which may be caused to, any beneficial use made of the site by any industrial processes or activity, waste or substance (including any chemical substance), and 3. completed an environmental audit report in accordance with section 53X of the Act, a copy of which has been sent to the Authority and the relevant planning and responsible authority.

HEREBY STATE that I am of the opinion that: The site is suitable for the beneficial uses associated with high density residential development and commercial land-use, subject to the following conditions attached thereto: On-going groundwater monitoring (at least six-monthly for three years) is required and should be formalised through provision of a Groundwater Quality Management Plan (GQMP) within 30 days of the date of this statement. Asian Pacific Building Corporation will be responsible for its implementation. Groundwater should not be abstracted for use without appropriate testing at the subject site or the adjacent sites to the east fronting Commercial Road to the corner of Izett Street; consequently a Groundwater Quality Restricted Use Zone (GQRUZ) should be placed over the site and these properties.

The condition of the site is detrimental or potentially detrimental to any (one or more) beneficial uses of the site. Accordingly, I have not issued a Certificate of Environmental Audit for the site in its current condition, the reasons for which are presented in the environmental audit report. The terms and conditions that need to be complied with before a Certificate of Environmental Audit may be issued are set out as follows: In order for the site to gain a Certificate of Environmental Audit further groundwater assessment and analysis, and possibly remediation, would be required to quantify levels of chemicals of concern in the uppermost aquifer beneath the site.

Other relevant information: EPA Victoria have determined (on 31 October 2008) that groundwater pollution at the site has been cleaned-up to the extent practicable, and have identified the site as being within a Groundwater Quality Restricted Use Zone. Remaining chemicals in groundwater beneath the site are components of fuel such as total petroleum hydrocarbons (TPH) and benzene, toluene, ethyl-benzene and xylenes (BTEX). Some other chemicals such as trimethybenzenes, naphthalene, arsenic, nitrate and heavy metals (aluminium, chromium, nickel, iron, manganese and mercury) have also been detected. Despite these occurrences, the only precluded beneficial uses are considered to be for on-site and adjacent

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TABLE OF CONTENTS

1 INTRODUCTION...... 9

2 PURPOSE OF AUDIT...... 9

3 AUDIT REQUIREMENTS ...... 10

4 SITE DETAILS & CHARACTERISTICS ...... 12 4.1 DOCUMENTS REVIEWED 12 4.2 SITE IDENTIFICATION, ZONING AND MUNICIPALITY 12 4.3 CURRENT SITE STATUS 12 4.4 ORIGINAL SITE STATUS 12 4.5 PROPOSED USE 13 4.6 ADJACENT USES 13 4.7 SITE HISTORY 13 4.8 TOPOGRAPHY, VEGETATION AND DRAINAGE 14 4.9 GEOLOGY AND SITE STRATIGRAPHY 14 4.10 HYDROGEOLOGY 14 4.11 POTENTIAL SOURCE OF AND NATURE OF CHEMICALS OF CONCERN 15 5 ENVIRONMENTAL QUALITY CRITERIA & BENEFICIAL USES ...... 16 5.1 SOIL 16 5.1.1 NEPM interim ecological investigation levels (EILs) 16 5.1.2 NEPM human health based soil investigation level guidelines (HILs) 18 5.2 OFF-SITE DISPOSAL 20 5.3 ADOPTED SITE CRITERIA FOR IN-SITU SOIL 20 5.3.1 Modified and highly modified ecosystems 20 5.3.2 Human Health 20 5.3.3 Aesthetics 20 5.3.4 Production of food, flora and fibre 20 5.3.5 Buildings and structures 21 5.4 ADOPTED SITE ACCEPTANCE CRITERIA FOR GROUNDWATER 21 6 ASSESSMENT OF SITE CONDITIONS ...... 22 6.1 SCOPE OF AUDIT 22 6.2 REVIEW OF LRM GLOBAL INVESTIGATIONS 23 6.2.1 Review of nearby environmental audit 24 6.2.2 LRM Global soil investigation and classification assessments 24 6.2.3 Excavation works 25 6.2.4 LRM Global validation sampling 25 6.2.5 LRM Global groundwater assessment 26 6.3 AUDITOR INSPECTIONS AND VERIFICATION SAMPLING 29

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7 EVALUATION OF QUALITY AND COMPLETENESS ...... 29 7.1 SAMPLE DENSITY AND SITE COVERAGE 29 7.1.1 Environmental site assessment 29 7.1.2 Waste classification 29 7.1.3 Validation sampling 30 7.2 ANALYTICAL SCHEDULE AND COMPLETENESS 30 7.2.1 Soil assessment and classification for off-site disposal 30 7.2.2 Validation sampling 31 7.2.3 Groundwater sampling 32 7.3 MEASUREMENT DATA QUALITY OBJECTIVES 33 7.4 SAMPLING METHODOLOGY 33 7.4.1 Soil sampling 33 7.4.2 Groundwater borehole installation and sampling 33 7.5 FIELD QUALITY ASSURANCE AND QUALITY CONTROL 34 7.6 LABORATORY QUALITY ASSURANCE AND QUALITY CONTROL 34 7.7 BLIND AND SPLIT DUPLICATE EVALUATION 35 7.7.1 Soil assessment and waste classification 35 7.7.2 Validation sampling 36 7.7.3 Groundwater sampling 36 7.8 DATA SET COMPARABILITY 36 7.9 AUDITOR CONCLUSIONS ON QUALITY ASSURANCE AND QUALITY CONTROL 36 8 AUDIT FINDINGS ...... 37 8.1 NATURE AND EXTENT OF CONTAMINATION 37 8.2 IMMINENT ENVIRONMENTAL HAZARD 38 8.3 EVALUATION OF ENVIRONMENTAL QUALITY AND ASSESSMENT OF RISK 38 8.3.1 Soil 38 8.3.2 Air quality 39 8.3.3 Groundwater and surface water 39 8.4 POTENTIAL MIGRATION OF CONTAMINATION 43 8.5 CLEAN-UP TO THE EXTENT PRACTICABLE (CUTEP) DETERMINATION 43 9 CONCLUSIONS...... 43

10 LIMITATIONS ...... 44

11 REFERENCES ...... 45

12 ABBREVIATIONS ...... 46

FIGURES

APPENDICES A CURRENT TITLE DETAILS B AUDITORS VERIFICATION SAMPLING RESULTS C LRM GLOBAL ASSESSMENT REPORTS

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1 INTRODUCTION

Asian Pacific Building Corporation (APBC) commissioned Philip Mulvey in February 2007, to act as the Environmental Auditor for the property located at 160-162 Commercial Road, Prahran, Victoria, 3181, described as Lot 1 on TP555135 (Volume 01862 Folio 303) (‘the site”). Reported total site area is 1244 m2.

The site has a history of light industry and commercial use (service station). In 2007 all structures on site were demolished and the site is currently vacant and undeveloped with the exception of the basement car park excavation.

The site is zoned Business 1 Zone (B1Z) and is subject to a statutory Environmental Audit due to a Planning Permit requirement triggered by the change from one land use to a more sensitive one. Hence, an Environmental Audit is to be undertaken and will assess whether the site is suitable for any beneficial use and if not, whether it is suitable for uses pertaining to commercial and high density residential land-use.

The following reports were reviewed in compilation of this environmental audit report: • Douglas Partners (March 2006) Limited Contamination Assessment; • LRM Global (October 2006) Hazardous Materials Risk Assessment report; • LRM Global (March 2007) Phase 1 Environmental Site Assessment; • LRM Global (June 2008) Phase 2 Environmental Site Assessment; and • LRM Global (October 2008) Phase 2 Hydrogeological Assessment.

The Auditor and his team’s role in the audit of the site included the assessment of the above reports, the Auditor’s (and representatives) inspections of the site, liaison with the client’s consultant, and the preparation of this audit report. The LRM Global investigations and documentation been assessed as acceptable and consistent with the level of quality expected from members of the environmental consulting profession.

2 PURPOSE OF AUDIT

The owner of the site proposes to develop the site with a six storey serviced apartment block (high density residential) and commercial structure with an underground car park extending to approximately 4.0 metres below ground level (mBGL).

As the site is changing from a specific (commercial/industrial) land use to a more sensitive one (residential) the City of Stonnington requires a Statutory Environmental Audit be conducted as one of the planning permit conditions for the site to be developed for commercial and residential land-use.

The purpose of this audit is to evaluate whether the site is suitable for issue of a Certificate of Environmental Audit (CoEA) indicating that the site is suitable for any beneficial use, and if not whether it is suitable for the proposed high density residential and commercial usage. Such determination would result in the issue of a Statement of Environmental Audit (SoEA).

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3 AUDIT REQUIREMENTS

An environmental audit is a total assessment of the nature and extent of any harm caused to, or the risk of any possible harm or detriment which may be caused to, any beneficial use made of any segment of the environment by any industrial process or activity, waste, substance (including any chemical substance) or noise. Note that Section 3 of the Auditor Guidelines states that “noise is not a relevant consideration when conducting an environmental audit (contaminated land) but is a factor which can impact on a beneficial use”.

In May 1992 the Minister for Planning and Housing (currently Department of Planning and Community Development) under the Planning and Environment Act 1987, Section 12 (2) (a) substituted his Direction No. 1 (dated October 1989) and issued a revision to Councils to direct them that they must satisfy themselves that potentially contaminated land, which is proposed to be allowed under an amendment to a planning scheme, is suitable for more sensitive uses such as residential use, a child care centre, a pre-school centre or a primary school.

Councils must satisfy themselves by obtaining either a Certificate or Statement of Environmental Audit by an Appointed Environmental Auditor pursuant to Part IXD of the Victorian Environment Protection Act 1970 and its amendments for the nominated land- use(s).

A Certificate of Environmental Audit (CoEA) certifies that the site is suitable for all beneficial uses. A Statement of Environmental Audit (SoEA) is a conditional certification with some restriction on the use of the site.

An Auditor must have regard to the requirements of relevant State Environment Protection Policies (SEPPs), Industrial Waste Management Policies (IWMPs), guidelines issued by EPA Victoria for the purpose of the Act, and any National Environment Protection Measure (NEPM) publication. In addition the Auditor should also refer to published guidelines and standards relevant to the assessment and auditing of sites.

This audit has been undertaken using the guidance contained in the EPA Victoria guidelines, in particular the Environmental Auditor (Contaminated Land) Guidelines for Issue of Certificates and Statements of Environmental Audit (Publication 759.1, September 2007).

A list of references is provided in Section 11.0 of this report. In addition, all information was compared to other relevant guidelines for an investigation of this nature with the following documents also consulted in preparing this audit:

Guidelines • Australian and New Zealand Environment and Conservation Council (ANZECC)/National Health and Medical Research Council (NHMRC) (1992) — Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites; • ANZECC (1992) — Australian water quality guidelines for fresh and marine waters. National Water Quality Management Strategy; • ANZECC (August 1996) — Guidelines for Laboratory Analysis of Contaminated Soil;

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• ANZECC and Agriculture and Resource Management Council of and New Zealand (ARMCANZ) (2000) — Australian and New Zealand guidelines for fresh and marine water quality. National Water Quality Management Strategy; • Dutch Ministry of Housing, Spatial Planning and Environment (2000) — Circular on target Values and Intervention Values for Soil Remediation; • Environment Protection Act (1970) and amendments; • EPA Victoria Publication 597 (1998) — State Environment Protection Policy (Groundwaters of Victoria); • EPA Victoria Publication 441 (2000) — A Guide to the Sampling and Analysis of Waters, Wastewaters, Soils and Wastes; • EPA Victoria Publication 759.1 (September 2007) — Environmental auditor (contaminated land) – Guidelines for issue of certificates and statements of environmental audit; • EPA Victoria Publication 860.1 (August 2007) — Environmental Auditing of Contaminated Land; • EPA Victoria Publication 865.6 (August 2007) — Environmental auditor guidelines for appointment and conduct; • EPA Victoria Publication 902 (April 2003) — Environmental Auditing in Victoria; • EPA Victoria Publication 952.2 (August 2007) — Environmental auditor guidelines for the preparation of environmental audit reports on risk to the environment; • EPA Victoria Publication 953.2 (August 2007) — Environmental auditor guidelines for conducting environmental audits; • EPA Victoria Publication 1147 (September 2007) — Environmental auditor guidelines – provision of environmental audit reports, certificates and statements; • EPA Victoria Publication 854 (2002) — Policy impact assessment – Prevention and management of contaminated land in Victoria; • EPA Victoria Publication 735.1 (2003) — EPA Contaminated Site Information Systems Priority Sites Register; • EPA Victoria Information Bulletin, Publication 448.3 (2007) — Classification of Wastes; • EPA Victoria Publication 364d (2004) — The Transport and Disposal of Waste Asbestos; • National Environment Protection Council (NEPC) (1999) — National Environment Protection (Assessment of Site Contamination) Measure (NEPM); • NHMRC (2004) ⎯ Australian drinking water guidelines. National Water Quality Management Strategy; • NSW Environment Protection Authority (NSW EPA) (December 1994) — Contaminated Sites: Guidelines for Assessing Service Station Sites; • Standards Australia AS4482.1 (2005) — Guide to the investigation and sampling of sites with potentially contaminated soil. Part 1: Non-volatile and semi-volatile compounds; • Standards Australia AS4482.2 (1999) — Guide to the Sampling and Investigation of Potentially Contaminated Soil. Part 2: Volatile substances;

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• Standards Australia AS 2031.1 (1986) — Selection of Containers and Preservation of Water Samples for Chemical and Microbiological Analysis, Part 1 (Chemical) and Part 2 (Microbiological); • State Environment Protection Policy (SEPP) (1997) — Groundwaters of Victoria (GoV); • SEPP (2002) — Prevention and Management of Contamination of Land; and • SEPP (2003) — Variation to State Environment Protection Policy (Waters of Victoria).

4 SITE DETAILS & CHARACTERISTICS

4.1 Documents reviewed The following documents have been reviewed as part of this report: • Douglas Partners (March 2006) Limited Contamination Assessment; • LRM Global (October 2006) Hazardous Materials Risk Assessment report; • LRM Global (March 2007) Phase 1 Environmental Site Assessment; • LRM Global (June 2008) Phase 2 Environmental Site Assessment; • LRM Global (October 2008) Phase 2 Hydrogeological Assessment; • Environmental Earth Sciences (October 2008) CUTEP Submission; and • EPA Victoria’s letter dated 31 October 2008 in response to the CUTEP Submission.

4.2 Site identification, zoning and municipality The property is described as 160-162 Commercial Road, Prahran, Victoria 3181 covered by Lot 1 on TP555135. The relevant Certificate of Title is Volume 01862 Folio 303 (Appendix A). The site is located within the municipality of the City of Stonnington. The site is zoned Business 1 Zone (B1Z) and is subject to a statutory environmental audit triggered by the site changing from a specific (commercial/industrial) land use to a more sensitive one (residential), as detailed on the planning permit for the site. Site location is provided in Figure 1.

4.3 Current site status The site is currently being developed and has undergone excavation works to create a basement car-park across the entire site. At the time of publishing of this report, the basement and some above-ground levels had been put in place. In the Auditor’s opinion, LRM Global has adequately described the site, as confirmed by the Auditor’s site inspections and inspections conducted by members of the Auditor’s team.

4.4 Original site status The site consisted of a large building and sealed car-park. The main building was a single story structure with two sections, an office reception area and an open plan workshop. The building had a flat metal deck roof, concrete floor slab, and was last fitted out as a “Bob Jane T-Marts Tyre Centre”. Internal walls were cement sheet while the shop front was brick and

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Page 12 of 51 glass. The north and west sides of the site were an open car parking area though a narrow bin area was located immediately to the south of the building.

4.5 Proposed use The site is to be developed into a six story serviced apartment (high density residential) block with a commercial retail ground floor and a basement car park.

4.6 Adjacent uses Based on the LRM Global reports and Auditor’s site inspections, the site is surrounded by the following land uses: • retail, commercial showrooms, west side on Grattan Street; • Grattan Gardens parkland, south side; • senior citizens centre, east side of site; and • café’s, retail, commercial, north side across Commercial Road.

4.7 Site history LRM Global has conducted a historical review, which is presented in section 7 of their Phase 1 Preliminary Environmental Site Assessment and Sections 3.0 of their Phase II Environmental Site Assessment report. The historical review involved: • interview with Ms Melita Balaam – current property owner (APBC) representative; • interview with Mr Ben Frankil – family property owners 1944 – 2006; • interview with Mr Gary Job, Property Manager Bob Jane T-Marts; • completion of a Phase I assessment questionnaire by Mr Jon Lawson (LRM) in December 2006; • detailed site inspections; • review of historical maps and other information through the State Library of Victoria and maps/site layout plans held by Asian Pacific Building Corporation; • review of past environmental and hazardous material investigations at the site and in the nearby area; • review of aerial photographs; • search of Sands & McDougall Register; and • historical certificates of title.

LRM Global has compiled historical information from 1944 to the present day. Based on the review of historical information, the site has been occupied by a mixture of light industrial (service station) and commercial purposes (tyre fitting and sales). A summary of the site history information is provided below in Table 3.

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TABLE 3 HISTORICAL INFORMATION

Date Site Information Pre 1940s The site and surrounding area was most likely used for agriculture 1940 – 1960 The site was purchased by the Frankil family and was leased as a car sales yard 1960 – 1981 Site was leased by and used as a service station 1981 – 1991 Site was leased by Ultra Tune and used as a service motor mechanics garage 1991 – 2007 Site was leased by Bob Jane t Mart and used as a tyre sales and service centre

4.8 Topography, vegetation and drainage The natural topography of the site is flat with a very gentle regional slope towards the south and west, with a surface height at approximately 10 metres Australian Height Datum (mAHD). The topography of the site after demolition of the buildings remains flat.

The closest natural watercourse to the site is the Albert Park Lake located approximately 1.3km to the southwest of the site. Port Phillip bay is located approximately 2.5 km south- west from the site. It is expected that surface drainage would be to the municipal stormwater system which would discharge to the Yarra River.

Because the site has previously been covered by buildings with concrete flooring and asphalt, no vegetation is present at the site.

4.9 Geology and site stratigraphy The regional geology was described by LRM Global based on the Geological Survey of Victoria Map Sheet 1:63,360, Part 7822, Zone 55 indicates that the subject site lies within the Tertiary, Pliocene, Red Bluff Sands (Brighton Group), consisting of sand, red brown, yellow white well bedded to cross-bedded, silty sand, minor gravel, sometimes clay balls, underlain with Tertiary, Miocene, Newport formations.

The soil investigation conducted by LRM Global identified fill containing dark brown to light grey sandy clay, with gravel ranging from 0.2m to 1.5m in thickness. Underlain this material is light brown to orange brown sandy clay, which is firm to stiff in consistency. This material ranges from 1.5 m to 2.7 m in thickness. This is underlain by grey brown to light grey sandy clay and dark brown sandy silty clay which was found to be from firm to stiff in consistency. This layer ranges from 2.7 m to 3.8 in thickness. Beneath this soil profile there is light brown to light grey sandy clay with gravel up to a depth of approximately 4.5 m. This profile was found to be stiff to firm in consistency.

The Auditor considers the consultant’s assessment of the local geology to be adequate. In the Auditor’s opinion, the observed natural soil profile at the site is consistent with the regional geology.

4.10 Hydrogeology The closest natural watercourses to the site are the Yarra River, located 1.5km to the north, and Albert Park Lake, located approximately 1.5km to the west of the site. Based on relative

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Page 14 of 51 levels reported for on-site monitoring boreholes GW1 to GW4 and off-site monitoring borehole GW5 to GW9, groundwater is migrating in a northerly direction.

LRM Global has reviewed hydrogeology using maps, a review of the DSE groundwater database and through a review of groundwater information on environmental audits, for neighbouring properties.

Based on LRM’s investigation, and confirmed by the Auditor, the site is located overlying the Brighton Group aquifer, which is semi-confined. Total dissolved salts (TDS) in this aquifer generally range between 1,000 and 3,500 mg/L. Groundwater in this vicinity is therefore classified as Segment B (DNRE 1995a) in accordance with the State Environment Protection Policy (SEPP) (1997) Groundwaters of Victoria (GoV).

(Check GW for surface water leakage I suspect regional GW is close to 3000 and reticulated water has dilted TDS on site. Need comment. Is this based on regional data ie what is expected or what is found.)

4.11 Potential source of and nature of chemicals of concern The site history review indicated that the site has a history of industrial/commercial activity (service station). LRM Global has suggested that chemicals of potential concern (CoPC) originating from the site are: • asbestos; • metals; • total petroleum hydrocarbons (TPH); • mono-aromatic hydrocarbons (MAH); • polycyclic aromatic hydrocarbons (PAH); • phenolic compounds; • volatile halogenated compounds (VHC); and • acids and solvents.

LRM suggests that CoPC originating from the nearby area are limited to trichloroethylene (TCE), tetrachloroethylene (PCE) and chloroform associated with nearby dry cleaning premises.

The Auditor considers LRM’s assessment of CoPC originating from the nearby area to be adequate.

The Environmental Audit report for a nearby site at lots 8-25, Commercial Road was reviewed by LRM as part of the assessment of chemicals of concern. Present at elevated levels in imported fill material present at the site were: • heavy metals and PAHs in the soil; and • TPH and BTEX in the groundwater.

Four underground storage tanks (USTs) were identified across the site as well as a triple interceptor trap (TIT) which are potential sources of: • metals;

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• total petroleum hydrocarbons (TPH); • mono-aromatic hydrocarbons (MAH); • polycyclic aromatic hydrocarbons (PAH); and • phenolic compounds.

Due to past use of the site as a service station, the Auditor considers the potential for on-site contamination to be significant. However, due to the removal of the upper four metres of soil the potential risk has potentially been removed. Despite this, prior to the excavation works the Auditor considers that there was a potential for a wide range of chemicals to be present across the site.

5 ENVIRONMENTAL QUALITY CRITERIA & BENEFICIAL USES

The audit process requires site contamination to be assessed in the context of beneficial uses that need to be protected in relation to the relevant sections of the environment including soil, groundwater, surface water and air.

The site is to be developed for high density residential and commercial landuse. As such, the applicable section of the environment in relation to the site was considered to be soil, surface waters and groundwater, which are discussed in more detail below.

5.1 Soil The SEPP (2002) — Prevention and Management of Contamination of Land provides the framework for the protection of land and associated beneficial uses throughout Victoria. The policy allows for a consistent approach to the prevention of contamination of land, and clean- up of pollution of land in Victoria, and sets environmental quality indicators and objectives for each beneficial use. The SEPP defines certain land use categories and associated beneficial uses of land to be protected.

The beneficial uses of land to be protected are dependant on the proposed land use and are shown in Table 4, with relevant guidelines detailed in Table 5.

A protected beneficial use may not apply at a site where background concentrations of a substance is greater than the relevant guideline designated in Table 6. Therefore, it is important to determine the concentrations of substances which occur naturally in a region of the site.

5.1.1 NEPM interim ecological investigation levels (EILs) The NEPM EILs are used as the basis for assessment where further investigation of the land may be necessary. Where investigation guidelines are not nominated in the NEPM or ANZECC Guidelines, reference is made to the Dutch investigation level guidelines (2000). The Dutch 2000 guidelines essentially replaces the Dutch 1994 guidelines and have been referenced where necessary as part of this audit. The NSW EPA (1994) criteria were used where there are no specified levels in the NEPM, ANZECC or Dutch guidelines.

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In general, the NEPM EILs are considered to protect most sensitive receptors and are known to be very conservative without any or very little scientific support. Where the levels of chemicals in soils are below the NEPM EILs, the condition of the land is considered to satisfy the requirements for protection of all beneficial uses (excepting groundwater quality). These guidelines provide the basis for further investigation of contamination for a range of chemicals and where exceeded a risk based review of the potential impact from environmental exposure for the proposed residential land use is considered appropriate.

TABLE 4 SEPP PREVENTION AND MANAGEMENT OF CONTAMINATION OF LAND – PROTECTED BENEFICIAL USES OF LAND

Land Use Recreation/ Parks & Agricultural Sensitive Use Commercial Industrial Beneficial use Reserves Open space High Other density Maintenance of ecosystems Natural ecosystems √ Modified ecosystems √ √ √ Highly modified ecosystems √ √ √ √ √ √ Human Health √ √ √ √ √ √ √ Buildings & structures √ √ √ √ √ √ √ Aesthetics √ √ √ √ √ Production of food, flora & √ √ √ fibre

TABLE 5 BASIS FOR ASSESSMENT OF LAND

Beneficial use Indicators Relevant Guidelines Interim Urban Ecological Investigation levels (EILs) Maintenance of Concentration of nominated in Schedule B(1) of the NEPM (1999) Assessment Ecosystems contaminants of concern of Site Contamination Guidelines Health Based Investigation Levels (HILs) for the relevant land Concentration of Human Health use as nominated in Schedule B(1) of the NEPM (1999) contaminants of concern Assessment of Site Contamination Guidelines pH, sulfate, redox Contamination must not cause the land to be corrosive to or Buildings and potential, salinity or other adversely affect the integrity of structures or building Structures substance materials Any contaminant that may Contamination must not cause the land to be offensive to the Aesthetics be offensive to the senses senses of human beings Contamination must not adversely affect produce quality or Production of yield, affect the level of any indicator in food, flora or fibre Concentration of food, flora and such that the level is greater than that specified by the contaminants of concern fibre Australian and New Zealand Food Authority Food Standards Code

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TABLE 6 NEPM ECOLOGICAL INVESTIGATION LEVELS – EILS & BACKGROUND RANGES LISTED IN THE NEPM

Metals/Metalloids Ecological Investigation Levels (mg/kg) Background Ranges (mg/kg) Arsenic 20 1-50 Barium 300 100-3000 Cadmium 3 1 Chromium (III) 400 Chromium (VI) 1 Chromium (total) * 5-1000 Copper 100 2-100 Cobalt 1-40 Lead 600 2-200 Manganese 500 850 Mercury (inorganic) 1 0.03 Nickel 60 5-500 Vanadium 50 20-500 Zinc 200 10-300

Note(s): * - valence state not distinguished – expected as Cr (III)

5.1.2 NEPM human health based soil investigation level guidelines (HILs) A review of health based soil investigation or guidance levels has been undertaken by Langley et al. (1995) through the “Third National Workshop on the Health Risk Assessment and Management of Contaminated Sites”. This provided a range of health based investigation levels considered to be safe for a range of generic land uses for Australia, including the sensitive uses. Exceedances of these guidelines do not mean the land is not safe, it means further investigation is required.

These guidelines have been published as Health Based Soil Investigation Levels (National Environmental Health Forum Monographs Soil Series No. 1, 1996). HILs which have been derived from the National Health Forum (1996) guidelines are included in Schedule B(1) of the NEPM. The NEPM HILs for selected contaminants are presented in Table 7 for a range of uses.

The HIL guidance should only be applied statistically and therefore where adequate characterisation of soil contamination has been completed. This requires that firstly data quality is acceptable and secondly that a representative sample data is provided. The data should also be interpreted in terms of background and natural variances in assumptions in the standard scenarios. The NEPM guidance requires the mean concentration of a contaminant be used as a basis for assessment.

The review by Langley et al. added that the level of any contaminant at a discrete location should not exceed the guidance value by more than 250 percent, and that the standard deviation of any contaminant across the site should be less than 50 percent of the guidance value. These statistical requirements for reviewing data against the guidelines have been adopted in the NEPM Schedule B(7a) - Guideline on health based investigation levels. Where 250% exceedances occur and the proposed development allows for no soil access

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Page 18 of 51 and a risk evaluation has taken place the Auditor considers assessing the results against the 95% UCL more appropriate in these situations.

TABLE 7 NATIONAL ENVIRONMENTAL HEALTH FORUM HEALTH-BASED SOIL INVESTIGATION LEVELS

SUBSTANCE Health-based Soil Investigation Levels (mg/kg) Exposure Settings A Ba Ca D E F Aldrin + Dieldrin 10 40 20 50 Arsenic (total) 100 400 200 500 Benzo (a) pyrene 1 4 2 5 Beryllium 20 80 40 100 Boron 3 000 12 000 6 000 15 000 Cadmium 20 80 40 100 Chlordane 50 200 100 250 Chromium (III) 12% 48% 24% 60% Chromium (VI) 100 400 200 500 Cobalt 100 400 200 500 Copper 1 000 4 000 2 000 5 000 Cyanides 500 2 000 1 000 2 500 (complexed) DDT+DDD+DDE 200 800 400 1 000 Heptachlor 10 40 20 50 Lead 300 1 200 600 1 500 Manganese 1 500 6 000 3 000 7 500 Methyl mercury 10 40 20 50 Mercury (inorganic) 15 60 30 75 Nickel 600 2 400 600 3 000 Total PAH 20 80 40 100 PCBs (total) 10 40 20 50 Phenol 8 500 34 000 17 000 42 500 TPH >C -C 16 35 90 360 180 450 aromatics TPH >C -C 16 35 5 600 22 400 11 200 28 000 aliphatics TPH >C35 56 000 224 000 112 000 280 000 Zinc 7 000 28 000 14 000 35 000

Exposure Setting(s): A ‘Standard’ residential with garden/accessible soil (less than 10% intake of home grown produce; no poultry): this category includes children’s day-care, pre-schools etc. B Residential with substantial vegetable garden (contributing up to 50% of vegetable and fruit intake) and poultry providing all dietary egg intake and 25% poultry meat intake. C Residential with substantial vegetable garden (contributing up to 50% of vegetable and fruit intake); poultry excluded. D Residential with minimal opportunities for soil access includes high-rise apartments and flats. E Parks, recreational open space and playing fields: includes secondary schools. F Commercial/Industrial: includes premises such as shops and offices as well as factories and industrial sites. (If, however, a commercial site is also used for residential purposes or regular soil access by children if possible then the appropriate ‘residential’ setting should be used.) It is assumed that thirty years is the duration of exposure. a Site and contaminant specific

A review of the likely site uses and receptors confirms that the assumptions behind the standard scenarios are valid.

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As NEPM guidelines do not include health-based criteria for MAH and TPH, threshold concentrations for sensitive land-use were provided by the NSW EPA Guidelines for Assessing Service Station Sites (1994).

5.2 Off-site disposal The surface soils at the site have been excavated for the purpose of disposal off site. Where soil is to be disposed off site, LRM Global has assessed the soil against the criteria provided in the Victorian EPA Publication 448.3 Classification of Wastes.

5.3 Adopted site criteria for in-situ soil The proposed future use of the site is commercial/high density residential. However, irrespective of the proposed land-use, an environmental auditor must assess a site from the context of ‘Sensitive Use’. Therefore in accordance with SEPP (2002) Prevention and Management of Contamination of Land, it is appropriate to assess the site against the following protected beneficial uses: • modified ecosystems; • highly modified ecosystems; • human health; • buildings and structures; • aesthetics; and • production of food, flora and fibre.

5.3.1 Modified and highly modified ecosystems For the protection of the environment, LRM Global refers to the NEPM EILs.

5.3.2 Human Health For the protection of human health, LRM Global refer to the NEPM HILs for standard residential use (Column A) and residential with minimal soil access (Column D).

5.3.3 Aesthetics LRM Global do not comment on aesthetic considerations for the site. The Auditor notes that there are no aesthetic based criteria for soils. The protection of aesthetics requires that the land must not be offensive to the senses of human beings.

5.3.4 Production of food, flora and fibre LRM Global has not provided criteria for the protection of the beneficial uses: protection of buildings and structures, or production of food, flora and fibre, as these have been considered irrelevant under the proposed development. The Auditor agrees that these criteria are not relevant to the proposed development. However in order to assess the site for the issue of a Certificate of Environmental Audit (CoEA), the Auditor has supplied criteria for these protected beneficial uses.

For the protection of production of food, flora, and fibre, the NEPM EIL criteria have been adopted, as these criteria are provisionally based on phytotoxicity.

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5.3.5 Buildings and structures For the protection of buildings and structures the SEPP requires that contamination must not cause the land to be corrosive, or to adversely impact the integrity of structures or building materials. Australian Standard AS3600 – Concrete Structures states that permeable soils with a pH of less than 4 are considered aggressive and detrimental to concrete structures. The NEPM 1999 sets a sulfate level of 2,000 mg/kg for protection of buildings and structures.

LRM Global assessed the potential impact of soil on buildings and structures on the basis of pH and sulfate concentration.

5.4 Adopted site acceptance criteria for groundwater The SEPP (1997) — Groundwaters of Victoria provides the framework for the protection of groundwater and associated beneficial uses throughout Victoria. The policy allows for a consistent approach to the prevention of contamination of groundwater and clean-up of pollution of groundwater throughout Victoria and sets environmental quality indicators and objectives for each beneficial use. The SEPP defines certain aquifer categories based on salinity reported as total dissolved salts (TDS) and associated beneficial uses to be protected. The beneficial uses of groundwater to be protected are dependant on the proposed land-use and are shown in Table 8.

TABLE 8 SEPP GROUNDWATERS OF VICTORIA BENEFICIAL USES BASED ON TOTAL DISSOLVED SALTS (TDS)

Segments (mg/L TDS)

Beneficial Uses A1 (0- A2 (501- B (1001- C (3501- D 500) 1000) 3500) 13000) (>13000)

1. Maintenance of ecosystems √ √ √ √ √

2. Potable Water supply:

Desirable √

Acceptable √

3. Potable mineral water supply √ √ √

4. Agriculture, parks & gardens √ √ √

5. Stock watering √ √ √ √

6. Industrial water use √ √ √ √ √

7. Primary contact recreation (eg. √ √ √ √ √ bathing, swimming)

8. Buildings and structures √ √ √ √ √

The Authority (EPA) may determine that these beneficial uses do not apply to groundwater when: • there is insufficient yield; • the background level of a water quality indicator/s other than TDS precludes a beneficial use; • the soil characteristics preclude a beneficial use; and

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• a groundwater quality restricted use zone (GRUZ) has been declared by the EPA.

In addition, any assessment of the likelihood of the particular beneficial uses of groundwater being realised should be based on an evaluation of whether an owner/occupier of the site, or in the vicinity of the site, may reasonably expect to use or be able to use groundwater for the above purposes, having regard to existing and future land-use.

For this site the most sensitive beneficial use to be protected is the freshwater ecosystem, in particular the nearest down hydraulic gradient surface water body (Yarra River), located 1.5km north of the site.

Where the SEPP Groundwaters of Victoria (GoV) does not specify contaminant limits, ANZECC/ ARMCANZ (2000) and NEPM (1999) Groundwater investigation levels (GILs) are consulted. In Victoria the NEPM levels are generally used in preference to ANZECC/ ARMCANZ criteria for all beneficial uses other than ecological receptors. The reason for this is that the ecological receptor for an aquifer is the nearest surface receiving water or discharge zone for that aquifer, which is controlled under the SEPP Waters of Victoria (WoV). The SEPP WoV refers to ANZECC/ ARMCANZ 2000. The NEPM GIL’s presented within Schedule B(1) Table 5-B are essentially based on ANZECC (1992).

The SEPP Groundwaters of Victoria states that in order to protect the beneficial uses associated with Segment B (relevant to this site) the following should be referred to: • Maintenance of ecosystems – criteria specified for protection of fresh water ecosystems in ANZECC/ ARMCANZ 2000; • Potable mineral water supply – criteria specified in Australian Food Standards Code 1987 – Standard 08 Mineral water; • Stock watering and agriculture parks and gardens – those specified for irrigation and livestock in NEPM Schedule B(1) Table 5-B; • Industrial Water Use – those specified for industrial use in the ANZECC 1992 guidelines; • Primary Contact Recreation – those specified for primary contact recreation in the ANZECC 1992 guidelines; and • Buildings and Structures – introduced contaminants shall not cause groundwater to become corrosive to structures or building materials. Sulphate concentration greater than 1000mg/L is considered aggressive to concrete structures and a pH below 4.

A protected beneficial use may not apply at a site where background concentrations of a substance are greater than the relevant guideline. Therefore, if contamination is expected, it is important to determine the concentrations of substances which occur naturally in groundwater in the region of the site.

6 ASSESSMENT OF SITE CONDITIONS

6.1 Scope of audit LRM Global was commissioned by David Rogalsky, Construction Manager of Asian Pacific Building Corporation to undertake a preliminary environmental site assessment and an

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The following reports were reviewed as part of this environmental audit report: • Douglas Partners (March 2006) Limited Contamination Assessment; • LRM Global (October 2006) Hazardous Materials Risk Assessment report; • LRM Global (August 2007) Phase 1 Environmental Site Assessment; • LRM Global (April 2008) Phase 2 Environmental Site Assessment; and • LRM Global (October 2008) Phase 2 Hydrogeological Assessment; • Environmental Earth Sciences (October 2008) CUTEP Submission; and • EPA Victoria’s letter dated 31 October 2008 in response to the CUTEP Submission.

The scope of this audit included the following: • liaison with the client and the assessor; • review of sampling and analytical plans including QA/QC objectives; • detailed review of the LRM Global reports (both draft and final versions); • site inspection on 22 March 2007 during installation of on-site groundwater boreholes and detailed site soil assessment; • site inspection on 11 September 2007; • site inspection on 2 October 2008 and the collection of two auditor verification groundwater samples; • review of audit reports in close proximity to the site; • review of quality and completeness of the reports; • assessment of the environmental condition of the site; • evaluation of nature and extent of risks to the beneficial uses of the site; • preparation of the environmental audit report in the form required by the EPA; and • the issue of a Certificate or Statement of Environmental Audit.

6.2 Review of LRM Global investigations The overall assessment of 160-162 Commercial Road, Prahran was undertaken by LRM Global from December 2006 to October 2008 and involved: • a desk top review of site history and geological and hydrogeological information, and of a previous site contamination assessment; • a hazardous building materials survey; • review of audit reports within the immediate vicinity of the site (one in total); • a search of the groundwater database to assess whether registered groundwater bores or users existed in the vicinity of the site; • a site inspection to identify any potentially contaminating activities and/or potentially contaminated areas at the site;

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• soil sampling and analysis in order to assess the soil for the purposes of on-site reuse and off-site disposal; • installation of four on-site groundwater monitoring boreholes (MW01 to MW04) and undertaking three rounds of sampling at these locations between April 2007 and April 2008; • supervision of soil excavation, remediation and validation works; • validation testing to confirm the condition of the remaining soil at the site; • installation of five off-site groundwater monitoring boreholes (MW05 to MW09) and undertaking between one and two rounds of sampling at these locations in September 2008; • data assessment; and • an appraisal of results against the beneficial uses to be protected in the form of three reports: o a Phase 1 Environmental Site Assessment; o a Phase 2 Environmental Site Assessment; and o a Phase 2 Hydrogeological Assessment.

6.2.1 Review of nearby environmental audit As part of LRM Global’s assessment, one available environmental audit report within the vicinity of the site was reviewed. This was undertaken to assist in determining the presence of off-site sources of soil and groundwater contamination and to assist in determining background or regional contaminant concentrations.

The nearby audit occurred at Lots 1-25, Balmoral Place, Prahran approximately 50m north of the site and was undertaken by Sinclair Knight Merz (SKM) in 1999. This site history was not discussed by LRM but is thought to be similar to the site due to its proximity. The assessment works indicated that the soil was impacted with heavy metals and PAH below 3.5m and in the groundwater at approximately 6m. An EMP for groundwater use was required to prevent groundwater abstraction and use on site. As part of the investigation 12 groundwater monitoring bores were installed and sampled and indicated that the groundwater flow direction was in a northerly direction towards the Yarra River. A Certificate of Environmental Audit was issued for Lots 8-25, and a Statement of Environmental Audit was issued for Lots 1-7.

In addition, and as discussed in the CUTEP submission report (Environmental Earth Sciences 2008), Environmental Earth Sciences has issued audits for nearby sites located in Charles Street Prahran, Bond Street South Yarra and Chapel Street SouthYarra. Further, Environmental Earth Sciences has assessed sites where audits have been or are being issued (43 Upton Road Winsor, 12 Ellis Street South Yarra, 22-24 Wilson Street South Yarra). As such, an understanding of geological and contamination issues in the surrounding area has been developed.

6.2.2 LRM Global soil investigation and classification assessments A Phase 2 environmental site assessment (ESA) was undertaken on the site, with field work occurring between 13 and 14, and 22 and 23, March 2007. Eleven locations were assessed at this time using mechanical drill rig equipped with a push tube sampling head, or hand auger depending on accessibility to a maximum depth of 7.0 mBGL. These locations are shown on the attached Figure 2 as boreholes BH132-1 to BH132-6, BH132-9, BH132-11, BH132-12, BH132-A and BH132-B. An Auditor’s representative was present on-site during

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Page 24 of 51 this sampling program (22 March 2007). A total of 28 soil samples (excluding QA samples) were collected by the assessor at this time with all samples undergoing laboratory analysis.

Following the completion of the Phase 2 ESA, approximately 5,000 m3 of soil was removed from the site to create the space for the proposed basement car park. The soil classification requirements for off-site disposal were determined using the soil samples collected from during the Initial site assessment.

Based on the initial soil sampling event the soil across the site was classified as either ‘Category C waste’ or ‘Fill Material’ though more specific details regarding volumes have not been supplied by LRM. This material was subsequently disposed according to its waste category by appropriately licensed trucks delivering the soil to Western Land Reclamation Pty Ltd at Brooklyn, a licensed premise, using waste transport certificates. The Auditor has not seen these certificates, only the landfill receipt dockets.

Based on EPA VIC Publication 1178, for a volume of material in the range of >5,000 m3, waste characterisation samples should be collected at a rate of one sample per 250 m3. Therefore the minimum number of samples which would be required to classify this volume of material should have been 20. As such the site soil classification works undertaken do comply with this density, as 28 samples were collected and analysed. In addition, a further eight samples underwent analysis for TPH/BTEX (two samples also analysed for heavy metals), and two for lead and TPH leachability (ASLP) in April 2008, prior to off-site soil disposal.

Soil sampling was conducted both from boreholes constructed with a solid flight auger (SFA) drilling rig and hand auger. Representative samples were collected from both the fill and natural material at the site. Soil samples were collected in 250 mL glass sample jars and stored in a cool dark environment, prior to being forwarded to the laboratory. A calibrated photo ionisation detector (PID) was used during all stages of soil sampling.

It is the opinion of the Auditor that the sampling and analytical program for the soil was adequate to characterise the nature of the material which required excavation from the site. Overall the sampling and analytical methodology was considered to be satisfactory for the purpose of off-site characterisation. In addition a member of the Auditor’s team conducted a site visit on 22 March 2007 to check on the field investigation. The Auditor was satisfied with the sampling methods followed. The Auditor’s assistants collected two groundwater verification samples, and comparison of the verification samples and the assessor’s results from the same locations showed good agreement (Appendix B). Overall the Auditor considers that the sampling and analysis plan was sufficient to characterise material on the site, with reference to EPA Publication 1178.

6.2.3 Excavation works A total of approximately 5,000 m3 of soil was excavated from the site for off-site disposal as either Fill Material or Category C waste.

6.2.4 LRM Global validation sampling After excavation of the building platform, LRM Global conducted a round of validation sampling on the final soil surface across the site. Validation sampling consisted of the collection of nine primary soil samples from the exposed basement floor (five samples) and each wall (four samples), along with one field duplicate and one split duplicate QA/QC samples. In addition, three boreholes (W1, W2 and W3) were installed just outside the eastern northern and southern boundaries respectively. Sixteen discrete samples and one blind duplicate were analysed from these locations.

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For a site of 1,244 m2 AS4482.1 (2005) recommends a minimum acceptable sample number of six to seven samples. Therefore the Auditor considers that this sampling density is sufficient for the purposes of validation of the excavation.

6.2.5 LRM Global groundwater assessment A total of four on-site and five off-site groundwater monitoring boreholes were installed as part of the groundwater assessment. The locations of these boreholes are provided on Figure 2. A first round of groundwater sampling was conducted on on-site boreholes (MW01 to MW04) on 27 March 2007, a second round was conducted on 4 September 2007, and a third round was conducted on 7 April 2008 by MGT Environmental Consulting Pty Ltd (MGT). Off-site boreholes (MW05 to MW09) were sampled on 6 and 26 September 2008. Groundwater samples were collected using a micro-purge sampling system and have been analysed for a wide range of inorganic and organic chemicals of potential concern.

The summary of the results of the groundwater sampling is presented in LRM Global (October 2008) Phase 2 Hydrogeological Assessment. In the auditors opinion the groundwater analysis undertaken at the site is sufficient for the purposes of this investigation, including assessment of the requirement for a Cleaned-Up To the Extent Practicable (CUTEP) application. A CUTEP submission was made by the Auditor to EPA Victoria on 14 October 2008. EPA Victoria completed their CUTEP determination on 31 October 2008.

Based on the review of regional geology, and based on the results of on-site groundwater characterisation, LRM Global has classified groundwater as Segments A2 to B. The Auditor concurs with this classification, based on on-site, off-site and regional assessment of the groundwater within the Brighton Group formation.

Protected beneficial uses of Segment B groundwater include: • maintenance of ecosystems; • potable water (acceptable); • potable mineral water supply; • agriculture, parks and gardens; • stock watering; • industrial water use; • primary contact recreation; and • buildings and structures.

Segment A2 also includes “acceptable potable water supply” in addition to the above. LRM Global has considered the beneficial uses at the site not likely to be realised for the following reasons: • Maintenance of ecosystems – no nearby water bodies in a sealed urban area with a highly modified ecosystem, hence this beneficial use is not likely to be realised; • Acceptable potable water supply – unlikely given low aquifer yield and available reticulated supply of water; • Buildings and structures – unlikely given depth of groundwater is greater than 6 m, pH is >6.3, chloride is <120 mg/L and sulfate concentrations are <200 mg/L;

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• Industrial – unlikely given that a high quality low cost reticulated water is available on industrial sites in the area, and groundwater yield may not be sufficient for such use; • Stock watering – unlikely given the urban setting of the site and high quality low cost reticulated water is available in the area, and groundwater yield may not be sufficient for such use; • Primary contact recreation – unlikely given the low potential for groundwater emanating from the site to discharge in significant volumes at the Yarra River (the nearest potential recreational water). Abstraction of groundwater for swimming pool use is unlikely given that high quality low cost reticulated water is available, and groundwater yield may not be sufficient for such use; • Agriculture, parks and gardens (Irrigation) – unlikely given that a high quality low cost reticulated water is available in the area, that groundwater yield may not be sufficient for such use, and given the urban setting of the site; and • Potable mineral water – unlikely and not in a recognised potable mineral water zone.

Groundwater results LRM Global has provided a summary of the groundwater results compared to relevant criteria for the segment. Based on LRM Global’s assessment of their results over five rounds of monitoring, the following exceedances have occurred:

Round One (April 2007) MW01 (on-site) TPH C6-C9, TPH >C9, benzene, ethyl-benzene, 1,2,4-trimethylbenzene (TMB), 1,3,5-TMB, naphthalene, arsenic. MW02 (on-site) TPH C6-C9, benzene, 1,2,4- TMB, 1,3,5-TMB, aluminium, arsenic, chromium, iron, nickel. MW03 (on-site) TPH C6-C9, TPH >C9, BTEX, 1,2,4-TMB, 1,3,5-TMB, naphthalene, arsenic, iron, manganese. MW04 (on-site) nitrate, mercury and nickel.

Round Two (September 2007) MW01 (on-site) TPH C6-C9, benzene, ethyl-benzene, 1,2,4-TMB, 1,3,5-TMB, naphthalene, arsenic, iron. MW02 (on-site) TPH C6-C9, benzene, 1,2,4-TMB, 1,3,5-TMB, arsenic. MW03 (on-site) TPH C6-C9, BTEX, 1,2,4-TMB, 1,3,5-TMB, naphthalene, arsenic, iron, manganese. MW04 (on-site) nitrate and nickel.

Round Three (April 2008) MW02 (on-site) arsenic, iron. MW03 (on-site) TPH C6-C9, benzene, toluene, ethyl-benzene, 1,2,4-TMB, 1,3,5-TMB, naphthalene, arsenic, iron. MW04 (on-site) nitrate, pH, iron.

Round Four (early September 2008) MW05 (off-site) aluminium, iron. MW06 (off-site) aluminium, nitrate.

Round Five (late September 2008) MW07 (off-site) aluminium, nitrate. MW08 (off-site) aluminium, nitrate. MW09 (off-site) aluminium, iron, nitrate.

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Auditor Verification Monitoring (October 2008) MW05 (off-site) aluminium, iron. MW06 (off-site) aluminium, iron, nitrate.

The Auditor notes that the apparent detection of dissolved aluminium is likely to be a false positive due to the groundwater pH being >6.3 throughout. Likewise, detection of dissolved metals during all rounds of sampling are also likely to be false positives due to the high level of sediment in the collected samples, and the subsequent inability of the laboratory to remove this sediment prior to sample preparation and analysis. The exception to this is dissolved arsenic (As), which is a non-metallic element (Hem 1992 pp144-145) whose solubility is less pH dependent than many of the dissolved metals detected (Drever 1997 pp192-194).

Dissolved arsenic was detected in groundwater at monitoring well MW01 at a concentration of 0.18 mg/L in September 2007, after which this borehole was decommissioned. Monitoring well MW03 also contained 0.10 mg/L arsenic at the same sampling event, while monitoring well MW02 contained 0.021 mg/L, and monitoring well MW04 detected 0.003 mg/L. These results correlate with elevated dissolved iron and (to a lesser extent) manganese, as well as reducing conditions. A summary of these results is provided in Table 9 to illustrate the relationships discussed.

TABLE 9 ARSENIC, IRON, MANGANESE AND REDOX – SEPTEMBER 2007

Analyte/Borehole Units MW01 MW02 MW03 MW03 Split MW04

Arsenic mg/L 0.18 0.021 0.10 0.099 0.003

Iron mg/L 11 0.18 16 21 0.07

Manganese mg/L 0.30 0.056 0.67 0.68 0.007

Redox mV -105 -68 -159 - 23

The interpretation of these results is that reducing conditions in the hydrocarbon plume centre at the site have caused the reduction and dissolution of FeIII(s) to FeII(aq) and As(V)(s) to As(III)(aq). These processes are described in the literature, including Ravenscroft et al. (2005), Schreiber et al. (1999) and Haque and Johannesson (2006).

Accordingly, a Groundwater Quality Management Plan (GQMP) needs to be provided within 30 days from the date of this audit report, and specify that the groundwater monitoring program include field determination of redox, and analysis for dissolved heavy metals (including Fe and Mn) and As in addition to chemicals of potential concern (as a minimum), and that monitoring well MW05 in particular be monitored closely for the occurrence of these processes.

Inorganic groundwater results show that groundwater beneath the site is neutral to slightly - acidic, fresh (TDS ≤1100 mg/L), Na-HCO3 dominated, with elevated nitrate (NO3 ) in boreholes MW04, MW06, MW07, MW08 and MW09. The fact that groundwater is fresh points to a local source of recharge (i.e. contamination), as regionally this water-bearing zone is usually brackish (Environmental Earth Sciences 2007 and 2008b). This conclusion is supported by fluoride (F-) levels, which are in the expected range for treated waters and greater than those expected for most natural groundwaters.

- As elevated NO3 has been detected in up-gradient monitoring wells MW04 and MW06 it may be concluded that it is not sourced from the site, and is ubiquitous in groundwater within the

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Brighton Group in this area. This is confirmed by results from Environmental Earth Sciences 2008b (range of 33-282 mg/L for five boreholes) and Environmental Earth Sciences 2007 - (NO3 concentration of 71 mg/L).

6.3 Auditor inspections and verification sampling The Auditor or Auditor’s representative inspected the site on 22 March 2007, 11 September 2007 and 2 October 2008. At these times the property and adjacent properties were inspected. During the March 2007 inspection the field work for the Phase 2 ESA (including groundwater bore installation) was being undertaken, while during the October 2008 inspection two Auditor verification groundwater samples were collected for analysis from boreholes MW05 and MW06 (see Figure 2). The verification samples were tested for dissolved heavy metals, pH, TDS, cations and anions, and a wide suite of volatile organic compounds.

All chemicals tested were at acceptable concentrations with the exception of dissolved aluminium (Al) in monitoring wells MW05 and MW06 and nitrate in monitoring well MW06. As discussed above, the Al is considered a false positive and the nitrate is characteristic of the aquifer in this region.

7 EVALUATION OF QUALITY AND COMPLETENESS

Quality assurance and quality control (QA/QC) procedures were undertaken by LRM Global throughout the assessment. QA/QC data is discussed specifically within Section 13.0 of the LRM Global Phase 2 Environmental Site Assessment report and Appendix J of the LRM Global Phase 2 Hydrogeological Assessment report. A review of these procedures and completeness has been undertaken by the Auditor as discussed below.

7.1 Sample density and site coverage

7.1.1 Environmental site assessment Eleven locations were assessed as part of the Phase 2 ESA, using soil coring techniques, or hand augering depending on accessibility, to a maximum depth of 7.0 mBGL. The sampling points were selected on a grid basis as well as judgmental basis in areas of potential contamination (around USTs). These locations are shown on the attached Figure 2 as boreholes BH132-1 to BH132-6, BH132-9, BH132-11, BH132-12, BH132-A and BH132-B. An auditor’s representative was present on-site during a portion of this sampling program. A total of 28 soil samples (excluding QA samples) were collected by the assessor at this time. According to AS4482.1 (2005) and AS4482.2 (1999), this density, QA sample collection program, and sampling strategy is considered appropriate.

7.1.2 Waste classification Based on EPA VIC Publication 1178, for a volume of material of 5 000 m3, waste characterisation samples should be collected at a rate of one sample per 250 m3 (at least 20 samples and statistical evaluation of the data). A total of 28 samples were analysed to classify the soil for off-site disposal during the first round of soil sampling to depths of up to 7.0 mBGL. This program is considered appropriate.

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7.1.3 Validation sampling Validation sampling consisted of the collection of five primary soil samples from the exposed basement floor, one from each wall and two QA/QC duplicate samples. In addition, three boreholes (W1, W2 and W3) were installed just outside the eastern northern and southern boundaries respectively. Sixteen discrete samples and one blind duplicate were analysed from these locations. All validation sample locations are provided on Figure 3 of this report.

Of the 25 validation samples analysed from the site, all were tested for TPH and BTEX, 10 for lead, four for PAH compounds, three for phenols/TCE and two for a screen of 14 heavy metals. The Auditor considers that this sampling density is sufficient for the purposes of validation of the excavation.

The results of the validation sampling are presented in Table 10 of LRM Global’s Phase 2 ESA report, and locations shown on Figure 4 of their report. The results of the analysis indicate that all detection concentrations are below the adopted NEPM (D) HIL guidelines. The laboratory results for the validation samples are also within NEPM EIL’s and NEPM (A) HIL’s.

7.2 Analytical schedule and completeness

7.2.1 Soil assessment and classification for off-site disposal During the initial ESA a total of 28 primary samples, five blind duplicate samples and five rinsate samples were collected. The analytical schedules are presented in Table 10. All samples were analysed for a range of chemicals of potential concern (CoPC) primarily including: metals, MAH, pH, OCP, PCB phenols and TRH. The Auditor considers the initial round of analysis was sufficient to characterise the chemicals of concern at the site, as presented in Tables 7 and 8 of the LRM ESA.

TABLE 10 ANALYTICAL SCHEDULE – ASSESSMENT AND WASTE CLASSIFICATION

Number of samples Analytes Assessment (13-14 March 2007) Metals (arsenic, cadmium, chromium, cobalt, copper, lead, mercury, 1 molybdenum, nickel, selenium, tin and zinc) 9 (+ 1 dup, 3 rinsate) Metals (antinomy, arsenic, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, molybdenum, nickel, selenium, tin, zinc) 8 Lead 2 PAHs (16 priority) 1 PCB 2 Phenols 9 pH 28 (+ 4 dup, 2 rinsate) TPH/BTEX 1 448.1 screen (TPH/MAH, VHCs, Phenols, PCBs, OCPs, metals, Total Cyanide, Total Fluoride, Hexavalent Chromium) Additional Waste Classification (1 April 2008) 8 TPH/BTEX 2 ASLP Lead and TPH

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Waste transport documentation has been provided to the Auditor by LRM Global as Appendix J of the Phase 2 ESA report.

In the Auditor’s opinion the analytical program for soil was adequate to characterise the material for disposal, in accordance with EPA Victoria Publications 448.3 and 1178. This conclusion is confirmed by the material being accepted as appropriately classified for disposal by facilities licensed to accept such waste.

7.2.2 Validation sampling Validation sampling involved the collection and analysis of five soil samples from the base of the final excavation and one on each wall. The soil classification assessment identified metals, TPH and BTEX to be the primary chemicals of concern at the site.

All nine primary validation samples and one blind duplicate and one split duplicate sample were analysed for TPH/BTEX, with a trip sample being analysed for BTEX and two primary samples also for heavy metals. The analytical schedules for the first round of validation sampling are presented in Table 11.

The second round of validation sampling was undertaken through the assessment of three further boundary locations W1, W2 and W3 as shown on Figure 3. Collected soil samples were analysed from 16 discrete locations as detailed in Table 11, and as follows: • seven samples from validation location W1 from 1.5 to 5.0 metres depth for TPH/BTEX (7 samples), lead (4 samples), PAH (2 samples), phenols (1 sample) and TCE (1 sample); • four samples from validation location W2 from 1.0 to 4.0 metres depth for TPH/BTEX (4 samples), lead (2 samples), PAH (1 sample), phenols (1 sample) and TCE (1 sample); and • five samples from validation location W3 from 1.0 to 5.0 metres depth for TPH/BTEX (5 samples), lead (2 samples), PAH (1 sample), phenols (1 sample) and TCE (1 sample).

TABLE 11 ANALYTICAL SCHEDULE – VALIDATION SAMPLES

Number of samples Analytes First Round (2 June 2008) 9 (+ 1 dup, 1 split) TPH/BTEX 1 trip BTEX 2 Metals (antinomy, arsenic, beryllium, cadmium, chromium, cobalt, copper, lead, mercury, molybdenum, nickel, selenium, tin, zinc) Second Round (19 August 2008) 16 (+ 1 dup, 1 rinsate) TPH/BTEX 8 Lead 3 Phenols/TCE 4 PAH 1 trip VOC

Given that chemicals of potential concern had already been identified in the soil classification assessment, the Auditor is satisfied that the sampling density and analytical program was sufficient to characterise the material remaining at the site.

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7.2.3 Groundwater sampling Groundwater sampling involved the installation of four on-site groundwater bores (MW01- MW04) and the collection of samples from these bores over four sampling rounds (27 March 2007, 4 September 2007 and 7 April 2008). An additional five off-site boreholes (MW05- MW09) were installed and sampled between one and three times during September and October 2008. The Auditor’s team conducted verification sampling on off-site monitoring wells MW05 and MW06 on 2 October 2008. Thus, in total, six rounds of monitoring (including Auditor verification sampling) were undertaken.

Groundwater analysis for all sampling rounds involved the collection and analysis of primary samples, one duplicate sample, one split sample and one rinsate sample for dissolved metals, pH, TDS, cations and anions, TPH, SVOCs and VOCs. A summary of the analytical schedule for each round is provided in Table 12.

TABLE 12 ANALYTICAL SCHEDULE – GROUNDWATER SAMPLES

Number of samples Analytes Round 1 (27 March 2007) 4 (1 dup, 1 split) Dissolved metals (Al, As, Cd, Cr, Cu, Fe, Pb, Ni, Mn, Hg, Zn) 4 (1 dup, 1 split) pH, TDS, cations and anions, BOD, TOC, COD 4 (1 dup, 1 split) VOC, SVOC, TPH 1 rinsate TPH, VOC Round 2 (4 September 2007) 4 (1 dup, 1 split) Dissolved metals (Al, As, Cd, Cr, Cu, Fe, Pb, Ni, Mn, Hg, Zn) 4 (1 dup, 1 split) pH, TDS, cations and anions, BOD, TOC, COD 4 (1 dup, 1 split) VOC, SVOC, TPH 1 rinsate TPH, VOC Round 3 (7 April 2008) 3 (1 dup, 1 split) Dissolved metals (Al, As, Cd, Cr, Cu, Fe, Pb, Ni, Mn, Hg, Zn) 3 (1 dup, 1 split) pH, TDS, cations and anions, BOD, TOC, COD 3 (1 dup, 1 split) VOC, SVOC, TPH 1 rinsate TPH, VOC Round 4 (6 September 2008) 2 (1 dup, 1 split) Dissolved metals (Al, As, Cd, Cr, Cu, Fe, Pb, Ni, Mn, Hg, Zn) 2 (1 dup, 1 split) pH, TDS, cations and anions, BOD, TOC, COD 2 (1 dup, 1 split) VOC, SVOC, TPH 1 rinsate TPH, VOC Round 5 (26 September 2008) 4 (1 dup, 1 split) Dissolved metals (Al, As, Cd, Cr, Cu, Fe, Pb, Ni, Mn, Hg, Zn) 4 (1 dup, 1 split) pH, TDS, cations and anions, BOD, TOC, COD 4 (1 dup, 1 split) VOC, SVOC, TPH 1 rinsate TPH, VOC Round 6 (2 October 2008 – Auditor verification sampling) 2 (1 dup, 1 split) Dissolved metals (Al, As, Cd, Cr, Cu, Fe, Pb, Ni, Mn, Hg, Zn) 2 (1 dup, 1 split) pH, TDS, cations and anions 2 (1 dup, 1 split) VOC, TPH 1 rinsate, 1 trip TPH, BTEX

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The Auditor considers that the sampling density and selection of analytes was sufficient to characterise groundwater beneath and about the site.

7.3 Measurement data quality objectives A review of the quality of data from the LRM Global Environmental Site Assessment reports was undertaken by the Auditor. The review was based on the following requirements: • review of the sampling methodology in accordance with all current guidelines; • review the analytical results against field observations; • analysis of 5% blind duplicates, 5% split duplicates, and compliance with relative percentage differences; • analysis of appropriate rinsate samples; • review of data quality based on verification of field QA/QC procedures, correct sample containers and completed chain of custody documentation; • review of correct sample analysis including the extraction and analysis within appropriate holding times; • review of the laboratory detection limits; and • review the internal laboratory QA/QC analysis including reagent blanks, spike recoveries and duplicates.

These requirements are defined in AS4482.1 (2005) and EPA Victoria guidelines.

7.4 Sampling methodology

7.4.1 Soil sampling During the initial Phase 2 ESA soil samples were collected using a solid flight auger with split spoon sampling mechanism or hand auger depending on accessibility. During the first round of sampling soil bores were drilled to a depth of up to 7.0 mBGL with an average of approximately 2.5 mBGL. Care was taken to ensure samples were not taken from material in direct contact with sampling equipment. Samples collected during the validation program were collected by hand, and cross contamination was prevented by the use of disposable gloves and a clean spatula that was cleaned between sampling locations.

Soil samples were immediately transferred to clean and appropriately labelled glass jars. These jars were stored in a cool dark place, until such time as they could be transferred to the laboratory.

The sampling strategy was developed on a roughly grid based pattern, with additional samples collected from areas of concern, and is consistent with the sampling requirements set out in AS4482.1 (2005).

7.4.2 Groundwater borehole installation and sampling Four on-site and five off-site groundwater monitoring bores were installed at and about the site using a drill rig with a 100 mm diameter solid flight auger. When groundwater was encountered, drilling continued until sufficient groundwater was intersected for monitoring purposes. The bores utilised a single standpipe piezometer using 50 mm Class 18 uPVC

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Page 33 of 51 casing and a slotted screen. The bores were then packed with sand, sealed with bentonite, and grouted to the surface. Following installation the groundwater bores were developed.

Groundwater well log sheets are presented in Appendix E of the LRM Global Hydrogeological Assessment report, while groundwater sampling data sheets are presented in Appendix K. Prior to each round of sampling, the groundwater bores were purged and sampled using a MicroPurge low flow sampling technique. During the purging process temperature, electrolytic conductivity (EC), pH, redox (ORP) and dissolved oxygen (DO) was recorded. Field chemistry and sample collection data sheets are presented in Appendix K of the LRM Global Phase 2 Hydrogeological Assessment report, which indicates that samples were collected once readings stabilised where sufficient yield was available to purge sufficient volumes of water.

One rinsate blank sample was collected during each round of groundwater sampling. The purpose of the rinsate sample is to ensure that equipment decontamination is adequate.

Rinsate samples were analysed for all the analytes listed in Table 12 above. All results were below laboratory detection limits, indicating that cross contamination did not occur during sampling, and that equipment decontamination was adequate. The results of these samples are presented in the laboratory transcripts in Appendix K of the LRM Global Phase 2 Hydrogeological Assessment report. All samples were analysed at NATA accredited laboratories (MGT and ALS).

7.5 Field quality assurance and quality control The chain of custody forms presented in the LRM Global report are clear and identify each sample, nature of the sample, collection date, analyses to be performed and departure date from the site and signature.

Copies of the field bore logs were presented in Appendix C of the LRM Global Environmental Site Assessment and comply with the information expected to be found in bore logs including soil description, PID results, date, name of sampler. A PID was used during the soil sampling. Calibration records have been provided for the PID, as well as calibration methodology documentation has been provided in Appendix E.

Rinsate samples were collected during each round of groundwater sampling, and during each day of soil sampling.

The Auditor notes that LRM Global collected blind and split duplicates in the appropriate way as stipulated in AS4482.1. The frequency of split and blind duplicate sample collection is presented in Tables 10 to 12. It is noted that in total 78 samples (soil and groundwater) were collected by the assessor for this project, with 12 blind duplicates, six split duplicates, 11 rinsate blanks and two trip blanks being analysed for comparison. It is also noted that the soil off-site disposal data set was considered appropriate for waste classification purposes by the licensed disposal facility accepting this material.

7.6 Laboratory quality assurance and quality control Chain of custody forms have been completed appropriately acknowledging date sent, receipt date and time by the laboratories, identity of samples were presented with the original laboratory transcripts and indicate satisfactory transit times. Primary samples and blind duplicate samples were analysed by MGT Laboratories, while split duplicate samples were analysed by ALS. The Auditor confirms that both MGT and ALS are NATA accredited for the

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Page 34 of 51 majority of analysis performed. Details of this accreditation can be viewed at http://www.nata.asn.au/.

As part of MGT internal QA /QC the following was undertaken: • sufficient internal duplicate analyses were undertaken with RPD’s reported; • sufficient blanks analyses were conducted; • samples were analysed within the appropriate holding times; • samples were analysed within the appropriate detection limits; and • sufficient spikes on reagent and the soil matrix were undertaken with percent recoveries reported.

As part of ALS internal QA /QC the following was undertaken: • sufficient blanks analyses were conducted; • samples were analysed within the appropriate holding times; • samples were analysed within the appropriate detection limits; and • sufficient spikes on reagent and the soil matrix were undertaken with percent recoveries reported.

7.7 Blind and split duplicate evaluation LRM Global has collected split and blind duplicate samples during all sampling rounds. The results of sampling duplicate comparisons for soil and groundwater are presented in Tables 11 and 12 of the Environmental Site Assessment and in Appendix J of the Hydrogeological Assessment (Tables 7, 8 and 9) respectively. The Auditor has reviewed these results, and is satisfied with their accuracy.

7.7.1 Soil assessment and waste classification During the site investigation a total of 11 primary samples, one blind duplicate sample, and three rinsate samples were collected and analysed for heavy metals. Based on these numbers the blind duplicates are slightly above the 5% requirement and therefore are in compliance with AS4482.1. Twenty-nine primary soil samples, four blind duplicates and two rinsate samples were analysed for TPH/BTEX.

Comparisons which resulted in greater than 50% relative percentage difference (RPD) values, of which there were two sample pairs of a possible 14 pairs that could be compared (i.e. 14%), are presented below: • Lead RPD 58% (0132-1/0.3 and SP2); and • Mercury RPD 133% (0132-2/0.3 and SP2).

Standards Australia (AS4482.1 - 2005) indicates that the acceptable range for RPD is 30% to 50%; however they do indicate that higher values are acceptable for numbers which are close to the laboratory method detection limits. Furthermore Standards Australia has assumed that these samples are homogenized in the laboratory prior to being spilt. The samples are split in the field with minimal effort to ensure homogenisation. The samples are field duplicates not laboratory duplicates therefore a greater RPD is acceptable.

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The Auditor has assessed the results taking into account that the samples are not laboratory split samples and the laboratory method detection limits. The Auditor considers that when samples are split in the field and results are low in comparison to laboratory method detection limits (MDL’s), RPDs in the range of 130% to 150% can be considered acceptable. When a result is within five times the MDL, up to 200% RPD can be considered acceptable. Based on the Auditors assessment, the reliability of the laboratory data in the soil assessment is considered acceptable.

7.7.2 Validation sampling Validation sampling involved the collection and analysis of 27 primary samples, two blind duplicate samples, one split sample and one rinsate sample over two sampling events. Based on these numbers, the blind duplicates are slightly above the 5% requirement and therefore are in compliance with AS4482.1.

No blind or split duplicates were outside the acceptable reproducibility range. Based on the Auditors assessment of the results, the reliability of the laboratory data in the soil validation assessment is considered acceptable.

7.7.3 Groundwater sampling Groundwater sampling by the assessor involved the collection and analysis of a total of 17 primary samples, five duplicate samples, five split samples, and five rinsate samples over five sampling rounds. This program is considered acceptable for this dataset.

Results comparisons show that there were 26 sample pairs of a possible 360 pairs that could be compared (i.e. 7%) with greater than 50% RPD values.

The Auditor considers that given the very small numbers involved (generally within 10 times the MDL) the reliability of the groundwater dataset is considered satisfactory.

7.8 Data set comparability The Auditor notes that all results adhered to chemical laws or were not outside logical explanation. Metal and pH levels in natural soil were within the range expected of sandy clay. In addition elevated metals and PAHs are confined to the fill layer, which is consistent with the results of the surrounding audit sites.

The slightly elevated concentrations of inorganic chemicals within the groundwater samples were consisted with the groundwater information from the review of surrounding audit reports. Thus, it is concluded that the data set overall was consistent and the samples are representative of the site, and the data can be seen as precise, accurate and representative of site conditions.

7.9 Auditor conclusions on quality assurance and quality control In the Auditors opinion: • the quantity of split and blind duplicate analysis for the LRM Global assessments are considered to be acceptable. Note that more splits should have been collected and analysed for the soil sampling program, but that this was off-set by adequate soil duplicate samples and adequate groundwater duplicate and split samples;

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• the field blind and split duplicate sample analyses indicated that an acceptable amount of RPD values were within the Auditor’s acceptable range or not outside logical explanation; • all results adhered to chemical laws or were not outside logical explanation; • in most instances field observations and measurements correlated with laboratory data; • the organic and inorganic analysis is consistent with the results of the desk top review; • internal laboratory duplicate analyses were within the acceptable RPD ranges; • spike values were within acceptable recovery percentages; and • laboratory blanks were all acceptable.

It is concluded that, based on the area of the site, the site history and the Australian Standard (AS 4482.1-2005), the locations and frequency of sampling at the site is considered sufficient to identify and characterise the contamination status of the fill and soil beneath the site, and to determine that remediation has been adequate. In addition, the data set is consistent, and the laboratory results can be seen as representative of the site condition. Therefore, data can be accepted as being representative of samples taken from the site.

Overall, the sampling and analyses procedures are considered acceptable after revision and implementation of the above discussed measures by LRM Global. The quality control procedures have indicated that the overall data supplied by the laboratories are adequate to arrive at the conclusions in this audit.

8 AUDIT FINDINGS

The environmental assessment undertaken by LRM Global for the site described as 160-162 Commercial Road, Prahran, Victoria, 3181 has provided objective information from which an assessment can be made regarding the suitability of the site for its proposed development as a high density residential and commercial site with basement car-parking. As part of the development process all soil across 100% of the site has been removed to a depth of approximately 4.0 mBGL.

8.1 Nature and extent of contamination The original soil assessment conducted at the site indicated that surface material consisted of imported fill material of unknown origin, while four USTs were present at the site. The imported fill material and soil around the USTs contained levels of heavy metals, TPH, benzene and PAH compounds at concentrations which exceeded NEPM HIL A, EIL and EPA Victoria 448.3 “Fill Material” criteria. All fill material was removed from the site to a depth of approximately 4.0 mBGL, and the excavation void validated. All validation soil samples comply with all site criteria.

Despite this finding, on-site contamination of the underlying uppermost aquifer was also identified in the form of TPH and BTEX in particular. Other chemicals such as trimethybenzenes, naphthalene, arsenic, nitrate and heavy metals (aluminium, chromium, nickel, iron, manganese and mercury) have also been detected on-site at above criteria concentrations.

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In total, six rounds of on- and off-site groundwater analysis were conducted as part of the environmental investigation. The results of the groundwater assessment indicate that off-site groundwater contamination has not been identified but may exist to the immediate north-east of the site. Assessment of beneficial uses has concluded that following establishment of a Groundwater Quality Restricted Use Zone (GQRUZ) on-site and on the properties to the east of the site fronting Commercial Road to the Izett Street intersection, all beneficial uses outside the GQRUZ boundary will be protected. This is discussed in more detail in Section 8.3.3 of this report.

8.2 Imminent environmental hazard The Auditor is not aware of any imminent environmental hazards that are associated with the site.

8.3 Evaluation of environmental quality and assessment of risk

8.3.1 Soil The SEPP (2002) Prevention and Management of Contamination of Land sets out the relevant beneficial uses for various end uses. The site is proposed to be developed into high density residential and commercial development. However in order to issue the site with a Certificate of Environmental Audit (CoEA), the Auditor must be satisfied that the site is suitable for any future land-use. Therefore the condition of the site must be assessed against the criteria for sensitive land-use.

The relevant beneficial uses of land are set out below: • Maintenance of ecosystems (natural, modified and highly modified); • Human Health; • Buildings and Structures; • Aesthetics; and • Production of Food, Flora, and Fibre.

A review of the compliance of the condition of the land with the beneficial use objectives is presented below.

Maintenance of natural and modified ecosystems The SEPP (2002) Prevention and Management of Contamination of Land states that the beneficial use of maintenance of ecosystems should be assessed against the interim NEPM EIL’s or against any regional ecological protection levels developed in accordance with the NEPM. The development of the site has involved the excavation of chemically impacted fill material and removal from the site. The validation samples collected from the site indicate that no chemicals of potential concern exist at the site at levels which exceed the interim NEPM EIL’s. The Auditor considers that soil at the site would not adversely impact any ecosystems which may be present at the site currently and in the future.

Human Health The SEPP states that the beneficial use of protection of human health should be assessed against the human health investigation levels (HILs), as set out in the NEPM. The Auditor must assess the site against the most sensitive criteria for the issue of a CoEA, hence the most sensitive HIL’s have been adopted which are the NEPM (A) HIL’s (standard residential

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Page 38 of 51 with garden/accessible soil, including children’s day care centres, preschools and primary schools).

There are no concentrations of chemicals of concern remaining in the soil and fill at the site, which are elevated above the relevant NEPM (A) HIL’s. Based on the results obtained, the Auditor concludes that material remaining at the site does not pose a risk to human health.

Buildings and Structures The SEPP requires that contamination must not cause the land to be corrosive, or to adversely impact the integrity of structures or building materials. Australian Standard AS3600 – Concrete Structures states that permeable soils with a pH of less than 4 are considered aggressive and detrimental to concrete structures. The NEPM 1999 sets a sulfate level of 2000 mg/kg for protection of buildings and structures. These conditions were not identified on the site.

Aesthetics The beneficial use of aesthetics requires contamination must not cause the land to be offensive to the human senses. This is considered to relate to the presence of offensive odour or the presence of stained or visually impacted soil, including and evidence of waste materials.

Contaminated fill material has been excavated from the site. No odour or discolouration due to contamination was noted in any of the samples from the natural material remaining at the site. In addition the proposed development of the site will result in almost complete site coverage, indicating that underlying soil at the site will have no effect on the aesthetics of the site.

Production of Food, Flora and Fibre The SEPP (2002) Prevention and Management of Contamination of Land states “contamination of land must not adversely affect produce quality or yield”. Specific criteria for the protection of food, flora and fibre are not provided, however the NEPM EILs are based on phytotoxicity. Therefore the Auditor considers that given no chemicals of concern have been identified at the site at levels which exceed the NEPM EILs, the protection of the beneficial use of “production of food, flora and fibre” should not be precluded.

8.3.2 Air quality After the remediation of the site no volatile compounds were detected within the validation samples at levels above laboratory detection limits. No odours were detected in any of the sampling points analysed. Therefore it is not expected that chemicals within the soil would impact on air quality. In addition the proposed site development will result in almost complete site coverage which will prevent the generation of any dust from soils at the site.

8.3.3 Groundwater and surface water Based on the LRM Global assessment, groundwater beneath the site is classified as Segment A2/B.

The protected beneficial uses for groundwater within Segment B are: • Ecosystems; • Potable Mineral Water supply; • Agriculture parks and gardens; • Stock watering;

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• Industrial water use; • Primary contact recreation; and • Buildings and structures.

Segment A2 also includes “acceptable potable water supply.” This is considered to be due to artificial recharge of reticulated water at the site, and is not representative of background groundwater quality.

Ecosystems The assessor has determined that the appropriate criteria for the protection of beneficial uses at this site would be the ANZECC/ ARMCANZ (2000), 95% freshwater species protection criteria, to which the Auditor concurs. As the nearest significant receiving water is the Yarra River (1500 metres to the north), it can be inferred that the ecosystem that requires protection from groundwater discharging from the site is this water body. Note that this receptor is only relevant if the hydraulics indicate that groundwater will discharge from the site to the receptor at a sufficient rate to cause an impact, and attenuation does not occur along the travel path.

All water quality indicators (at the most recent sampling event for each borehole) are acceptable for discharge to such an environment, with the exception of:

• TPH C6-C9, ethyl-benzene and naphthalene in monitoring wells MW01 and MW03; • toluene and xylenes in monitoring well MW03; • aluminium (Al) in monitoring wells MW07, MW08 and MW09; • arsenic (As) in monitoring well MW01; and - • nitrate (NO3 ) in monitoring wells MW04, MW06, MW07, MW08 and MW09.

Monitoring wells MW01 to MW04 were decommissioned as part of site remedial activities, which included primary and secondary contaminant source removal. Monitoring wells MW05, MW07, MW08 and MW09 have been subsequently installed off-site down-gradient of these former locations and the identified contamination plumes beneath the site.

As the pH of groundwater beneath and about the site is ≥6.4, the dissolved Al detected in monitoring wells MW07, MW08 and MW09 (and also previously detected in monitoring wells MW02, MW05 and MW06) is a false positive due to sediment/ colloids that have passed the filtration process and been acidified prior to analysis.

- As elevated NO3 has been detected in up-gradient monitoring wells MW04 and MW06 it may be concluded that it is not sourced from the site, and is ubiquitous in the Brighton Group aquifer in this area. This is confirmed by results from Environmental Earth Sciences 2008b - (range of 33-282 mg/L for five boreholes) and Environmental Earth Sciences 2007 (NO3 concentration of 71 mg/L).

The low hydraulic conductivity (K) and the oxidation potential of the formation will ensure that the attenuation rate of contamination is greater than the rate of migration, and therefore the hydrocarbon plume will never reach the Yarra River. Groundwater modelling has confirmed this supposition (Environmental Earth Sciences 2008a). On the basis of the total assessment of groundwater beneath and about the site undertaken, it is considered that the site currently is protective of down-gradient ecological receptors.

Potable mineral water supply

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The site is not located within a recognised mineral water zone. Therefore this beneficial use is considered irrelevant.

Acceptable potable water supply Due to the fresh nature of groundwater beneath and about the site, potable water supply needs to be considered as a potential beneficial use. Note however that the freshness of the water has been determined to be due in part to local leakage associated with contamination impacts (Environmental Earth Sciences 2008a), and therefore a potable water supply is not viable.

All water quality indicators (at the most recent sampling event for each borehole) are acceptable for discharge to such an environment, with the exception of: • benzene, 1,2,4-TMB and 1,3,5-TMB in monitoring wells MW01 and MW03; • ethyl-benzene in monitoring well MW01; • arsenic (As) in monitoring wells MW01, MW02 and MW03; • TDS in monitoring wells MW05 and MW06; • iron (Fe) in monitoring wells MW01, MW02, MW03, MW04, MW05 and MW09; and • pH in monitoring well MW04.

Monitoring wells MW01 to MW04 were decommissioned as part of site remedial activities, which included primary and secondary contaminant source removal. Monitoring wells MW05, MW07, MW08 and MW09 have been subsequently installed off-site down-gradient of these former locations and the identified contamination plumes beneath the site.

The hydraulic conductivity (K) of the formation beneath the site is likely to be insufficient to deliver a commercially sustainable water supply, while quality is expected to be marginal at best for potable supply. It has therefore been concluded that the site currently has no potential to impact on down-gradient domestic receptors, but that groundwater on the site is not suitable for potable use.

Agriculture, parks and gardens The protection of the beneficial use of agriculture, parks and gardens has been assessed against the criteria for irrigation use, as set out in ANZECC 1992. Based on this assessment, natural background concentrations of TDS, sodium, chloride, fluoride and sulfate within the groundwater are elevated above the criteria for the protection of agriculture, parks and gardens. Hence, groundwater within the aquifer beneath and about the site is naturally not suitable for such use.

Stock watering Due to the potential for down-gradient domestic users and the potential for the Yarra River to be used for stock-watering, this is a relevant beneficial use for the site. The health-based criteria applied to potable supply have been used to assess the suitability of groundwater discharging from the site for stock-watering use. As such, stock-watering is a chemically suitable beneficial use down-gradient of the site but not on-site, while the physics of the formation limits sustainable extractive use of water.

Industrial water use The SEPP recommends that for the protection of industrial water use, groundwater parameters should be compared to the criteria specified for industrial water quality set out in ANZECC 1992, which is based on the specific industry using the water. No specific industrial users are known to be abstracting groundwater within the vicinity of the site.

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Further, it can be generally stated that natural TDS, hardness, alkalinity, dissolved iron and corrosion index levels exceed acceptable thresholds for industrial applications of this water as specified in the SEPP, while yield is unlikely to be sustainable for commercial abstraction.

Primary contact recreation Due to the potential for down-gradient domestic users and for the Yarra River to be used for recreational swimming, this is a relevant beneficial use for the site. In order to assess groundwater against the beneficial use of primary contact recreation, results were compared to the guidelines for recreational water quality and aesthetics as set out in ANZECC 1992, ANZECC/ ARMCANZ 2000, and drinking criteria presented in NHMRC 2004.

All water quality indicators (at the most recent sampling event for each borehole) are acceptable for recreational use, with the exception of: • arsenic (As) in monitoring wells MW01, MW02 and MW03; and • iron (Fe) in monitoring wells MW01, MW02, MW03, MW04, MW05 and MW09.

Monitoring wells MW01 to MW04 were decommissioned as part of site remedial activities, which included primary and secondary contaminant source removal. Monitoring wells MW05, MW07, MW08 and MW09 have been subsequently installed off-site down-gradient of these former locations and the identified contamination plumes beneath the site.

It has been concluded that the site currently has no potential to impact on down-gradient recreational receptors, but that groundwater on the site is not suitable for such a use. Note that the Fe criteria have been set based on aesthetics and taste threshold rather than health concerns (NHMRC 2004).

Buildings and structures The SEPP recommends that protection of buildings and structures should take into account corrosive potential of groundwater, as indicated by pH, sulfate content and redox potential. NHMRC (2004) states that pH which is less than 6.5 can be corrosive. The pH of all groundwater samples was ≥6.4. Australian Standard AS 3600-1994 Concrete Structures states that groundwater containing more than 1 g per litre (1,000 mg/L) sulfate ions can be corrosive. All sulfate values were significantly less than 1,000 mg/L. Therefore it is concluded that groundwater beneath the site does not pose a risk to buildings and structures.

Conclusion on groundwater and surface water Based on EPA publication 759.1 (September 2007) Environmental Auditor (Contaminated Land) Guidelines for Issue of Certificates and Statements of Environmental Audit, if groundwater is polluted (in the sense that chemical concentrations exceed the criteria for one or more beneficial uses), a Certificate of Environmental Audit may still be issued for the site if it can be determined that potential beneficial uses are irrelevant or unlikely to be realised, and the site is not a source site, and nothing else precludes the issue of a Certificate.

The site has been identified as a source site, therefore the Auditor is of the opinion that the groundwater condition precludes the issue of a Certificate of Environmental Audit.

In conclusion, with reference to Section 13 and Figure 2 of EPA Victoria Publication 759.1, groundwater within the aquifer beneath the site is polluted, the site is the source of pollution, and the on-site beneficial uses precluded by this pollution (agricultural use, recreational use and stock-watering) are relevant. As EPA Victoria have determined that groundwater has been cleaned-up to the extent practicable (EPA Victoria 2008), a Statement of Environmental Audit can therefore be issued.

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8.4 Potential migration of contamination On the basis of a review of all the available data and following the site inspection the Auditor considers that chemical concentrations in soil at the site reflect local background concentrations. Therefore there is no potential for contaminant migration from soil at the site. Contamination of groundwater sourced from the site has however been identified, and has the potential to migrate off-site (although off-site migration has not been identified, and if it occurs is expected to be extremely localised and is predicted to degrade rapidly).

As such, a clean-up to the extent practicable (CUTEP) application has been made to EPA Victoria, who have determined that CUTEP has been achieved, a Groundwater Quality Management Plan (GQMP) is required for the site, and the site and adjoining properties have been determined to represent a Groundwater Quality Restricted Use Zone (GQRUZ).

8.5 Clean-up to the extent practicable (CUTEP) determination Following the CUTEP submission made by the Auditor on 14 October 2008 (Environmental Earth Sciences 2008a), EPA Victoria have determined (on 31 October 2008) that CUTEP has been achieved (EPA Victoria 2008).

Conditions of the CUTEP determination include: • on-going groundwater monitoring (at least six-monthly for three years) is required and should be formalised through provision of a Groundwater Quality Management Plan (GQMP) within 30 days of the date of this statement. Asian Pacific Building Corporation will be responsible for its implementation; and • groundwater should not be abstracted for use without appropriate testing at the subject site or the adjacent sites to the east fronting Commercial Road to the corner of Izett Street; consequently a Groundwater Quality Restricted Use Zone (GQRUZ) should be placed over the site and these properties.

9 CONCLUSIONS

Based on the proposed land-use of high density residential and commercial use, and the Auditor’s review of information supplied by the assessor as outlined in the previous sections of this report, the Auditor considers that this information is of sufficient quality and quantity to meet the requirements of an audit. The sources of information include: • the site history; • the geology and hydrogeology of the site; • the distribution and frequency of sampling locations to obtain a valued judgement of the contamination status of the site; • the accuracy and reproducibility of results verified via QA/QC sampling; • the analytical suite sufficient to identify a broad spectrum of likely contaminants; • the soil and groundwater sampling procedures suitable to produce accurate results; • the Auditor’s discussions with the assessor, EPA and client;

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• the Auditor’s site inspections and verification sampling results (both in terms of concentrations of chemicals recorded and comparison with assessors results); • the results of the assessment; • the EPA Auditor Guidelines and the relevant EPA policies as referenced in Section 3.0; and • the NEPM 1999 Guidelines, ANZECC 1992 Guidelines, AS4482.1-2005 and EPA Victoria 448.3-2007 in particular.

Soil The soil assessment conducted at the site indicated that surface material consisted of imported fill material of unknown origin, while four USTs were present at the site. The imported fill material and soil around the USTs contained levels of heavy metals, TPH, benzene and PAH compounds at concentrations which exceeded relevant criteria. All fill material was removed from the site to a depth of approximately 4.0 mBGL, and the excavation void validated. All validation soil samples comply with all site criteria.

Therefore the auditor considers the site suitable for the issue of a Statement of Environmental Audit.

Groundwater On-site contamination of the underlying uppermost aquifer was identified in the form of TPH and BTEX in particular. The results of the groundwater assessment indicate that off-site groundwater contamination has not been identified but may exist to the immediate north-east of the site. Assessment of beneficial uses has concluded that following establishment of a GQRUZ on-site and on the properties to the east of the site fronting Commercial Road to the Izett Street intersection, all beneficial uses outside the GQRUZ boundary will be protected. This conclusion needs to be validated through the implementation of a GQMP for the site within 30 days of the date of this audit report.

Given the above, the Auditor concurs with the assessor and considers that the groundwater condition of the site does not preclude the issue of a Statement of Environmental Audit.

10 LIMITATIONS

The site has been investigated as part of the audit by the placement of sampling points on a systematic and targeted basis. Though the Auditor has inspected the site and viewed the reports, the Auditor is not responsible for opinions based on work that is later found to be false or misleading. The audit in no way implies that the site will be free from contamination after development but only that exposure of contamination to the environment or from activities on the site as a whole will not cause adverse impact.

This audit does not conclude that all material remaining on-site, if excavated, will be classified as “Fill Material or Prescribed Waste” for off-site disposal (under EPA Victoria Information Bulletin 448.3 (2007) – Classification of Wastes). As the site has been investigated on a systematic and targeted basis and validated statistically the Auditor cannot guarantee that the locations between the sampling points are not contaminated, but the site statistically, as a whole, is fit for the proposed use.

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The Auditor does not conclude that commercially viable yields of food flora and fibre can be achieved on this site. Prospective buyers who envisage this use should undertake their own investigations.

The Auditor does not make any comment regarding the geotechnical suitability of the site. The Auditor is not responsible for any change in state of the site from the date of the audit report, and for the compliance by site owners of any laws or regulations relating to demolition and waste disposal.

11 REFERENCES

1. Dahlhaus, P et al. (2004). Port Phillip and Westernport Groundwater Flow Systems. Port Phillip and Westernport Catchment Management Authority. 2. Department of Natural Resources and Environment (DNRE) (1995a). Victorian groundwater beneficial use map series, South Western Victoria water-table aquifers. 3. DNRE (1995b). Victorian groundwater beneficial use map series, South Western Victoria regional aquifer systems. 4. Drever, J I (1997). The geochemistry of natural waters. Third Edition. Prentice Hall. 5. Environmental Earth Sciences (2008a). CUTEP submission for 160-162 Commercial Road, Prahran. October 2008. 6. Environmental Earth Sciences (2008b). Hydraulic testing of the Brighton Group aquifer beneath and about 12 Ellis Street and 9 – 13 Simmons Street, South Yarra, Victoria. Report 208038B. 7. Environmental Earth Sciences (2007). Limited environmental site assessment of 424 Malvern Road, Prahran, Victoria. Report 207032. 8. Environmental & Earth Sciences Pty Ltd (2005). Soil, Gas and Groundwater Sampling Manual. 9. EPA Victoria (2008). Clean-up of groundwater to the extent practicable, 160-162 Commercial Road, Prahran. Letter to Philip Mulvey dated 31 October 2008. 10. Geological Survey of Victoria (GSV) (1974). Melbourne 1:63 360 map sheet, SJ55-1. 11. Haque, S and Johannesson, K (2006). Arsenic concentrations and speciation along a groundwater flow path: The Carrizo Sand aquifer, Texas, USA. Chemical Geology 228:57-71. 12. Hem, J D (1992). Study and interpretation of the chemical characteristics of natural water. Third Edition. US Geological Survey Water-Supply Paper 2254. 13. Leonard, J (1992). Port Phillip Region Groundwater Systems – Future Use and Management. Department of Water Resources.

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14. Ravenscroft, P, Burgess, W G, Ahmed, K M, Burren, M and Perrin, J (2005). Arsenic in groundwater of the Bengal Basin, Bangladesh: distribution, field relations, and hydrogeological setting. Hydrogeology Journal 13:727-751. 15. Schreiber, M E, Simo, J A and Freiberg, P G (1999). Stratigraphic and geochemical controls on naturally occurring arsenic in groundwater, eastern Wisconsin, USA. Hydrogeology Journal 8:161-176. 16. Van de Graaff, R and Wootton, C (1996). Landcare Notes Melbourne Soils. Department of Sustainability and Environment.

12 ABBREVIATIONS

~ approximately AHD Australian Height Datum ANZECC Australian and New Zealand Environment and Conservation Council ASLP Australian Standard Leaching Procedure BaP Benzo(a)pyrene bgl below ground level CHC Chlorinated hydrocarbons CN Cyanide COC Chain of Custody CoEA Certificate of Environmental Audit CoPC Chemicals of Potential Concern DQE Data Quality Objectives DNRE Department of Natural Resources and Environment DPO Development Plan Overlay EAO Environmental Audit Overlay EILs Environmental Investigation Levels EPA Environment Protection Authority GD Guideline Dose GoV Groundwaters of Victoria (SEPP 1997) HILs Health-based soil Investigation Levels IWMP Industrial Waste Management Policy LTa Lower Tertiary aquifer MAHs Monocyclic Aromatic Hydrocarbons MTa Middle Tertiary aquifer Myo Million years old NATA National Association of Testing Authorities NEHF National Environmental Health Forum NEPC National Environmental Protection Council NEPM National Environment Protection Measure NHMRC National Health and Medical Research Council OCP Organochlorine (pesticides)

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OH & S Occupational Health and Safety OPP Organo phosphorous (pesticides) PAH Polycyclic Aromatic Hydrocarbons PCB Polychlorinated biphenyls pCz pre-Cainozoic bedrock aquifer PID Photo ionisation detector PTWI Provisional Tolerable Weekly Intake QA/QC Quality Assurance / Quality Control RPD Relative Percentage Difference SoEA Statement of Environmental Audit

SO4 Sulfate SEPP State Environment Protection Policy TC Total Concentration TCLP Toxicity Characteristics Leachate Procedure TDS Total Dissolved Salts TPHs Total Petroleum Hydrocarbon/ Total Recoverable Hydrocarbons UCL Upper Confidence Limit USEPA United States EPA UTa Upper Tertiary aquifer VOC Volatile Organic Compounds WTa Water Table aquifer ya years ago

Metals As Arsenic Be Beryllium Ba Barium Mn Manganese Mo Molybdenum Se Selenium Cd Cadmium Ni Nickel Cr Chromium Pb Lead Cu Copper Co Cobalt Sn Tin Hg Mercury Zn Zinc V Vanadium

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FIGURES

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SITE LOCATION

Source: UBD Australian City Streets (version 2.1)

Title: Locality Map

Location: 160-162 Commercial Rd. Prahran, Vic. 0 500 Client: Asian Pacific Building Corporation Job No: 207026 Scale in Metres Project Man: MS Scale: As shown Figure 1 Drawn By: LB Date: Oct. 2008

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LEGEND: Monitoring well location Soil sample location GLP Gas Low Pressure SEW Sewer Title: W Water Site Layout, Monitoring Well HV High Voltage and Soil Sample Locations T Telstra Location: 160-162 Commercial Rd. SW Storm Water Prahran, Vic. LE Lighting Electricals LVA Low Voltage A/G Client: Asian Pacific Building Corporation Job No: 207026 P Product Line Project Man: MS Scale: As shown A Air Figure 2 Drawn By: LB Date: Oct. 2008

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