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 Environmenf Profecfion Acf 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environmental audit reports, appointed environmental auditors who are highly certificates and statements may be withdrawn or qualified and skilled individuals.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 I N FORMATION 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.clov.au/envaudit any appendices and, where applicable, any certificate Email: [email protected] or statement of environmental audit. Sinclair Knight Men ? .. 590 OrrOflg Road, Amdale 3143 Tel 413 9248a, 9. PO Box 2500 Fax 4139500 1217 klalvern VIC 3144 Australia Web www skmconsulbng.mm
Dr Paul Moritz Manager - Land and Groundwater Environment Protection Authority GPO Box 439544 MELBOURNE VIC 3001
24 November 2004 LO1 ragepa.doc WC02871
Dear Dr Moritz
Environmental Audit Report: Lot 1,585-609 Kororoit Creek Road, Altona
On 14 May 2004, I wrote to EPA advising of my engagement by Mr Peter Home of Orica Australia Pty Ltd, to conduct an environmental audit and issue a Certificate appropriate) of Environmental Audit for a site located at 585 -609 Kororoit Altona. I note that the correct address is 585-609 Kororoit Creek Road and initially notified. An environmental assessment was undertaken for this site in June-August 2004 by HLA Envirosciences Pty Limited, as consultants to the site owner. The assessment report and findings of the HLA investigation program form the principal information used in the audit. The environmental audit of the site has now been completed and I attach a copy of the audit report, prepared in accordance with Section 53X of the Environment Protection Act. On the basis of my evaluation of the site contamination conditions, as described in the audit report, I am of the opinion that the condition of the audit site is potentially detrimental to some beneficial uses of the site. Accordingly, I have decided not to issue a Certificate of Environmental Audit for the site. I have issued a Statement of Environmental Audit for the site, which is included in the audit report. The Statement and report explain the reasons for this decision and provide information on the beneficial uses (and corresponding land uses) for which, in my opinion, the site is suitable. Development and use of the site for the proposed commercialhndustrial uses is considered a suitable use of the site, subject to certain conditions as described in the Statement and audit report. Should you require further information please contact me on 9248 3393.
Phone: 03 9248 3393 Fax: 03 9248 3364 E-mail: r!zaham(iiskmcom.au _-
cc. Hobsons Bay City Council I Mr Peter Home, Orica Australia Pty Ltd
SinclairKnighCMwrP(yUmited AYF! 3? $?< 085 Offices am% Australia. New Zealand, South East Asia, The Pacific, The Americas and Europe Report of Environmental Audit North Title, Altona Properties, Altona, Victoria
ALTONA PROPERTIES PTY LTDlORlCA AUSTRALIA PTY LTD Final 24 November 2004
Sinclair Knight Men ABN 37 001 024 095 590 Orrong Road, Armadale 3143 PO Box 2500 Malvern VIC 3144 Australia Tel: +61 3 9248 3100 Fax: +61 3 9248 3364 Web: www.skmconsu1ting.com
COPYRIGHT: The concepts and information contained in this document are the property of Sinclair Knight Metz Pty Ltd. Use or copying of this document in whole or in part without the written permission of Sinclair Knight Men constitutes an infringement of copyright. Ei
Environmental Audit
Summary of the Environmental Audit 1
1. Audit Details 5
a. Ountroduction 2.1 Background 2.2 Objectives of the Environmental Audit 2.3 Activities of the Environmental Auditor 2.4 Limitations 3. Sill@History and Characteristics 11 3.1 Site Description 11 3.2 Site Use History 11 3.3 Future Site Development 12 3.4 Ge~l~gy,Hydrogeology and Surface Waters 12
4. kWkWOf Site k&SeSSUIl@nt Program 14 4.1 Ontrodlaction 14 4.2 CMPSQF Due Diligence Investigation - 1995 14 4.3 CMBSQF Environmental Base Line Report - 1997 15 4.4 Parsons Brinckerhoff Phase 1 Site Assessment - April 2004 15 4.5 Groundwater Investigation - WLA April 2004 17 4.6 Additional Assessment Works - HLA July 2004 17 4.7 Quality Assurance /Quality Control 20 4.8 Auditor’s Verification 22 5. Grouundwat@r~ssessment a4 5.1 Scope of Groundwater Assessment 24 5.2 Groundwater Analysis Results 25 5.3 Groundwater QNQC 28 5.4 Auditor’s Comments 30 6. Auditor’s Review and Comments 31 6.1 Design of Site Investigation 31 6.2 Investigation Findings 31 9. Review of Wealth and Environmental Risks 33 7.1 Wealth Effects of Soil Quality 33 7.2 Environmental Effects of Soil Quality 33
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7.2.1 Overview 33 7.2.2 On-Site Soil Quality Effects 34 7.2.3 Production of Food, Flora and Fibre 35 7.2.4 Air Quality 35 7.2.5 Aesthetic Effects 36 7.3 Groundwater and Surface Water Issues 36 7.3.1 Groundwater Effects 36 7.3.2 Surface Water Effects 37 7.4 Buildings and Structures 37 8. Audit Conclusions and Statement of Environmental Audit 39 8.1 Conclusions 39 8.2 Statement of Environmental Audit 40 8.3 Auditor’s Signature on Audit Report 41 Appendix A List of Documents Reviewed 44
Appendix B Certificates of Title 46
Appendix C Relevant Data from CMPS&F Assessment Reports 47
Appendix D PB Site History 48
Appendix E HLA Assessment Reports 49
Appendix F Auditor Sampling Results 50
Appendix G Analytical Summary Tables from Assessments 51
P.L:GE ii i
Environmental Audit
Document history and status
I Revision f Dateissued 1 Reviewed by I Approved by I Dateapproved I Revisiontype !A ! 24-11-2004 j R. Graham j R. Graham 22-11- 2004 1 Final I
Distribution of copies I Revision '1 Copyno I Quantity I lssuedto I I Final 1 1 and 2 /2 Orica Australia Pty Ltd
i j5 11 j SKMLibrary i ! ! ! 16 11 I SKM File (original) j ! !7 I1 i RickGraham I
Printed: 24 November 2004 Last saved: 24 November 2004 0354 PM File name: I:\WCMS\Projects\WC02871\Deliverables\EnvAudit(Orica).doc Author: Corrado Rizza Project manager: Rick Graham Name of organisation: Orica Australia Pty Ltd Name of project: North Title, Altona Properties, Altona. Victoria Name of document: Report of Environmental Audit Document version: Final Project number: wc02871
PAGE hi Environmental Audit
Summary of the Environmental Audit
An environmental audit has been completed in accordance with Part KD of the Environment Protection Act 1970 for the site located at Lot 1, 585 - 609 Kororoit Creek Road, Altona, referred to as the “North Title, Altona Properties”. The site is described in the Certificate of Title Vo108460 FolO87 and being Lot 1 on Title Plan 334090V.
It is understood that the site was vacant prior to the southern portion being deve!oped in the 1960s by BF Goodrich for petrochemical use. During the 1970s a warehouse (north store) was built in the northern portion of the site. The site infrastructure included water tanks, a treatment plant, the north store for PVC extrusion and a site office.
Subject to the outcome of this audit, the site owner Orica Pty Ltd proposes to divest the site for ongoing commercial/industrial use. The site is currently zoned Special Use 3 (Petrochemical Industry), which is understood to be appropriate for the ongoing commercialhndustrial use (subject to planning approval).
Site Assessment Program
The assessment work at the site has included preliminary investigations by CMPS & F Pty Ltd in 1995 and 1997, which aimed to assess the potential for soil contamination. Subsequently Parsons Brinckerhoff Pty Ltd completed a detailed site history in 2004. On the basis of the site history a number of areas were targeted for groundwater investigation. HLA-Envirosciences Pty Limited was commissioned to undertake this groundwater investigation in 2004. After the groundwater investigation, HLA was also commissioned to complete a detailed soil investigation across the site. This work was managed by PB on behalf of the principal site owner (Orica Australia Pty Ltd), with the objectives of identifying soil or groundwater contamination, confirming the environmental conditions of the site as suitable for the proposed future use and providing information and data needed for the completion of an environmental audit.
The environmental auditor, Rick Graham of Sinclair Knight Merz, has been involved in consultation with PB and HLA during the conduct of the site assessments since the auditors engagement, and has reviewed the reports on the site contamination assessment program and site groundwater investigation prior to completing this audit report. The audit findings are summarised below. Environmental Audit
Findings of Environmental Audit Based on the assessment of all available relevant information about site conditions on the site located at Lot 1, 585 - 609 Kororoit Creek Road, Altona, which is subject to this audit, and the health and environmental considerations outlined in this audit report, the environmental auditor concludes that: Prior to 1962 the site was vacant land. In 1962 BF Goodrich acquired the North and South Titles and developed the South Title for PVC manufacture. The North Title (the site subject to this audit) was mainly vacant land until the 1970s when the land was leased to Hardie Extrusions, who established a warehouse (north store) in the north west part of the site. The extrusion plant operated until 1990, when Hardie Extrusions relinquished their lease. The North Title site also contained some peripheral equipmentlstructures for the PVC production on the South Title (non audit area) including a catalyst store, water tanks and fire fighting Pump-
A staged environmental assessment and validation program for soil quality was undertaken, in accordance with relevant guidelines and the auditor’s requirements, which adequately characterised the soil conditions on the site;
Soil at the site was found to have concentrations of nickel and lead at levels whch exceed ecosystem protection guidelines at a number of locations. These ,nickel concentrations are considered to represent background levels and not evidence of contamination, whilst the lead contamination is representative of a localised hotspot. Other analytes tested for in fill and natural soil were within the relevant guidelines for ecological protection under all feasible land uses. The beneficial uses of ecosystem protection and production of food, flora and fibre are protected other than at the area with localised lead contamination; Lead was detected at a concentration exceeding the adopted human health guideline within the transformer compound on the west of the north store. This was found to be localised within the caged transformer area and is considered to not present significant risk to future site occupants whilst human access is restricted. Other analytes tested for in fill and natural soil were within the relevant guidelines for human health protection under all feasible land uses; Based on the CMPS&F assessment reports, the auditor considered that there was the potential for a former UST to be present at the site, and required an investigation into its presence to be undertaken. A 5 x 15 m area was excavated to assess for the presence of a former or existing tank. The investigation by HLA did not detect the presence of a tank, backfilled tank pit or residual hydrocarbons. HLA concluded that the tank had been removed or was never present; A groundwater assessment was camed out at the site to identify contamination, which may have resulted fiom a number of potential sources (suspected underground tank, north store operations, catalyst store, etc). The investigation detected trace concentrations of
PAGE 2 Environmental Audit
dichloroethene, carbon tetrachloride and chloroform marginally exceeding the adopted guidelines for stock water supply andor primary contact recreation uses, however these were detected in on-site wells up-gradient of potential site sources. Similar contaminants were detected in a monitoring well located near the northern boundary and up-gradient of these wells, indicating a potential regional impact. It was concluded that site concentrations are likely to be from an unidentified regonal off site source. Concentrations reported for copper, nickel, selenium and zinc in groundwater were found to slightly exceed water quality guidelines for aquatic ecosystem protection. These exceedances were, however, considered not to be significant as they are likely to be naturally occurring levels. Concentrations were typically within relevant guidelines protective of on-site groundwater uses (stockwater supply etc), with the exception of the isolated nickel occurrence (considered naturally occurring); g) The past use of the site and its current condition do not present a significant risk of contamination of surface waters or the air environment. The site does not contain significant aesthetic evidence of soil contamination. The beneficial use of buildings and structures is protected. The auditor is of the opinion that the environmental condition of the site is potentially unsuitable for some sensitive land uses (such as residential), due to the presence of metal (lead) concentrations above ecological investigation levels (EILs) and exceeding the HIL A and D guidelines for residential use and the NEPM HIL F guidelines for commercial or industrial use in the transformer compound. The elevated lead concentration within the transformer compound is considered acceptable for ongoing commercialhndustrial use while this area remains fenced off. If the transformer area is decommissioned then this area should be either cleaned up or capped with a suitable surface barrierflayer. Groundwater is unsuitable for extractive uses on parts of the site as a result of offsite or regionally elevated concentrations of some chlorinated hydrocarbons and a localised elevated nickel concentration. The auditor is of the opinion that the environmental condition of the site is suitable for less sensitive uses of commercial and industrial use (as proposed) without further investigation or remediation.
Statement of Environmental Audit
After considering the issues described in this audit report, and having prepared this audit report in accordance with Section 53X of the Environment Protection Act 1970, the environmental auditor is of the opinion that the site is detrimental or potentially detrimental to some beneficial uses of the site. Accordingly, the auditor has not issued a Certificate of Environmental Audit for the audit site located at Lot 1, 585 - 609 Kororoit Creek Road, Altona, Victoria.
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PAGE 3 Environmental Audit
The auditor has issued a Statement of Environmental Audit in accordance with Section 532 of the Act. The Statement confirms that the site is suitable for beneficial uses associated with the feasible land uses of agncultural, commercial or industrial subject to conditions relating to the management of contaminated soils and groundwater.
The Statement of Environmental Audit is attached to this audit report (following Section 8). Environmental Audit
1. Audit Details
Name of Environmental Auditor: Richard Alan Graham Sinclair Knight Merz Pty Ltd
Date of Appointment as an Environmental 7 January 1997 Auditor (Contaminated Land) under the (subsequently renewed and current until 18 Environment Protection Act 1970: April 2005)
Name of Person making the Request for a Peter Home of Orica Australia Pty Ltd Certificate of Environmental Audit: (representative of owner)
Relevant Segment of the Environment: The relevant segment of the environment for the purpose of this environmental audit is the site defined below
LocatiodAddress of the Audited Site: Lot 1,585 - 609 Kororoit Creek Road, Altona, Victoria
(Refer Figure 1, Site Location Plan )
Certificate of Title or Plan of Subdivision Certificate of Title Vol08460 FolO87, Lot 1 on Details: Title Plan 334090V
Municipality: Hobsons Bay City Council
Date of Request to Issue a Certificate of 13 May 2003 Environmental Audit:
Date Auditor notified EPA of Request: 14 May 2003
Completion date of the Environmental 24 November 2004 Audit:
Documentation reviewed during the conduct Refer to Appendix A of this audit:
PAGE 5 SITE LOCALITY PLAN Orica Australia Pty Ltd Groundwater Investigahon, North Title - Altona Propertres 1 -
Environmental Audit
2. Introduction
2.1 Background
The site, which is subject to this environmental audit (“the audit site”), is rectangular inshape and has an area of approximately 7.35 ha, comprising the property located at Lot 1, 585-609 Kororoit Creek Road, Altona, Victoria, and referred to as the “North Title, Altona Properties”. The site is located within the Altona Petrochemical complex. The site is bounded by Kororoit Creek Road and vacant land to the north, Qenos to the west, Dow Chemicals to the east and the South Title Altona Properties to the south.
The Certificate of Title details are provided in Section 1 of this audit report and a copy of the title is provided in Appendix B. The current site title indicates AVC Pty Ltd as the registered site owners. AVC Properties Pty Ltd was taken over by Altona Properties Pty Ltd (APPL) in the 1990s and Orica Australia Pty Ltd and PolyOne Corporation Pty Ltd are currently joint shareholder of APPL. The site location is shown in Figure 1 - Site Locality Plan (fi-om HLA‘*’’) of the Audit Report. The site use history indicates the audit site formed part of a larger site that has been associated with the plastics industry from the early 1960s until closure in 2003. The main plastics making operation were located on the southern title and not on the audit site. Some infrastructure relating to the plastics manufacturing was located on the southern end of the audit site. This included fire water tanks, a catalyst store and water treatment plant. Located toward the northern end of the audit site is a large warehouse (north store) which was leased to Hardie Extrusions (Hardie Iplex). The remainder of the audit site generally comprised of vacant land, during the site’s occupation. The history of the site use is summarised in Section 3.2 of this audit report.
The Onca Australia Pty Ltd propose to divest the site for ongoing commercialhndustrial use. The site is currently zoned Special Use 3 (Petrochemical Industry).
A statutory environmental audit was requested by the client to be completed in accordance with Part IXD of the Environment Protection Act 1970 (the Act) in order to exercise due diligence as part of the sale process and to demonstrate the site is suitable for ongoing commercialhndustrial use, with the outcome being the issue of either:
a Certificate of Environment Audit; or
rn a Statement of Environmental Audit to the effect that the environmental conditions of the site are suitable for the proposed uses.
Mr Peter Home of Orica Australia Pty Ltd (representative of the site owner), commissioned Parsons Brinkerhoff Australia Pty Ltd (PB) and HLA-Environmental Sciences Pty Ltd (HLA) to
PAGE 6 Environmental Audit
undertake environmental investigations required to support a statutory environmental audit. PB was commissioned to project manage investigations works on behalf of Orica and also completed a preliminary site history investigations. The scope of works and findings of those programs of works are summarised in Sections 4.2 to 4.6 of this audit report.
Consistent with Environment Protection Authority (EPA) guidelines (EPA 2002), an environmental auditor who is independent of the assessment consultant was engaged to undertake the audit. On 13 May 2004 Mr Peter Home engaged Mr Richard Graham of Sinclair Knight Merz consulting engmeers, under Section 53U of the Act, to conduct an environmental audit of the site. Mr Graham notified the EPA of this engagement on 14 May 2034.
2.2 Objectives of the Environmental Audit
The statutory environmental audit process for contaminated land is described in Part IXD of the Act, in EPA auditor guidelines (EPA 2002) and the Planning Minister's Direction No. 1 (Department of Planning and Housing, 1992). The audit process is intended to be applied to land formerly used for industrial or other potentially contaminating uses, which is proposed to be redeveloped for a sensitive use such as residential.
The environmental assessment and audit process for the site subject to this audit was generally consistent with EPA guidelines, although it is recognised that the future use of the site is proposed to remain commercial or industrial, not a sensitive use. The environmental auditor was engaged prior to additional investigations undertaken by HLA Envirosciences Pty Ltd. The scope of works were approved by the auditor in order to ensure that the investigation works would be adequate to satisfy the requirements of the audit.
The overall objective of the audit process is to facilitate a change in land use from a contaminated or potentially contaminated site in a controlled manner, while protecting human health and environmental quality. The specific objectives of this audit were:
rn to audit the environmental status of the site in accordance with Part IXD of the Act and EPA guidelines for auditors;
rn to evaluate the environmental quality of the audit site (being the relevant segment of the environment for the purposes of the audit); to provide an independent evaluation of the site conditions, potential risks to human health or the environment and the suitability of the site for a range of future uses;
rn to assess whether any clean-up is required for the site and, if so, make recommendations for clean-up;
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Environmental Audit
to prepare an environmental audit report and issue a Certificate (or Statement) of Environmental Audit as appropriate, depending on the contamination status of the land; and through the audit report and Certificate (or Statement) of Environmental Audit, to provide assurances to the site owner, planning authority, prospective purchasers and occupants and the nearby community that redevelopment and use of the site may proceed without unacceptable risk to human health or environmental quality.
2.3 Activities of the Environmental Auditor During the environmental audit, the auditor and/or his support staff conducted a number of activities to ensure that these objectives were met, including:
inspections of the site accompanied by representatives of HLA, PB and Onca (representative of site owners); discussions with staff of PB, HLA and Onca; review of all available relevant documentation including the site assessment reports, site plans, government agency policies and guidelines. A full list of documents relied upon for this audit is produced in Appendix A - List of Documents Reviewed; review of the quality and completeness of the environmental site assessment reports and verification of the assessors’ conclusions; and preparation of this report of the environmental audit in support of a decision whether to issue a Certificate or Statement of Environmental Audit. The auditor was supported during this audit by Mr Corrado Rizza, Environmental Engineer of SKM, including for site verification sampling and inspection of the final site conditions. Expertise from the auditor’s nominated specialist support team was not required in this audit.
2.4 Limitat ions
This audit report and the accompanying Statement of Environmental Audit relate to the site located at Lot 1, 585-609 Kororoit Creek Road, Altona, Victoria as defined in the relevant Certificate of Title and Title Plan (refer Section l), and have been prepared in accordance with Part IXD of the Environment Protection Act 1970, relevant EPA guidelines and other standards, policies and guidelines.
The audit report and Statement have been prepared for Orica Australia Pty Ltd for the purposes described in the audit report, including informing prospective purchasers and occupants of the land at the site. It is acknowledged that the audit report and Statement may also be used by the Environment Protection Authority and the Hobsons Bay City Council in reaching their conclusions about environmental conditions at the site. The scope of work performed in connection with the
SlNCIAlR KNIGHT MERZ Environmental Audit
audit may not be appropriate to satisfy the needs of any other person. Any other person’s use of, or reliance on, the audit report and Statement, or the findings, conclusions, recommendations or any other material presented in them, is at that person’s sole risk.
The conclusions of this environmental audit report and the issue of the Statement of Environmental Audit are based on a review of information which was available to the auditor at the time of the audit and relating to the environmental quality conditions of the audit site and adjacent land. Sinclair Knight Merz and the environmental auditor are satisfied that the information and data available were adequate for this purpose.
Sinclair Knight Merz and the environmental auditor have taken due care to consider all reasonably available information in undertaking this audit and have taken this information to represent a fair and reasonable characterisation of the environmental status of the site, but recognise that any site assessment program is necessarily limited in scope and true site conditions may differ from those inferred from the available data.
Whilst all reasonable care has been taken, to the extent practical under normal auditing procedures, to assure the reliability of the information, the environmental auditor and Sinclair Knight Merz cannot warrant that this is the case. If the information is subsequently determined to be false, inaccurate, misleading or incomplete, it is possible that the environmental auditor’s conclusions as expressed in the audit report may change. Sinclair Knight Merz and the environmental auditor disclaim any responsibility for inconsistencies between the findings of this audit report (and the issue of a Statement of Environmental Audit) and information or data whch may become available after the date of completion of this audit.
Sinclair Knight Merdthe auditor conducted limited verification testing by sampling and analysis of site soils, but otherwise relied on the data produced from the site assessment program undertaken by Parsons Brinckerhoff Pty Ltd (PB) and HLA Envirosciences Pty Ltd (HLA) for Orica Australia Pty Ltd. The auditor provided comment on, and approval of, the environmental site assessment and investigations completed by PB and HLA. The auditor is reasonably satisfied that the data were reliable for the purpose for which they have been used, and only limited independent testing was justified in this case.
This environmental audit applies to the condition of the site at the time the site assessment was undertaken. The environmental auditor and Sinclair Knight Merz cannot be responsible for fiture activities that may result in changes to the site conditions. In the event that site conditions have since changed or are likely to change in the future, the environmental auditor recommends that the property owner engage an environmental consultant to confirm that the site conditions remain suitable for its proposed use.
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PAGE ‘i Environmental Audit
It is not possible in an environmental audit report to present all data that could be of interest to all readers of this report. Readers are therefore referred to the referenced documentation for fiuther information and data. Environmental Audit
3. Site History and Characteristics
3.1 Site Description
The site located at Lot 1, 585-609 Kororoit Creek Road, Altona is subject to this audit, is rectangular in shape and has an area of approximately 7.35 ha. The site is located within Altona Petrochemical Complex. The Altona Properties North Title (audit site) is bound by Kororoit Creek Road to the north, Qenos Resins to the west, Dow Chemical to the east and the Altona Properties South Title to the south. The nearest surface waterbody is Cherry Lake approximately 1.5km southeast and Port Phillip Bay located approximately 2 km south of the site. The site location is shown in Figure 1 of the Audit Report.
3.2 Site Use History
Information on the history of use of the audit site was compiled as part of the contaminated site assessment and is documented in the Parsons Brinckerhoff Pty Ltd (PB) site history report (24). The site use history indicates the site has been associated with the plastics industry from at least 1960s until its recent closure in 2003. The following is a brief summary of the site history extracted from the PB report (24).
Prior to being acquired by BF Goodrich in 1962, the North and South Titles were vacant undeveloped land. Shortly after acquiring the land, a PVC resin plant was constructed on the South Title, whilst the North Title remained undeveloped (with the exception of a carpark). Run-off fiom bunded areas in the South Title may have been pumped into a small natural pond located in the North Title.
In the early 1970s the north west portion of the North Title was leased to Hardie Extrusions who established a PVC pipe extrusion factory plant in the north store warehouse (which remains present on the site). The extrusion plant operated until 1990, when Hardie Extrusions relinquished their lease. In the mid 1970s the carpark was extended and two fire water tanks were constructed in the south east comer of the North Title. Prior to commissioning an effluent treatment plant in 1982, plant process water was allowed to settle in earthen bunds located in the north east comer of the South Title and possibly extended to the North Title. A refiigerated catalyst store was also established near the treatment plant at about the same time.
During the 1980s the vacant paddock in the north east comer was cleared of basalt boulders and used as a golf course by plant workers. The golf course was watered with waste process water after treatment in the effluent ponds on the boundary of the current Qenos site. Also goat grazing and rabbit poisoning using bait was conducted in this area.
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BF Goodrich was taken over by Geon which then became Auseon. Australian Vinyls assumed ownership in 1997 and Altona Properties Pty Ltd operated the site after plant operations ceased in
2001. Figure 2 - Site Layout and Former Infrastructure (from PB 2004 (24)) shows the layout and former infrastructure at the audit site.
On the basis of the site history review the auditor has identified the following potential activities/sources of contamination, summarised in Table 3-2.
a Table 3-2:Potential Sources of Contamination Contamination Source Potential Contaminants
PVC manufacturing on South Title Metals, chlorinated hydrocarbons Suspected underground tank in the North Title and TPH, BTEX and lead and underground tank in the South Title PVC Extrusion on North Title Metals, TPH
3.3 Future Site Development
The current site owners propose to divest of the site (North Title) for ongoing commercial andor industrial use, consistent with the zoning.
3.4 Geology, Hydrogeology and Surface Waters
The site history report(24)and investigation (257 26) contain adequate information on the geology, hydrogeology, topography and surface water catchment for the audit site and local area, as summarised below.
a) Geology and Soils The Geological Survey’s Melbourne Map Sheet (Scale 1:63,360) indicates that the site is located on Quaternary aged Newer Volcanics, consisting of Olivine basalts.
The site investigation found that the lithology at the site generally comprised of fill varying in depths up to Im overlying residual basaltic clay to a maximum depth of 2m which was underlain by basalt.
a) Hydrogeology
PB (24) completed an existing bore search within a 2km radius of the site. The State Groundwater Database records indicated that 45 registered bores were present within a 2km radius of the site. Registered bores varied in depth from 11 to 195 m, with listed uses for 43 of the 45 as observation
SlNCLAlR KNIGHT MER,? KOROROIT CREEK ROAD
Y'
m
I Figure 2 - Site Layout and Former Infrastructure I ~ ~~
Environmental Audit
bores. One deep bore (145m) was registered as stock and domestic and another (1 95m deep) listed as groundwater. Recorded groundwater quality data ranged between 4,960 and 81,600 mg/L. Regional groundwater is expected to flow to the south-south east toward Port Phillip Bay.
Based on the TDS (4,480-8,270 mg/L) levels recorded ~n-site'~~',groundwater would be classified as Segments C to D, under the State Environment Protection Policy (SEPP) Groundwaters of Victoria (Victorian Government 1997).
For Segment C groundwater, the following beneficial uses are protected:
maintenance of aquatic ecosystems (relevant after discharge of groundwater to nearest surface water receptor);
stock watering (a likely use in the area);
industrial water use (a possible but an unlikely use in the area, given the absence of registered bores for this use);
primary contact recreation (unlikely due to abstraction but possible after discharge to surface waters). On site or nearby site use for this purpose is considered unlikely, gwen the presence of a reticulated water supply; and
buildings and structures (foundations or services are unlikely to contact groundwater at the site, given the groundwater table depth).
Topography and Surface Waters The site and local surrounding land is typically flat lying land with little surface relief. The nearest surface water body is Cherry Lake located approximately 1.5km south east of the site, and Port Phillip Bay located approximately 2km south of the site. Based on the reduced groundwater levels fiom monitoring wells on site, groundwater is expected to flow southeast toward Cherry Lake and Port Phillip Bay.
The site surface water would drain to the local street stormwater drainage system, and in turn would drain to Port Phillip Bay. The beneficial uses, water quality objectives and attainment program to maintain appropriate water quality for surface waters in this catchment are set out in the State Environment Protection Policy (SEPP) for the Waters of Victoria (Vic Govt 2003), which incorporates Schedule F6: Waters of Port Phillip Bay (Vic. Govt 1997, as varied by Vic Govt 2003). -~
Environmental Audit
4. Review of Site Assessment Program
4.1 Introduction Prior to the more recent investigations by PB and HLA, CMPS&F Pty Ltd completed two phases of investigations at the Altona North and South Titles in 1995 and 1997. The investigations undertaken in 1995 were preliminary and only the summary table and sample locations of the 1995 report were provided to the auditor. However, as this was only a preliminary investigation, this was not considered a quality issue for the audit. The following is a list of the reports and information reviewed in the completion of the Audit report:
Figure and Summary Laboratory Tables from “Auseon Australia Due Diligence Review Soil Assessment, Kororoit Creek Road, Altona” by CMPS&F Pty Ltd, dated 1995.
D Environmental Baseline Report, for Auseon Limited, by CMPS&F Pty Ltd, dated 1997.
Phase 1 Site Assessment - Altona Properties, North Title, for Onca Australia, by Parsons Brinckerhoff Pty Ltd, dated 14 April 2004. Final Report, Groundwater Investigation, North Title, Altona Properties, for Orica Australia Pty Ltd, by HLA Envirosciences Pty Limited, 27 April 2004. Additional Assessment Works, North Title, Altona Properties, for Orica Australia Pty Ltd, by HLA Envirosciences Pty Ltd, 17 September 2004. Other minor items of correspondence were also reviewed during this audit. These have not been listed as all the site information relevant to the audit was contained within the above reports. Copies of the above reports are included in Appendices C, D and E of this report.
The following sections briefly outline the scope and findings of the various stages of investigations. The groundwater investigation is discussed in Section 5. The complete assessment reports should be referred to for more detail.
4.2 CMPS&F Due Diligence Investigation - 1995
CMPS&F completed an assessment across the North and South Titles comprising sampling at 39 locations across the site and sampling for potential contaminants of concern OCPs, chlorinated compounds, TPH, BTEX and phenols. Sampling and analysis of soils reported the following:
Volatile Chlorinated Compounds (VCH)concentrations below the adopted criteria in the former effluent treatment ponds area on the South Title (adjoining the North Title); VCH Concentrations below the adopted criteria in the grassed paddock in the north east comer of the North Title; Lead impacts at the former effluent treatment ponds;
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Lead impacts in the grassed paddocks in the northeast and on the Hoechst property to the west of Hardie Extrusions. Elevated lead concentrations were reported in surface and 0.5 m samples immediately west of the Hardie Extrusions warehouse; A soil sample near a former fuel tank (assumed to be a UST) on the Hardie Extrusions site reported benzene (1.5 mgkg), toluene (1.4 mgkg), ethylbenzene (4.6 mgkg) and xylene (20 mg/kg) at one location (TBH2) near the North Store. Also trace concentrations of BTEX at detection limits were detected in SP33 in the open paddock to the east of the north store. With the exception of benzene and xylene in BH1 all concentrations were within the then adopted Dutch B guidelines; and Chromium, copper, cobalt, mercury, nickel and zinc were detected at the former effluent treatment ponds and in the grassed paddock at concentrations below adopted criteria. Subsequent to these works it was concluded that the contamination levels detected were suitable for the ongoing site use and did not require clean up. A copy of the site sample locations and analytical summary tables from the 1995 CM€'S&F investigation are included in Appendix C of this audit report.
4.3 CMPS&F Environmental Base Line Report - 1997
CMPS&F completed an assessment across the North and South Titles comprising a total of 89 sample locations, with approximately 41 sample locations in the North Title. Soil samples were analysed for potential contaminants of concern OCPs, PCBs, chlorinated compounds, TPH, BTEX, phenols, PAH and metals. With the exception of three samples reporting metals at concentrations exceeding the then adopted Dutch guidelines, the remaining samples from the North Title reported concentrations within the adopted guidelines.
The auditor notes that generally sample points were evenly distributed across the site in a grid pattern, providing a reasonable baseline of the quality of the soils across the North and South Title.
QNQC sampling was completed during this phase of work and a discussion of QNQC results is included in section 4.7 . A copy of the body of the CMPS&F report, site sampling locations and summary analytical results are included in Appendix C of this audit report.
4.4 Parsons Brinckerhoff Phase I Site Assessment -April 2004 As part of the information required to support a statutory environmental audit, PB completed a detailed Phase 1 site assessment incorporating a site history and review of previous works at the site:
The scope of works for this included:
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Review of available historical reports and records held in the PB library or the Altona site office; Review of titles and zoning information; Review of historical aerial photographs; A groundwater database search of registered wells in the area; Review of regional geological and hydrogeologcial conditions at the site; A site visit to assess conditions and to evaluate potential sampling locations for the Phase 2 intrusive works; Interviews with former site personnel who are familiar with the site history operations; and Compilation of a factual report including potential contamination issues associated with the site and contaminants of concern and proposed investigation locations for the Phase 2 works. The results of the above work found:
The total site prior to 1962 was undeveloped. In 1962 development of the site commenced with the development of the South Title for the manufacture of PVC resin. Some of the PVC manufacturing infrastructure was located on the south part of the North Title. This included a process water treatment plant and above ground fire fighting tanks and associated above ground diesel tank and pump. Also located on the north western part of the South Title were bunded effluent ponds which were used for the settling of process water, prior to the fabrication of the treatment plant (in 1982). The north store warehouse was built in the early 1970s when the North Title was leased to Hardie Extrusions who were producing pipes using an extrusion process. A due diligence audit of the Hardie Extrusions site in 1992 detected lead in the dust in the vicinity of the north store and subsequently a clean up was undertaken. During the 1960s effluent from the settling ponds in the South Title may have also been pumped into the natural pond in the north -eastern paddock of the North Title. A UST was mentioned in the 1995 CMPS&F report and believed to be located near the north eastern comer of the north store. Asbestos has been identified in the north store and the Hardie Extrusions office. Three stainless steel monitoring wells were present at the North Title as part of broader groundwater investigations. These were wells BH14G and OSW34A in the upper aquifer and BH 15G in the deeper aquifer. The site history review identified the following potential sources of contamination; - Impacts to undeveloped grassland due to watering with treated effluent and rabbit bait; - Impacts to the natural ponds due to pumping of effluent before settling ponds established; Environmental Audit
- Impacts in the vicinity of the north store where pipes were extruded. Potential impacts for asbestos, lead metals, VCHs and phthalates; - A UST on the north eastern side of the north store; - Electrical substation on the western side of the north store; - Wash down bay on the south eastern comer of the north store; - Overflow from the equalisation tank in the treatment plant; - Storage of caustic and acids used to treat effluent; - Former effluent treatment ponds possibly located on the North Title (used to for the settling of process water); - Catalyst store located in the south western part of the North Title; - Two 2000 L above ground diesel tanks for the fire tank pumps located in the southwestern part of the North Title; - A substation location near the fire water tanks; - Spill of product from the Qenos tank farm located to the west of the site (including hydrocarbons and chlorinated hydrocarbons); and - Groundwater impacts from the South Title. The site history report recommended that seven groundwater monitoring wells be installed at the site in order to target potential for groundwater impacts across the site (discussed in the next section of this audit report).
4.5 Groundwater Investigation - HLA April 2004 HLA was commissioned to undertake the drilling, installation and sampling of the proposed seven groundwater monitoring wells at the North Title. The location of the seven monitoring wells is shown in Figure 3 - Groundwater Monitoring Bore Locations (from HLA 2004 (25)).
The results of the groundwater analysis are discussed in Section 5.
4.6 Additional Assessment Works - HLA July 2004 HLA was engaged to undertake additional soil investigations and additional groundwater sampling at the site in order to support the statutory environmental audit. The scope of works included the following:
Sampling of soil at 40 grid locations and at approximately 17 targeted locations across the North Title; Collection of soil samples at each location from surface, 0.5 mbgs, 1.O m bgs and at the base of each testpithoil borehole; Field screening of soil samples using a photoionisation detector;
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GROUNDWATER MONITORING BORE LOCATIONS Orica Australia Ry Ltd Groundwater Investigation, North Title - Altona Propertres 0 125 25 Metres D Kororolt Creek Road, Altona North J -FILE NAME M4014401 DATE 10 Figure 3 - Groundwater Monitoring Bore Locations L- I Environmental Audit
m Analysis of selected samples fiom each testpitlsoil bore location (one surface sample and selected deeper samples fiom 50% of the locations); Gauging all on-site monitoring wells; Analysis of soil and groundwater(resu1ts are discussed in section 5 of this audit report) for selected organics and inorganics; and Compilation of suitable report. In discussion with the Auditor, in addition to general gnd bores, HLA also targeted the following features for further soil investgiation:
The suspected former UST location near the north eastern comer of the north store building; A pit located at the eastem end of the north store, suspected to be related to cooling water fiom the extrusion process; The transformer compound to the east of the north store; An open spoon drain along the southern boundary of the site; The natural pond located in the north eastern paddock; Service trenches within the Hardie north store; A triple interceptor trap located on the north western side of the Hardie north store;
Primary soil samples were sent to Labmark which is a NATA certified laboratory. Soil samples were analysed for selected analytes including metals, PAHs, TPHs, volatile organics and semi volatile organics (including chlorinated hydrocarbons), phthalates, cyanide, BTEX, phenols, organochlorine pesticides and organophosphatepesticides and polychlorinated biphenyls;
The assessment report discusses the analytical data relating to the validation samples in the context of relevant health and environmental guidelines. Specifically, HLA compared the analytical data to relevant health-based investigation levels (HILs) and NEPM interim urban ecological investigation levels (EILs) sourced from the NEPM (NEPC, 1999). HLA used the NEPM HIL F for industrial site use (considered appropriate for the site) as well as the NEPM HIL A for sensitive site uses (even though HIL A guidelines are conservative for the current site). The auditor notes that the NEPM health-based guidelines Setting F are appropriate for the site under investigation given that the site will be used for ongoing industrial use. The auditor notes that the ecological investigation levels adopted by HLA are conservative for this site given that the site use will be industrial and only highly modified ecosystems are protected for this land use.
Nevertheless, the auditor must consider the suitability of the site for any feasible use, and so guidelines for sensitive uses (HIL A health-based guidelines for sensitive residential use and EILs) are appropriate for data evaluation purposes for the audit.
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PAGE !6 Environmental Audit
Soil samples were submitted to the primary laboratory Labmark for individual analysis of specified contaminants, as summarised in Table 1 and 2 of HLA'26'. Quality control analyses were conducted by ALS Pty Ltd (ALS). QNQC protocols were observed, as described in the assessment report (26). Soil sample locations are shown in Figure 4 - Additional Soil Investigation Sample Location Plan (from Figure 2 of HLA @@).Whilst laboratory analysis reports are provided in
Appendix B of HLA (26f.
The results of the analysis found:
The pH of soils ranged between 6.9 to 1 1.6; With the exception of lead in one sample from the transformer area on the western end of the Hardie Iplex north store which exceeded the NEPM HLL F guideline, all other metals were within the adopted NEPM HIL F guidelines. Lead was detected in sample HA3/0.05 at a concentration of 3350 magcompared to the NEPM HIL F guideline of 1500 mag; With the exception of lead at two locations HA3/0.05 and CSTl5/0.1 , at concentrations of 3350 and 3 10 mgkg respectively which exceeded the NEPM HIL A guideline of 300 mgkg, all other samples reported metals concentrations within the NEPM HIL A guidelines; Copper was detected at one location at a concentration of 440 mgkg, exceeding the NEPM EIL of 100 mgkg; Cadmium was detected at one location at a concentration of 4.9 mgkg, exceeding the NEPM EIL of 3 mgkg; One sample CSTl/O.5 reported 1,2,4 trichlorobenzene at a concentration of 3.2 mag.HLA indicated that no local guideline was available for this contaminant; TPH was detected at a concentration of 1040 mgkg in sample AP5/0.7 m, exceeding the NSW EPA guideline for sensitive land use of 1000 mgkg, but within normally adopted guidelines for ongoing commercial or industrial use; and All other analytes tested for were either below the laboratory detection limit or the adopted guidelines. Inspection of the service trenches within the north store revealed a white substance within the concrete lined trenches similar to gypsum. It was inferred by HLA that this may have been some type of buffer. A sample of this material was analysed and found to be free of contaminants of concern (including chlorinated compounds).
At the request of the auditor, HLA also excavated the area believed to be the location of the former underground tank near the northeast comer of the Hardie Iplex north store. HLA removed a 5 x 15m area of concrete in this location and undertook to excavate this area to assess for the presence
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E69 @
6S40 6S41 43 8
,egend sample Type 0 Hand Auger Locations. HLA (2004)
Q) Soil Bore Locations. HIA (2004)
d) Soil Investigation Location CMPS&F (1995)
4lD Test Pit Location. HLA (2004) Sample Method HA (eg HAI) - Hand Auger CST (eg CSTI 5) - Geoprobe presence of concrete sublayer at adjacent locations. AP (eg AP5) - Hydraulic Drill Rig (Solid Auger/Hammer) Drilled with hammedauger. Samples collected by hand auger. EB (eg EB10) - Backhoe \ SOIL INVESTIGATION LOCATION PLAN \ Orica Australia Pty Ltd Additional Assessment Works, 125 25 50 North Title - Altona Properties 0 - Metres Kororoit Creek Road, Altona North J DATE JI PROJECT-FILE NAME M4018201. Figure 4 - Additional Soil Investigation Sample Location Plan Environmental Audit
of a tank or tank pit. This investigation did not find evidence to suggest that there was an underground tank at this location. HLA sampled soils in the base and walls of this excavation (EBO1 - EB11) and did not detect hydrocarbons in the soil in this area. The auditor has reviewed all the information to date and concurs with HLA that there is no underground tank at this location or TPH impacts. Careful review of the earlier CMPS&F data indicates that there was no firm evidence that there actually was an underground tank at this location. In fact if a tank was present it may have been an aboveground tank. In any case, the auditor is satisfied that there are no soil contamination impacts and the BTEX results reported by CMPS&F for soils in this area (refer to section 4.2) were not reproducible.
At the auditors request, HLA also completed delineation testing in the vicinity of the elevated lead concentration at HA3 by sampling soils at three step out locations (HA4 - HA6) within the transformer compound. Analysis for lead reported concentrations within the NEPM HIL A guidelines. HLA concluded that the elevated lead concentration at HA3 was an isolated occurrence and not representative of wider impacts in this area of the site.
QNQC results are discussed in Section 4.7 of this audit report.
4.7 Quality Assurance /Quality Control Environmental Baseline Report (CMPS&F 1997) QMQC During this phase of work CMPS&F collected QNQC samples including field duplicates and split and rinsate blanks. However, CMPS&F did not calculate RPDs or provide a discussion of the results of this analysis.
Generally, duplicate and split sample analyses showed good correlation, with most data pairs reporting levels below detection limits. However, where concentrations were detected there was generally good correlation between the data pairs.
Analysis of 7 field blanks and 12 rinsate blanks did not report analytes at concentrations above the laboratory detection limits.
Given the age of this investigation, the auditor concludes that the QNQC data is adequate to support the data provided in that phase of work. However, the information from the CMPS&F report has not been solely relied on for this audit, rather it has been used to gain an appreciation of the general site conditions in 1997.
Additional Assessment (HLA 2004) QMQC)
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Quality assurance/quality control protocols which were incorporated during the main soil sampling program undertaken by HLA in 2004 incorporated the following:
4 field blind duplicate samples were analysed at the primary laboratory (Labmark) for the principal contaminants of potential concern, namely metals, TPH/BTEX, SVOCs, VOCs and PAH; 4 field split duplicate samples were analysed at the secondary (QC) laboratory (ALS) for the principal contaminants of potential concern, namely TPWBTEX, SVOCs, VOCs and PAHs; five rinsate blanks were analysed at the primary laboratory for principal contaminants of potential concern including metals, TPWBTEX, SVOC and VOCs; intra-laboratory QNQC protocols, including analysis of matrix spike/matrix spike duplicates, internal duplicate analysis and method (reagent) blanks at standard frequencies; and other QNQC protocols in accordance with HLA standard procedures (documented in Appendix E of HLA's report), based on accepted good practice and relevant guidelines or Australian Standards. This included decontamination procedures, appropriate storage and preservation of soil samples and appropriate chain of custody documentation. HLA reported that the relative percentage difference (RPD) between primary sample and duplicates and triplicates and laboratory duplicates were all generally within the data quality objectives (DQO) of < 50%. HLA indicated that:
two data pairs for duplicate samples out of 355 data pairs reported RPDs greater than the DQO of 50%, with a maximum RPD of 136%; seven data pairs for split samples out of 130 data pairs reported RPDs greater than the DQO of 50% ,with a maximum RPD of 165 YO. relative percent differences could not be calculated for the majority of data pairs, as one or both data sets were below laboratory detection limits; HLA noted that most of the QA analysis results produced RPD values which complied with the DQOs for quality control samples as set out in the Australian Standard AS 4482.1 (Standards Australia 1997). The RPD values outside the acceptable range for the samples mentioned were either detected in samples representative of potentially heterogenous fill or were attributed to low levels detected, which accentuates variations when expressed as RPDs.
With the exception of three rinsate blank samples reporting zinc at trace levels (0.005 mg/L to 0.008 mg/L), laboratory analysis of the five samples collected, reported all other analytes below the laboratory detection limits.
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HLA also completed an assessment of the intra and inter-laboratory QNQC results, with almost all spike recoveries reported within the data quality objective range of 70-130%. No contaminants were detected in any method (reagent) blank analyses. The auditor notes that RPDS were not calculated if one or both of the sample pairs reported concentrations below detection limits. The auditor concludes that the small number of non- compliances with the DQO of 30-50% are not considered to significantly reduce confidence in the validity of the primary analysis data. The results were generally of the same order of magnitude and generally confirm the levels present. The auditor notes that the analyses were performed within the appropriate sample holding times. The auditor is satisfied on this basis that the RPD non compliances are acceptable and the QNQC results are satisfactory to support the data from the investigation.
4.8 Auditor’s Verification The auditor’s representative attended the site during the soil sampling work undertaken by HLA. During this inspection HLA were undertahng test pits in the open grassed area to the north east of the North Title. During this time the auditor’s representative was able to inspect the quality of soils in the north eastern part of the open paddock and the former natural pond. During the site inspection the auditor noted that site soils were generally free of staining. Soils in the north eastern part of the site were consistent with natural undisturbed soils. Soil within the former pond were also noted to be mainly natural or disturbed natural soils with minor rubble.
The auditor’s representative collected samples from two test pits in the north eastern area of the site. Soil samples were collected for independent testing from EB4 located within the former natural pond (settling pond) and EB5 located near the northern boundary. Surface soil (O.lm) samples from each test pit for were sent to ALS Environmental for independent analysis. Soil samples were analysed for contaminants of concern (metals, chlorinated compounds and volatile halogenated compounds). With the exception of trace metals detected at similar concentrations to HLA, analysis for organics reported concentrations below the laboratory detection limits. HLA also did not report any organics above detection limits. The laboratory reports for the auditor’s verification samples are included in Appendix F.
The auditor’s representative also visited the site whilst HLA was sampling the groundwater monitoring wells. The auditor’s representative observed HLA to be undertahng sampling using a low flow device and dedicated tubing. Samples were collected after the stabilisation of groundwater parameters had been observed. It was noted that groundwater sampling was undertaken in accordance with industry standards and good practice.
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On the basis of the auditor’s representative’s observations of HLA’s soil and groundwater sampling practices, it was concluded that the field works were to a standard likely to provide information and data suitable to support the conclusions of the audit.
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5. Groundwater Assessment
5.1 Scope of Groundwater Assessment Given the potential point sources identified at the site, a total of 7 new groundwater monitoring wells were installed at the site in 2004 (labelled as BH26G to BH32G). HLA was commissioned to undertake the drilling, installation and sampling of the proposed seven groundwater monitoring wells at the North Title. The location of the seven monitoring wells is shown in Figure 3 - Groundwater Monitoring Bore Locations (from HLA 2004''5'). The seven motioning wells targeted the following:
The natural pond in the north east grassed paddock, to assess for potential impacts from effluent such for chlorinated compounds and peroxides as well as nutrient from possible sewerage discharge; Near the suspected former UST located northeast of the Hardie Extrusion north store; At the western end of the Hardie Extrusion north store targeting component of PVC extrusions and any contamination from the substation; In the south west comer of the site, near the former effluent settling ponds, targeting likely components of plant effluent and contaminants from the neighbouring Qenos site; At the western end of the former effluent treatment plant, targeting components of plant effluent, contaminants associated with the electrical substation, metals and degradation products of organic catalysts; At the eastern end of the former effluent treatment plant, targeting components of plant effluent, diesel spill, degradation; In the drain in the south east comer of the site to target plant effluent, metals accumulation, potential diesel spills and potential contamination from the carpark. Monitoring wells BH26G to BH32G were installed on 4 and 5 March 2004. Groundwater monitoring wells were located in order to assess the quality of groundwater entering the site (BH30G and OSW34A (already present)) and groundwater leaving the site (BH26G) as well as on- site conditions.
A truck mounted dnll rig was used to drill the groundwater bores using solid flight augers in the shallow silty clays and air hammer in the basalt. The bores were licensed with Southern Rural Water (licence number 9019523). The drilling equipment was decontaminated prior to drilling each bore, in accordance with HLA protocols. Bores were drilled to depths from 11 to 13.7 m. Following installation, HLA developed the wells using a water lift pump, until low turbidity was obtained in groundwater. The auditor noted that screen intervals intersect the standing water level, enabling the measurement of any non aqueous phase liquid (NUL) if it was present on the water
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table. Overall the auditor notes that the bores were drilled, installed and developed in accordance with standard good practice.
During drilling of bores, all soil samples were logged in the field and subjected to visuallolfactory assessment. Soil samples were not collected for analysis from these bores. A soil sample was collected from the drill cuttings for the purpose of classifying soils for offsite disposal. The sample was analysed for an EPA screen. Borelogs showing the geology encountered are included in the HLA report (Appendix D of this audit report).
Groundwater bores BH26G to BH32G were sampled in March and in June 2004. A11 samples were collected using a low flow pump. A range of chemical parameters (DO, electrical conductivity, pH, temperature and Redox) were monitored whilst purgmg. Samples were collected once these parameters had stabilised. Gauging has indicated that groundwater is flowing to the southeast. Figure 5 shows the interpreted groundwater contours (from HLA'26').
HLA noted that during the March sampling round the three existing wells BHl4G and OSW34A could not be sampled due to obstructions within the wells and due to the lost time trying to sampling blocked wells BH15G was also not sampled. No other evidence of contamination was noted during the sampling rounds (ie floating NAPL).
HLA also completed adequate QNQC procedures including decontamination of the sampling equipment between events and the collection of QNQC samples including a rinsate sample, a trip blank and field duplicate and split.
5.2 Groundwater Analysis Results HLA Groundwater Sampling - March 2004
In order to assess impacts to the protected beneficial uses, HLA established that the following beneficial uses are applicable based on site TDS (5200-10,000 mg/L):
Maintenance of ecosystems; Stock watering; = Industrial water; = Primary contact recreation; and Buildings and structures. HLA considered that the uses of industrial water and buildings and structures were not relevant as there were no existing uses for industrial water in the area and given the depth of groundwater impacts to structures was not likely. On this basis, HLA adopted marine ecosystem protection guidelines (though these apply at the point of discharge to the nearest surface waterbody), stock
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/ 1 Altona North
Groundwater Contours m(AHD)
Groundwater Flow Direction I Note: OSW34A - not gauged due to obstruction I I L / \ INTERPRETED GROUNDWATER ELEVATION CONTOUR PLAN Orica Australia Pty Ltd Additional Assessment Works, North Title - Altona Properties Kororoit Creek Road, Altona North Metres
nnit Ami PROJECT-FILE NAME M4018201 DATE JUL 2004 -- .-1,..-1 ,rn Figure 5 - Interpreted Groundwater Contours ..i Environmental Audit
water and primary contact recreation guidelines for comparison to the analytical results to assess whether groundwater was polluted or contaminated. The auditor notes that the beneficial uses of industrial water supply is a protected and relevant use in an industrial area, but recognises that it is unlikely based on the absence of use data in the area. There are no readily identifiable water quality guidelines for industrial water use, so this use will not be considered in the discussion below.
Analysis of groundwater by MGT Environmental Consulting Pty Ltd for metals found: Copper at concentrations ranging between 0.003 mg/L to 0.014 mg/L exceeding the adopted ANZECC (2000) marine water 95% trigger level value of 0.0013 mg/L. Copper did not exceed the stock water and recreational use guidelines; Cobalt at concentrations between <0.001 mg/L to 0.001 mg/L consistent with the adopted ANZECC (2000) marine water 95% trigger level value of 0.001 mg/L; Zinc at concentrations ranging between 0.015 mg/L to 0.087 mg/L exceeding the adopted ANZECC (2000) marine water 95% trigger level value of 0.015 mg/L. Zinc did not exceed the stock water and recreational use guidelines; Selenium at concentrations of 0.013 mg/L in well BH27G and 0.012 mg/L in well BH29G exceeding the adopted ANZECC (2000) recreational use guideline of 0.01 mg/L; and Other metals were either below the laboratory detection limit or the adopted guidelines.
Sampling and analysis of groundwater for organics reported: Carbon tetrachloride was detected at a concentration of 0.008 mg/L in BH32G exceeding the adopted ANZECC (2000) guidelines for stock water and primary contact recreation of 0.003 ma-; = 1,l - dichloroethene was detected at a concentration of 0.005 mg/L in BH32G exceeding the adopted ANZECC (2000) guidelines for primary contact recreation of 0.0003 mg/L; All other organics were either below the adopted guidelines or the laboratory detection limits.
HLA also reported on the result of groundwater testing by Parsons Brinckerhoff in 2004 of monitoring wells BH14G, BH15G and OSW34A. HLA reported the following: Carbon tetrachloride was detected at a concentration of 0.01 mg/L in OSW-34A exceeding the adopted ANZECC (2000) guidelines for stock water and contact recreation of 0.003 mg/L;
' 1,l 4ichloroethene was detected at concentration of 0.004 mg/L in OSW-34A exceeding the adopted ANZECC (2000) guidelines for contact recreation of 0.0003 mg/L; and Chloroform was detected at a concentration of 0.01 mg/L in OSW-34A, but no groundwater quality objectives are available for chloroform.
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uses of groundwater were present, those uses were either considered not to be relevant for the proposed hture site use (primary contact recreation or stock water) or will be attenuated over the distance to the nearest surface waters. In the case of the metals, the reported concentrations are considered to represent background conditions. HLA recommended another round of groundwater sampling to confirm the levels detected. The groundwater data are summarised and provided in the referenced report(25).
HLA Groundwater Samdina - June 2004
During the June 2004 sampling event, HLA sampled a total of 9 monitoring wells which included BH14G and BHlSG, which were not sampled in March 2004.
Analysis of groundwater by the primary laboratory (Labmark Pty limited) for inorganics found: TDS was reported to range between 4520 to 10,500 mg/L; Copper at concentrations ranging between 0.002 mg/L to 0.008 mg/L exceeding the adopted ANZECC (2000) marine water 95% trigger level value of 0.0013 mg/L. Copper did not exceed the stock water and recreational use guidelines; Nickel at a. concentration of 2.12 mg/L (in BH14G) exceeding the adopted ANZECC (2000) marine water 95% trigger level value of 0.07, the recreational guideline of 0.1 mg/L and the stockwater guideline of 1 mg/L; Zinc at concentrations ranging between 0.0 16 mg/L to 0.083 mg/L exceeding the adopted ANZECC (2000) marine water 95% trigger level value of 0.015 mg/L. Zinc did not exceed the stock water and recreational use guidelines; and Other metals were either below the laboratory detection limit or the adopted guidelines.
Sampling and analysis of groundwater for organics reported: rn Carbon tetrachloride was detected at a concentration of 0.009 mg/L in BH32G exceeding the adopted ANZECC (2000) guidelines for stock water and contact recreation of 0.003 ma; 1,l 4ichloroethene was detected at a concentration of 0.003 mg/L in BH32G and 0.002 mg/L in BH31G exceeding the adopted ANZECC (2000) guidelines for contact recreation of 0.0003 mgn; rn Chloroform was detected at concentration of 0.009 mg/L in BH31G and 0.013 mg/L in BH32G but no groundwater quality guidelines are available for chloroform; and rn All other organics were either below the adopted guidelines or the laboratory detection limits. HLA noted that elevated concentrations of dichloroethene (up to 0.009 mg/L) and carbon tetrachloride (up to 0.013 ug/L) had been historically detected in the upgradient well OSW34A.
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?%E 27 Environmental Audit
HLA also tested a water sample from within a pit in the north store building and detected trace metals exceeding adopted guidelines but no organics and concluded that due to the low TDS ths was likely to be potable water or rainwater confined in the pit HLA concluded that, because the trace levels of organics detected in the site groundwater were detected at on-site locations BH3 1G and BH32G which are upgradient to known potential on-site sources and the organics were also present in the upgradient well OSW34-A (at the northern site boundary), the trace levels detected on site were from an off site source. Furthermore, the applicable beneficial uses were unlikely given the current and proposed future land use. The auditor discusses this further in section 5.4.of this report. The groundwater data are summarised and provided in the referenced report(26).
5.3 Groundwater QNQC The groundwater sampling and analysis program incorporated the following QNQC procedures: March 2004 Samdinq one blind duplicate sample was analysed at the primary laboratory (MGT) for metals and organics; one split sample was collected and analysed at the a secondary laboratory (US)and analysed for metals and organics; Two rinsate samples were analysed for metals and organics; One trip blank was analysed for metals and organics; Intra-laboratory QNQC protocols, including analysis of matrix spike/matrix spike duplicates, internal duplicate analysis and method (reagent) blanks at standard frequencies; and other QNQC protocols in accordance with HLA procedures, based on accepted good practice and relevant guidelines or Australian Standards. This included the use of low flow sampling pump, decontamination procedures, appropriate storage and preservation of water samples and appropriate chain of custody documentation. Duplicate and split sample analysis undertaken by HLA generally reported RPDs within the accepted data quality objective (DQO) of <30 to 50% for most analyte pairs. Generally all duplicate or split pairs reported concentrations below detection limits, therefore RPDs were not calculated. For those pairs where RPDs exceeded the DQOs, the exceedances were due to low concentrations close to detection limits which accentuates the RPDs. Analysis of the two rinsate blanks detected trace levels of copper (0.001 ma)in sample RBI and zinc (0.051 mg/L and 0.007 mg/L) in RB1 and RB2. All other analytes were below the laboratory detection limits. HLA indicated that the low levels of metals are not considered to be due to cross contamination but likely to have been present in the water used for rinsate water.
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Analysis of a trip blank reported concentrations below the laboratory detection limits. The auditor notes that most analytes were below the laboratory detection limits in both primary and secondary samples, therefore indicating good correlation in the results. Satisfactory intra-laboratory QNQC results were reported by MGT and ALS;
June 2004 Sampling During this sampling round the following QNQC was undertaken; lowering of the laboratory reporting limits for benzo(a)pyrene, 1 ,1-dichloroethene, 1.2 dichloroethane and carbon tetrachloride to ensure reporting limits were below the adopted guidelines. However, this was not achievable for benzo(a)pyrene and 1,l-dichloroethene. one blind duplicate sample was analysed at the primary laboratory (Labmark) for metals and organics; one split sample was collected and analysed at the secondary laboratory (ALS) and analysed for metals and organics; three rinsate samples were analysed for selected organics and metals; three trip blanks were analysed for BTEX; intra-laboratory QNQC protocols, including analysis of matrix spike/matrix spike duplicates, internal duplicate analysis and method (reagent) blanks at standard frequencies; and other QNQC protocols in accordance with HLA procedures, based on accepted good practice and relevant guidelines or Australian Standards. These protocols included the use of low flow sampling pump, decontamination procedures, appropriate storage and preservation of water samples and appropriate chain of custody documentation. Duplicate and split analysis undertake by HLA reported RPDs within the accepted data quality objective (DQO) of <30 to 50% for most analyte pairs. Generally all duplicate or split pairs reported concentrations below detection limits, therefore RPDs were not calculated. For those pairs where RPDs exceeded the DQOs (maximum RPD of 155%) it was due to concentrations close to detection limits accentuating the RPDs Analysis of the three rinsate blanks detected trace levels of zinc (0.012 to 0.052 mgL) in EB1 to EB3. All other analytes were below the laboratory detection limits. HLA indicated that the low levels of metals are not considered to be due to cross contamination but likely to be present in the rinsate water used. Analysis of the three trip blanks reported BTEX concentrations below the laboratory detection limits.
The auditor notes that most analytes were below the laboratory detection limit in both primary and secondary samples, therefore indicating good correlation in the results.
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Satisfactory intra-laboratory QNQC results were reported by Labmark and ALS for spiked sample recovery tests, with spike recoveries reported within the data quality objective range of 70-1 30%. No contaminants were detected in any method (reagent) blank analyses. The auditor notes that the analyses were performed within the appropriate sample holding times.
5.4 Auditor's Comments The auditor is satisfied that an adequate assessment of groundwater conditions has been completed, and that the groundwater data obtained over the numerous sampling events are representative of actual groundwater quality and are reliable for the purpose for which they have been obtained.
With regard to potential chlorinated organic impacts &om the site or offsite activities, with the exception of monitoring wells BH3 1G and BH32G, contaminant concentrations in all monitoring wells were within the adopted guidelines or not detected. Dichloroethene and chloroform detected in BH31G and BH32G were generally low and near detection limits. However these compounds have also been detected in OSW34A (upgradient of BH31G and BH32G and at the northern (upgradient) site boundary) at similar or higher levels. From the available data, the auditor concludes that contaminants detected in BH3 1G and BH32G are likely to be from an offsite source. Previous experience during an audit of the Dow site north east of the current audit site reported similar chlorinated organic contaminants in the groundwater, confirming the potential for regional impacts.
The concentrations of metals detected in groundwater at the site are not of significant concern and do not represent a condition of contamination or pollution. Concentrations of copper, nickel, selenium and zinc exceed the adopted marine ecosystem guidelines at one or more locations, but are within applicable guidelines for stockwater and recreational use, (other than for nickel at one bore in the southern area of the site) and are considered representative of background concentrations in the aquifer. There is no evident source of these metals at the site. In the auditor's opinion, no further groundwater investigation is required. However, the auditor has included a restriction on the extraction of groundwater at the site in the issued Statement of Environmental Audit, which recognises that exceedances of criteria for protected beneficial uses of stock water supply and primary contact recreation for some chlorinated hydrocarbons and nickel.
The groundwater investigation adequately targeted the potential groundwater contamination sources at the site and bores near the site boundary also adequately addressed the potential for off- sources off-site contamination to impact the site. Furthermore, TPH contamination was not detected in groundwater from BH3 1 which targeted the suspected UST. Environmental Audit
6. Auditor’s Review and Comments
6.1 Design of Site Investigation The auditor considers that the site soil contamination assessment was generally designed in accordance with good practice and relevant guidelines, in particular AS4482.1 - 1997 (Standards Australia 1997).
AS4482.1 recommends a sampling density of 55 grid based sample locations for an area of 5.0 hectares, to detect a circular hotspot of diameter of 35.6m (if one exists) with a 95% confidence. For the audit site of area 7 hectares, over 80 grid sample points were investigated during the course of the investigation at the site. The auditor is satisfied that the sample location coverage was sufficient to characteke the site in accordance with AS4482.1.
Given the history of the site, a number of potential point sources of contamination were identified at the site and these locations were adequately targeted. Talung into account the sampling plan, the history and overall site data and the nature of the potential contamination, the auditor is of the opinion that adequate “general and targeted” sample locations were investigated.
The sample locations and depths and analytes selected were consistent with site characteristics and history. The analytical program focused on the potential contaminants of concern VOCs, SVOCs, PAHs, TPWBTEX and metals but adequate samples were also analysed for other potential inorganic and organic contaminants, such as metalloids, organochlorine pesticides, phenols, fluoride and cyanide.
In addition HLA completed a detailed investigation in the area of a suspected underground storage tank.
6.2 Investigation Findings The general site soil assessment results provide adequate data to characterise the soil conditions at the site. With the exception of a localised elevated concentration of lead, concentrations exceeding the adopted NEPM HE F guidelines were not detected in soil at the site. Some metals/metalloids (specifically nickel) were noted at concentrations exceeding the adopted NEPM EILs but within the NEPM HIL A guidelines. All other sample locations contained concentrations within the guidelines for low-density residential use. Given the proposed future commercial or industrial use, no further soil investigation or remediation on the general site is required.
Based on the potential for groundwater contamination to have resulted from site activities, seven groundwater monitoring wells were installed. The locations of the wells were considered adequate in terms of assessing the site hydrogeology, and detecting potential impacts to groundwater from the site and offsite activities. Contaminants of concern chlorinated hydrocarbons were detected in
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groundwater at trace concentrations but exceeding relevant guidelines for the beneficial uses of stock water supply and primary contact recreation. However, these contaminants were detected in bores at or near the upgradient (northern) site boundary and are likely to be from off-site sources. Metals (specifically copper, nickel, selenium and zinc) were detected at concentrations above aquatic ecosystem protection guidelines, however these were considered to represent background levels and not to impact on the protected beneficial uses of the groundwater. The auditor was satisfied that the site activities had not polluted the site groundwater, however offsite contamination had likely impacted the site groundwater with the trace chlorinated compounds detected. The detected trace chlorinated compounds were not considered to restrict the use of the site for ongoing commercial or industrial use.
Summary of Soil Quality
The auditor has included in Appendix G, are Tables from the HLA assessment reports (2526) which summarise the soil quality data from the recent site contamination assessment, which represents the quality of remaining site soils. These tables include the health-based and ecologcal guidelines, which provide the principal basis for assessment of potential risks associated with contamination in soil.
The significance of the soil quality data in relation to these risks is discussed fbrther in Section 7 of this audit report.
Summary of Groundwater Quality
Also included in Appendix G, are Tables from HLA (25,26) which summarise groundwater quality data at the site. The significance of the groundwater data has been discussed in Sections 5 and 7 of this audit report.
Quality Control I Quality Assurance
The quality controVquality assurance measures incorporated into the soil and groundwater assessment and validation program have been evaluated by the auditor as generally satisfactory, and therefore the data for this program are considered suitable to support the conclusions of the assessment and this audit. QNQC issues are discussed in Section 4.7 of this audit report.
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7. Review of Health and Environmental Risks
This section of the audit report comments on the hazards and levels of risk potentially arising from the contamination status of the audit site. Potential effects on the human health of future residents, users or neighbours of the site and on-site or off-site environment have been considered in mahng this assessment.
7.1 Health Effects of Soil Quality Health-based soil quality investigation thresholds recommended by the Australian authorities (NEHF 1999) have been adopted as national guidelines (NEPC 1999, Schedule B(7a)). These health-based thresholds (HILs) are shown in the summary tables in Appendix F. These HILs are intended to be used for comparison with site average contaminant concentrations, with limitations also placed on individual sample concentrations and standard deviations of the data.
Human health is a protected beneficial use for all land uses under the SEPP for Prevention and Management of Contamination of Land (Vic Govt 2002). The SEPP refers to the NEPM HILs as the primary basis for adopting soil quality objectives for the protection of this beneficial use.
The available data reported for the samples collected during the soil investigation and validation program confirm that with the exception of the localised area (at sample location HA3) containing lead exceeding NEPM HIL A and F guidelines, the quality of remaining soil at the site with respect to metals and organics tested comply with human health-based guidelines for any land use, in particular NEPM (1 999) health-based investigation levels (HILs) for commercialhndustrial use.
Overall the auditor is of the opinion that, with respect to potential effects of soil quality on human health of future site users or occupants, the site is suitable for less sensitive use such as commercial or industrial without further investigation or remediation, on the basis that NEPM HIL F and NSW EPA guidelines for all contaminants of concern contained within the audit site boundary are complied with (excluding the minor exceptions noted below).
The elevated lead detected at HA3 in the transformer compound is considered acceptable for the ongoing commercialhndustrial site use as the impacted area is fenced off and site occupants will not come in contact with these soils.
7.2 Environmental Effects of Soil Quality 7.2.1 Overview
Other than the potential risks to human health posed by soil contamination on the audit site, as discussed in Section 7.1, the quality of land at the site may have potential adverse environmental (including ecological) effects. These environmental hazards and risks must be evaluated by the
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environmental auditor in determining whether or not the land at the site is detrimental or potentially detrimental to future beneficial uses of the site.
The potential environmental effects of contaminated soil on a site include:
= uptake of contaminants by plants grown on the site, with phytotoxic effects; toxic effects on soils organisms or fauna; air quality impacts from volatile emissions or dust; contamination of surface or drainage waters ponded on or flowing through the site, with secondary effects on water quality in nearby surface waters; and contamination of groundwater beneath the site, potentially with secondary effects on water quality in surface waters as groundwater flows discharge to surface waters.
These potential effects are considered below, with respect to this audit site.
7.2.2 On-Site Soil Quality Effects
Soil quality data were assessed against the NEPC (1999) interim urban ecological investigation levels (EILs), which are generally consistent with the ANZECC/NHMRC (1992) guidelines, in particular B-level thresholds of concern for environmental impacts. These threshold levels are mainly based on potential for phytotoxic effects on plants grown in site soils and are normally used to trigger further investigation or site specific risk assessment.
The SEPP for Prevention and Management of Contamination of Land (Vic Govt 2002) protects the beneficial use of maintenance of modified ecosystems for land used for standard or low density residential use, and the use of maintenance of highly modified ecosystems for high density residential or commercialhndustrial land uses. The relevant SEPP objective is that “contamination must not adversely affect the maintenance of relevant ecosystems” and that contaminant concentrations are not to exceed either the NEPM interim urban EILs or other risk-based levels. The ELLS are considered reasonably conservative for protection of modified ecosystems in an urban environment.
The available data reported for the assessment and validation samples confirm that the quality of soil at the site with respect to most metals/metalloids contamination is generally compliant with the NEPM (1999) interim urban EILs.
However, concentrations reported for nickel were in the range of 65 to 120 mgkg and commonly exceed the NEPM EL of 60 mg/kg. However, these concentrations are considered to be representative of natural background concentrations and are within the background range of 5-500 mgkg cited in NEPC (1 999).
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The elevated lead concentration of 3350 mgkg located at HA3 exceeds the NEPM EILs and was confirmed to be a localised hot spot. Accordingly, the auditor is of the opinion that: The soil material at the site may not be suitable for the growth of some sensitive plant species or for the support of sensitive soil ecosystems under some land uses, including sensitive (low density residential or similar) uses; The site is suitable for less sensitive uses of commercial or industrial (as proposed) where the soils will be either not exposed or accessible not expected to sustain healthy ecosystems or sensitive plants; and In the event that a more sensitive use is proposed in the future, the lead contaminated soils in the transformer compound should be removed and remaining soils validated.
7.2.3 Production of Food, Flora and Fibre
The SEPP (Prevention and Management of Contamination of Land) protects the beneficial use of production of food, flora and fibre for the feasible land use of (sensitive) low density residential or similar uses. The objective requires that contamination of the land shall not adversely affect produce quality or yield and must not cause the concentration of any contaminant in food, flora and fibre to exceed that level specified in the Australia New Zealand Food Authority’s Food Standards Code. In the absence of specified soil quality guidelines for this beneficial use, it is generally accepted practice to compare soil contaminant concentrations with the NEPM EILs. As noted in Section 7.2.2 above, site soils contain naturally occurring exceedances of the EIL for nickel, and localised soil at the transformer compound contains significant excedence of the EIL for lead. The auditor concludes that this beneficial use is protected at the site in its current condition except at the transformer compound but would be hlly protected following the further remediation recommended in Section 7.2.2.
7.2.4 Air Quality The relevant Government policies are the State Environment Protection Policy (Ambient Air Quality) and SEPP (Air Quality Management). At the time of the completion of this audit, the site surface comprised stable soils, and was not considered to pose any significant risk to air quality.
The audit site has negligible potential to contribute to air pollution from volatile contaminant emissions since no volatile contaminants were detected in soils present on the site.
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7.2.5 Aesthetic Effects
The SEPP for Prevention and Management of Contamination of Land specifies aesthetics as a protected beneficial use for all feasible land uses for this site, with the objective that “contamination must not cause the land to be offensive to the senses of human beings.”
Odorous or stained soils were not detected at the site during the course of the investigation. On the basis of the work completed at the site, the auditor is satisfied that the aesthetic conditions of site soils are not offensive, and that the beneficial use of aesthetics is protected for any feasible future use of the site.
7.3 Groundwater and Surface Water Issues 7.3.1 Groundwater Effects
Section 3.4 of this audit report contains brief information on the hydrogeology and likely classification of groundwater in the area.
The relevant policy for groundwater quality protection is the State Environment Protection Policy for Groundwaters of Victoria (Vic Govt 1997). The SEPP specifies the beneficial uses to be protected for groundwater, and sets out water quality objectives and an attainment program to maintain quality consistent with these objectives.
In accordance with EPA guidelines to auditors (EPA 2002), the auditor must consider whether groundwater at the site is likely to be polluted from activities on (or in the vicinity of) the audit site. The auditor considered that a number of operations/features at the site represented a potential groundwater contamination source, and these were adequately addressed by a staged groundwater investigation program. Based on the concentrations reported for contaminants of concern:
some metals (copper, zinc, selenium, nickel) were present at concentrations above guidelines for protection of aquatic ecosystems. However, these concentrations are generally considered to be representative of naturally occurring background conditions. The elevated Nickel concentrations at BH14G is anomalous and, in the absence of any feasible site source, appears to be a localised natural effect. This concentration also exceeds the guidelines for stock watering and primary contact recreation; and chlorinated hydrocarbons were detected in groundwater sampled from the upgradient on-site monitoring wells, indicating that the groundwater is polluted with respect to the beneficial uses of stock water supply and primary contact recreation, but from an unidentified regional offsite source or sources. It is recognised that the site itself may have contributed to groundwater contamination through historical storage or application of industrial wastewaters on the north- eastern paddock.
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The auditor is satisfied that the site historical land uses are unlikely to have caused pollution of groundwater elsewhere at the site and this conclusion is confirmed by the groundwater investigation program.
The auditor concludes, on the evidence available, that groundwater at the site is “polluted” with respect to some protected beneficial uses. However, the elevated contaminant concentrations are likely to be attributable to natural background conditions (in the case of metals) or regional sources (in the case of chlorinated hydrocarbons). Furthermore, the beneficial uses of groundwater which are precluded (or potentially precluded) are unlikely to be realised under commercialhndustrial land uses (stockwater supply or primary contact recreation) or will be realised remote from the site (aquatic ecosystems).
However, as much of the site is undeveloped paddocks, it is feasible that this land may be used for stock grazing and so abstraction of groundwater for stock is a possible use.
No groundwater clean up is required (or feasible). The auditor has recognised the presence of groundwater pollution in the Statement of Environmental Audit issued for this site and places restriction on future extractive groundwater uses.
7.3.2 Surface Water Effects
The site is in the catchment of tlie Port Phillip Bay, as described in Section 3.3. The beneficial uses, water quality objectives and attainment program to maintain appropriate water quality for surface waters in this catchment are set out in the State Environment Protection Policy (SEPP) for the Waters of Victoria (Vic Govt 2003), which incorporates Schedule F6: Waters of Port Phillip Bay (Vic. Govt 1997, as varied by Vic Govt 2003).
Past and present site conditions have negligible potential to contribute to contamination of surface waters on the site, or in the catchment beyond the site boundaries, for the following reasons:
the soil conditions on the site do not present a significant potential source of surface water contamination via stormwater runoff; and rn groundwater at the site is not significantly polluted and is not likely to have a significant impact on surface water quality following discharge to surface waters;
7.4 Buildings and Structures
The SEPP for Prevention and Management of Contamination of Land protects the beneficial use of buildings and structures for all land uses. The objective is that “contamination must not cause the land to be corrosive to or adversely affect the integrity of structures or building materials.” The
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Environmental Audit
indicators of soil quality with respect to this objective are pH, sulfate, Redox potential, salinity or other relevant chemical substance or waste.
In this case, the soil pH is relatively neutral to alkaline, with maximum of 1 1.6 but typically within the background range of 6-8 pH units (ANZECC/NHMRC 1992) and sulfate concentrations were well within the NEPM ELL of 2,000 mg/kg. There is no evidence from the former land uses or site conditions that other contaminants are present whch may pose a risk to buildings and structures. There are no significant hydrocarbon concentrations to indicate the presence of contaminants which may attack or pass through plastic pipes.
The auditor concludes that the site does not present a significant risk to future buildings and structures on the site.
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8. Audit Conclusions and Statement of Environmental Audit
8.1 Conclusions Based on the assessment of all available relevant information about site conditions on the site located at 585 - 609 Kororoit Creek Road, Altona, which is subject to this audit, and the health and environmental considerations outlined in this audit report, the environmental auditor concludes that: Prior to 1962 the site was vacant land. In 1962 BF Goodrich acquired the North and South Titles and developed the South Title for PVC manufacture. The North Title (the site subject to this audit) was mainly vacant land until the 1970s when the land was leased to Hardie Extrusions, who established a warehouse (north store) in the north west part of the site. The extrusion plant operated until 1990, when Hardie Extrusions relinquished their lease. The North Title site also contained some peripheral equipment/structures for the PVC production on the South Title (non audit area) including a catalyst store, water tanks and fire fighting Pump.
A staged environmental assessment and validation program for soil quality was undertaken, in accordance with relevant guidelines and the auditor's requirements, which adequately characterised the soil conditions on the site;
Soil at the site was found to have concentrations of nickel and lead at levels which exceed ecosystem protection guidelines at a number of locations. These nickel concentrations are considered to represent background levels and not evidence of contamination, whilst the lead contamination is representative of a localised hotspot. Other analytes tested for in fill and natural soil were within the relevant guidelines for ecologxal protection under all feasible land uses. The beneficial uses of ecosystem protection and production of food, flora and fibre are protected other than at the area with localised lead contamination; Lead was detected at a concentration exceeding the adopted human health guideline within the transformer compound on the west of the north store. This was found to be localised within the caged transformer area and is considered to not present significant risk to future site occupants whilst human access is restricted. Other analytes tested for in fill and natural soil were within the relevant guidelines for human health protection under all feasible land uses; Based on the CMPS&F assessment reports, the auditor considered that there was the potential for a former UST to be present at the site, and required an investigation into its presence to be undertaken. A 5 x 15 m area was excavated to assess for the presence of a former or existing tank. The investigation by HLA did not detect the presence of a tank, backfilled tank pit or residual hydrocarbons. HLA concluded that the tank had been removed or was never present;
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f) A groundwater assessment was carried out at the site to identify contamination, which may have resulted from a number of potential sources (suspected underground tank, north store operations, catalyst store, etc). The investigation detected trace concentrations of dichloroethene, carbon tetrachloride and chloroform marginally exceeding the adopted guidelines for stock water supply and/or primary contact recreation uses, however these were detected in on-site wells up-gradient of potential site sources. Similar contaminants were detected in a monitoring well located near the northern boundary and up-gradient of these wells, indicating a potential regional impact. It was concluded that site concentrations are likely to be from an unidentified regional off site source. Concentrations reported for copper, nickel, selenium and zinc in groundwater were found to slightly exceed water quality guidelines for aquatic ecosystem protection. These exceedances were, however, considered not to be significant as they are likely to be naturally occurring levels. Concentrations were typically within relevant guidelines protective of on-site groundwater uses (stockwater supply etc), with the exception of the isolated nickel occurrence (considered naturally occurring); g) The past use of the site and its current condition do not present a significant risk of contamination of surface waters or the air environment. The site does not contain significant aesthetic evidence of soil contamination. The' beneficial use of buildings and structures is protected. The auditor is of the opinion that the environmental condition of the site is potentially unsuitable for some sensitive land uses (such as residential), due to the presence of metal (lead) concentrations above ecological investigation levels (EILs) and exceeding the HIL A and D guidelines for residential use and the NEPM HEF guidelines for commercial or industrial use in the transformer compound. The elevated lead concentration within the transformer compound is considered acceptable for ongoing commercialhndustrial use while this area remains fenced off. If the transformer area is decommissioned then this area should be either cleaned up or capped with a suitable surface bamedlayer. Groundwater is unsuitable for extractive uses on parts of the site as a result of offsite or regionally elevated concentrations of some chlorinated hydrocarbons and a localised elevated nickel concentration. The auditor is of the opinion that the environmental condition of the site is suitable for less sensitive uses of commercial and industrial use (as proposed) without further investigation or remediation.
8.2 Statement of Environmental Audit
After considering the issues described in this audit report, and having prepared this audit report in accordance with Section 53X of the Environment Protection Act 1970, the environmental auditor is
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of the opinion that the site subject to this audit is detrimental or potentially detrimental to some beneficial uses of the site. Accordingly, the auditor has not issued a Certificate of Environmental Audit for the audit site at Lot 1, 585 - 609 Kororoit Creek Road, Altona. The auditor has issued a Statement of Environmental Audit in accordance with Section 532 of the Act. The Statement confirms that the site is suitable for beneficial uses associated with the land uses of commercialhndustrial subject to conditions relating to the management of soils.
The Statement of Environmental Audit is attached to this audit report (see following pages).
8.3 Auditor's Signature on Audit Report This environmental audit report is signed and dated by the environmental auditor (below).
I/ R A Graham
Environmental Auditor
(appointed pursuant to the Environment Protection Act 1970)
Dated
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ENVIRONMENT PROTECTION ACT 1970 STATEMENT OF ENVIRONMENTAL AUDIT Lot 1,585 - 609 Kororoit Creek Road, Altona, Victoria I, RICHARD ALAN GRAHAM of Sinclair Knight Merz Pty Ltd, 590 Orrong Road, Armadale, Victoria 3 143, 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:-
been requested by Peter Home of Orica Australia Pty Ltd, to issue a Certificate of Environmental Audit in relation to the site located at Lot 1,585 - 609 Kororoit Creek Road, Altona , Victoria; comprising land defined by Certificate of Title Vo108460 FolO87 and being Lot 1 on Title Plan 334090V (“the site”), owned by Altona Properties Pty Ltd;
1. had regard to, among other things, -
(1) guidelines issued by the Authority for the purposes of Part EDof the Act;
(ii) the beneficial uses that may be made of the site; and
(iii) relevant State environment protection policieshndustrial waste management policies, namely the State Environment Protection Policies for the Prevention and Management of Contamination of Land, Groundwaters of Victoria, Waters of Victoria, Ambient Air Quality and Air Quality Management;
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 2. 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 the land uses of agricultural, commercial and industrial, subject to the following conditions attached thereto: a) Lead contaminated soils in the transformer compound in the north-westem area of the site shall be isolated fiom occupants or users of the site (other than during maintenance work in the transformer compound) by maintaining the existing fence around this compound (or similar). If the fence is to be removed soils in this area shall be removed fiom the site or capped with concrete or a minimum of 0.5m of clean soil.
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b) Groundwater shall not be abstracted f?om.the site for any purpose other than monitoring or clean up. 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:
R A Graham ENVIRONMENTAL AUDITOR (appointed pursuant to the Environment Protection Act 1970)
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Appendix A List of Documents Reviewed
Australian and New Zealand Environment and Conservation Council (1992). Australian Water Quality Guidelines for Fresh and Marine Waters, November 1992. ANZECC/ARMCANZ (2000). Australian and New Zealand Guidelines for Fresh and Marine Water Quality, October 2000. Australian and New Zealand Environment and Conservation CouncilhJational Health and Medical Research Council (1 992). Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites. Department of Conservation and Natural Resources, Victoria (1995). Victorian Groundwater Beneficial Use Map Series. South-Western Victoria Water Table Aquifers. Department of Planning and Housing Victoria (1 992). Minister's Direction No. 1: Potentially Contaminated Land. As amended 14 May 1992. Environment Protection Authority of NSW ( 1994). Contaminated Sites: Guidelines for Assessing Service Station Sites. EPA Publication No. 94/119, December 1994. Environment Protection Authority of Victoria (2004). Classification of Wastes. EPA Information Bulletin, Publication No. 448.1, February 2004. Environment Protection Authority of Victoria (2002). Environmental Auditor (Contaminated Land) Guidelines for Issue of Certificates and Statements of Environmental Audit. EPA Publication759b. Original version May 200 1, reissued June 2001, and effective from 1 July 2001. Amended June 2002. National Environmental Health Forum (1 999). Health-based Soil Investigation Levels. National Environmental Health Forum Monographs Soil Series No. 1, Third Edition (forms Schedule B(7a) to NEPC 1999). 10) National Environment Protection Council (1 999). National Environment Protection (Assessment of Site Contamination) Measure 1999. NEPC Service Corporation, December 1999. 11) National Health and Medical Research CounciVAgncultural and Resource Management Council of Australia and New Zealand (1996). Australian Drinking Water Guidelines. 12) Standards 'Australia (1997). Australian Standard AS4482.1-1997: Guide to the Sampling and Investigation of Potentially Contaminated Soil. Part 1: Non-volatile and Semi-volatile Compounds. September 1997. 13) Swartjes, F.A (1999). Risk-Based Assessment of Soil and Groundwater Quality in the Netherlands: Standards and Remediation Urgency. Risk Analysis, Vol 19, No 6, 1999. 14) US Environmental Protection Agency Region 9 (200 1). Preliminary Remediation Goals (PRGs) Update. Access from www.epa.gov/regionO9/waste/s~nd/prg/
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15) Worksafe VictoridEPA Victoria (2003). Draft Industry Standard for Identifying and Assessing Occupational Health and Safety on Contaminated Sites. Draft for Public Comment, August 2003. 16) Victorian Government (1997). State Environment Protection Policy for Groundwaters of Victoria. Victorian Government Gazette, 17 December 1997. 17) Victorian Government (1999). State Environment Protection Policy (Ambient Air Quality). Vic. Govt. Gazette. 9 February 1999. 18) Victorian Government (200 1). State Environment Protection Policy (Air Quality Management). Vic. Govt. Gazette, 21 December 2001. 19) Victorian Government (2002). State Environment Protection Policy (Prevention and Management of Contamination of Land). Vic. Govt Gazette No. S95,4 June 2002. 20) Victorian Government (2003). State Environment Protection Policy (Waters of Victoria). Victorian Government Gazette No. S107,4 June 2003. Incorporates Schedule F6: Waters of Port Phillip Bay (August 1997, varied by Vic Govt 2003). 21) VROM (2000). Ministerial Circular on Target and Intervention Values for Soil Remediation. Reference DBOA999226863. 22) Figure and Summary Laboratory Tables from “Auseon Australia Due Diligence Review Soil Assessment, Kororoit Creek Road, Altona” by CMPS&F Pty Ltd, dated 1995. 23) Auseon Limited, Environmental Baseline Report, by CMPS&F Pty Ltd, dated 1997.
24) Phase 1 Site Assessment - Altona Properties, North Title, for Orica Australia, by Parsons Brinckerhoff Pty Ltd, dated 14 April 2004. 25) Final Report, Groundwater Investigation, North Title, Altona Properties, for Orica Australia Pty Ltd, by HLA Envirosciences Pty Limited, 27 April 2004. 26) Additional Assessment Works, North Title, Altona Properties, for Orica Australia Pty Ltd, by HLA Envirosciences Pty Ltd, 17 September 2004.
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Appendix B Certificates of Title
SlNCLAlR KNIGHT MEW Cipertrlcrt of Sustainability and Environment
~ ~ ~____~ ~~~~ ate of Victoria. This publication is copyright. No part may be reproduced by any process except in accordance with the provisions of the (right Act or pursuant to a written agreement. The information from the Register of Land is only valid at the time and in the form obtained from ANDATAB System. The State of Victoria accepts no responsibility for any subsequent release, publication or reproduction of the information.
GISTER SEARCH STATEMENT Land Titles Office, Victoria Page 1
'urity no : 124009120997C Volume 08460 Folio 087 Produced 09/02/2004 01:16 pm ID DESCRIPTION 1 on Title Plan 334090V (formerly known as part of Lot 1 on Plan of )division 052190). .ENT TITLE Volume 08460 Folio 085 ated by instrument B546603 16/11/1962 iISTERED PROPRIETOR ate Fee Simple e Proprietor AVC PROPERTIES PTY. LTD. of LEVEL 2/575 BOURKE ST MELBOURNE 3000 V159450K 18/12/1997
TJMBRANCES, CAVEATS AND NOTICES
Any encumbrances created by Section 98 Transfer of Land Act 1958 or Section
24 Subdivision Act 1988 and any other encumbrances shown or entered on the plan set out under DIAGRAM LOCATION below. iGRAM LOCATION : TP334090V FOR FURTHER DETAILS AND BOUNDARIES
,LING ACTIVITY IN THE LAST 105 DAYS
I
,TEMENT END
Account: 20300 Order: 3359845 Title 8460/087 The Place To Be Page 1 of 1 I t 1 iLE PLAN I 1 EDITION 1 I TP334090V
Nolations Omtion of Land
'artsh TRUGANINA Ownshtp ecbon :rown Allotment rown Porhon aslPlan Reference:LP52190 lerived From: VOL 8460 FOL 087 leplh Limitation: NIL \NY REFERENCE TO MAP IN THE TEXT MEANS THE DIAGRAM SHOWN ON I THIS TITLE PLAN
Description of Land I Easement Information THIS PLAN HAS BEEN PREPARED FOR THE LAND REGISTRY. LAND VICTORIA, FOR TITLE DIAGRAM PURPOSES AS PART OF THE LAND TITLES AUTOMATION PROJECT COMPILED. 25/02/2000 VERIFIED: BH
h P F t 2
AREA = 17A 3R 2 9110P
I TABLE OF PARCEL IDENTIFIERS I WARNING: Where multiple parcels are referred to or shown on this Title Plan this does Inot imply separately disposable parcels under Section 8A of the Sale of Land Act 1962 I I PARCEL 1 = LOT 1 (PT) ON LP52190 I
LENGTHS ARE IN Metres = 0.3048 x Feet FEET INCHES Sheet 1 of 1 sheet Mebes = 0.201168 x Links
TP334090V, Page 1 of 1, Printed 13:16 09/02/2004, Search Enquiry 3359845, Customer 20300 Department of Sustainability and Environment Folio History Report Page 1 of 1
Produced: 910212004 1:57: 18 PM Volume 08460 Folio 087
Folio Creation : Created as paper folio continued as computer folio Parent Titles: Volume 08460 Folio 085 The Image of the Folio ceased to be the Diagram Location on 25/09/2002 05:Ol am
RECORD OF ALTS DEALINGS
Date Lodged for Date Recorded Dealing Imaged Dealing Type and Details Registration on Register
STATEMENT END
LAND VICTORIA, 570 Bourke Street Melbourne Victoria 3000 P.O. Box 500 East Melbourne Victoria 3002, DX 250639 -Telephone:-(03)-8636-201O-Facsimile~-(0-3)-86-36-2005-~~ -- ABN 907 19052204