INFORMATION REGARDING ENVIRONMENTAL AUDIT REPORTS
August 2007
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ENVIRONMENTAL AUDIT REPORT * LOT 1, RIVER ROAD, MILLGROVE, VICTORIA FOR MR DAVID SHERRIFF
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Dames & Moore June 19% 23251\001 2 of 44 - DAMES & MOORE - 25 BUCKHURST STREET, SOUTH MELBOURNE, VICTORIA, 3205 AUSTRALIA TELEPHONE: (03) 696 3344, FACSIMILE: (03) 696 3006
2 June 1992
Environment Protection Authority of Victoria Oldeffleet Building 477 Collins Street MELBOURNE VIC 3ooo
Attention: Mr Carsten Osmers
Dear Si,
RE: ENVIRONMENTAL AUDlT REPORT FOR LOT 1 RIVER ROAD, MILLGROVE, VICTORIA
Please find enclosed a copy of our environmental audit report on the above site. This report incorporates the Auditor's Environmental Adit Report, Dames & Moore's Assessment report for the site carried out in 1991 as requested by Mr Sherriff and a Certificate of Environmental Audit.
We trust that it meets your requirements. However, should you have any queries or require any assistance with this matter, please do not hesitate to contact our Mr K Mival, or the undersigned.
Yours faithfully DAMES & MOORE Pn LTD
- AnthonyPLane Manager - Geoscience and Engineering
3 of 44 OFFICES IN PRINCIPAL CITIES THROUGHOUT THE H'ORLD DAMES & MOORE PROPRIFTARY LIMITED A.C.N. 003 293 696 Mr D SMff - Environmental Audit Repit, Millpve Page i 29 May 1992
ENVIRONMENTAL AUDIT REPORT LOT 1, RIVER ROAD, MILLGROVE, VItXORIA FOR MR DAVID SHERRIFF
Dames & Moore were engaged on 12 August 1991 by Mr David Sherriff to carry out an Environmental Site Assessment of a property located at Lot 1, River Road, Millgrove, Victoria. It was recommended following that assessment, that some remediation of soil be undertaken, to raise pH and lower sulphate levels. This was undertaken by Mr Sherriff and Dames & Moore were commissioned to execute a secondary phase of investigation and validation sampling to assess the state of the site following completion of the remedial programme.
The works to date have been undertaken as part of the regulatov process for the proposed rezoning of the site from a Rural 1 Zone to a Landscape Living 2 Zone by the Shire of Upper Yarra. The purpose of the study was to provide Mr Sherriff with information regarding the environmental quality of the site to satisfy the Upper Yarra Shire council with regard to their requirements for rezoning of the properties for residential development.
The scope of work for the investigation, remediation and validation of the site included the foll-
e A review of the information provided by Mr Sherriff and information collected from the public record;
e An inspection of the site to determine potential sources of contamination and the most appropriate soil sampling locations;
e A phased site investigation including sampling and testing of soils for investigative and validation purposes;
e Advising Mr Sherriff on the environmental quality of the site and the need for remedial works to allow for rezoning of the land,
e A final phase of validation sampling on 16 April 1992.
R6295.001
DAMES& MOORE4 of 44 Mr D Shemff - Environmentul Audit Report, Millgrove Page ii 29 May 1992
This report surmnarises the results of all of the investigations and testing carried out on the site, and contains the Auditor's Environmental Audit Report and the Certificate of Environmental Audit.
The site is located approximately 76 km to the east of Melbourne and 2 lan west of Warburton. It is defined as Lot 1 on the Plan of Sub-Division No. 3553, Parish of Ywnga in the Shire of Upper Yarra on the Certificate of Title Vol. 8251, Fol. 668.
The site is underlain by consolidated rock comprising siltstone and minor sandstone of the Humevale Siltstone Formation, and Rhyodaates of the Acheron Sub-Group, both of Devonian age. In the areas of lower topography adjacent to the Dee and Yarra Rivers, Quaternary age scree fan deposits and stream-deposited sediments comprising gravel, sand, silt and clay are present.
The status of groundwater usage in the area is not known. However, the groundwater can be considered as having a beneficial environmental use.
The property was purchased in 1959 by Mr Sherriff. During his ownership of the site, it has been used for agricultural purposes only and there is no evidence to suggest that the land has ever been used for industrial purposes by him or previous owners.
Some use of pesticides was reported. A spotspraying method was used which was last conducted approximately 4 years ago. No other pesticides were used. Superphosphate was applied in previous years, but has not been used recently. 'Nocattle dip tanks are present on the property and according to Mr Sherriff, no dips have ever been used on the animals he has kept.
Some disposal of wastes from the pig farming has taken place. Some small waste pits are present on the site. These were investigated for this report. This is the only evidence of any landfill on the site. More recently, waste effluent from the pigs has been spray-irrigated over the lower lying parts of the site to the south of the house and farm buildings, below the 145 m AHD contour. We understand that the pig sheds were washed down with water and that no chemical additives have ever been used for this purpose.
A detailed inspection was carried out of all parts of buildings and of the surrounding land in order to idenw where any potential sources of contamination might exist on the site and to confirm the information supplied by Mr Sherriff. An aboveground tank remains on the site. However there have been no reported spills in the past. The area around the tank was inspected for indications of past spillage.
R6295.001
DAMES& MOORE5 of 44 Mr D Sm- EnvirvnmeruaJ Audit Rept, Millgrove Pqe iii 29 May 1992
An initial soil contamination investigation was carried out on 23 and 24 September 1992. The second stage of field work was carried out on 16 April 1992 following a remediation programme undertaken by Mr Sheniff to neutralise the pH of soils at the site and also redm the sulphate concentrations. A laboratory testing programme was performed by MGT Environmental consultants Pty Ltd (MGT), a laboratory accredited with NATA.
The assessment performed by Dames & Moore at this site has been performed in accordance with the ANZEC guidelines. Considering that there will be a future change in Zoning, adoption of the EPA WM91/01 - Clean Ed criteria was considered to be the most appropriate.
From the results of the assessment, the risk to human health or potential for environmental impact due to the possible presence of low levels of contaminants in the soil at the site is considered to be negligible. The low pH results and some elevated sulphate results, however, were of some concern. However this concern only relates to the potential for corrosion of concrete due to high sulphate levels.
Prior to remediation a large proportion of the test results did not meet the established criteria. Subsequent to the remediation operation, only three isolated samples from soils that currently remain on site fail the criteria agreed with the Auditor. Considering each subarea and the site as a whole, these three results are considered acceptable within the ANZEC guidelines and by the EPA appointed Auditor. Concrete structures constructed in the soil at the site should not be adversely affected by the moderate sulphate concentrations in the soil.
It is considered that the remediation undertaken by Mr Sherriff has been sUCCeSSfLlZ and the current condition of all the soils on site is considered by the Auditor to be acceptable for the proposed beneficial land use. All the work was carried out under the direct supervision of an EPA appointed Auditor. The site is therefore considered to be acceptable for the intended rezoning for more sensitive usage (residential). A few areas showing elevated sulphate levels (greater than 300 ppm) and low pH levels (less than six) exist on site, but in the context of the site as a whole are considered insignificant.
& DAMES MOORE6 of 44 Mr D Sheniff .Environmental Audit RepH. Millgrove Page iv 29 May 1992
TABLE OF CONTENTS Page No. EXECUTIVESUMMARY ...... i
1.0 INTRODUCTION ...... 1 1.1 BACKGROUND ...... 1 12 PURPOSE ...... 1 13 SCOPE OF WORK ...... 1 1.4 STUDYTEAM ...... 2
2.0 PHYSICAL SETTING OF THE SITE ...... 4 2.1 LOCATION AND LAND USE ...... 4 22 GEOGRAPHICSETI'ING ...... 4 23 HYDROGEOLOGY ...... 5 23.1 Geology and Aquifers ...... 5 2.32 Groundwater Flow Systems ...... 6 2.33 Groundwater Quality and Usage ...... 6
3.0 mULm OF THE INVESTIGATION ...... 7 3.1 SITEHISTORY ...... 7 3.2 SlTEINSPECTION ...... 8 33 SOILSAMPLING ...... 9 3.4 LABORATORY TESTING ...... 10 4.0 ASSESSMENT OF CONTAMINATION ...... 16 4.1 BASIS OF ASSESSMENT ...... 16 42 SOIL~NTAMINATION ...... 17 43 GROUNDWATER CONTAMINATION ...... 18
5.0 CONCLUSIONS ...... 19 5.1 QUALITY OF WORK COMPLEI'ED ...... 19 5.2 ENVIRONMENTAL QUALITY OF THE SITE ...... 19 53 CERTIFICATE OF ENVIRO-AL AUDIT ...... 19 6.0 LIMITATIONS OF THIS REPORT ...... 20
7.0 ENVIRONMENTAL AUDITOR'S REPORT AND CERTIFICATE OF ENVIRONMENTAL AUDIT ...... 21
R6295.001 DAMES6r MOORE 7 of 44 Mr D Sheniff - Enhnmental Audit Rem, Millpve 29 May 1992
LIST OF FIGURES
FIGURE 1 LOcALrnPLAN FIGURE 2 SKEI%H SITE PLAN FIGURE 3 DETAILED SlTE PLAN BUILDING AREAS
LIST OF APPENDICES
APPENDIX A TlTLES INFORMATION APPENDIX B PHOTOGRAPHIC RECORD APPENDIX C BOREHOLE LOGS APPENDIX D1 LABORATORY RESULTS - ASSESSMENT APPENDIX D2 LABORATORY RESULTS - VALIDATION APPENDIX E EPA "CLEAN FILL" CRITERIA WM91/01
R6295.001 DAMES& MOORE 8 of 44 ENVIRONMENTAL AUDIT REPORT LOT 1, RIVER ROAD, MILLGROVE, VICTORIA FOR MR DAVID SHERRIFF
1.0 INTRODUCI'ION
1.1 BACKGROUND
Dames & Moore were engaged on 12 August 1991 by Mr David Sherriff to ca~yout an Environmental Site Assessment of a property located at Lot 1, River Road, Millgrove, Victoria. It~was~ecommended~folldwing thatggsessment, that. some I;emediation The works to date have been undertaken as part of the regulatory process for the proposed rezoning of the site from a Rural 1 Zone to a Landscape Living 2 Zone by the Shire of Upper Yarra. The location of the site is indicated in the Locality Plan, Figure 1. The proposed sub-divisions are indicated on the Sketch Site Plan, Fgure 2. A find audit report for the site and Certificate of Audit is now required by the Council for the rezoning application as discussed with Mr Sherriff. 1.2 PURPOSE The purpose of the study was to provide Mr sherriff with information regarding the environmental quality of the site to satisfy the Upper Yarra Shire Cound with regard to requirements for rezoning of the properties for residential development. The objectives of the study were to assess the potential for and significance of soil contamination on the basis of site history studies and sampling and testing of soil at strategic locations on the site, and to assess the effectiveness of remediation carried out on the site. 13 SCOPEOFWORK The scope of work was outlined in Dames & Moore's proposals dated 7 August 1991 for the original phase of work and 14 Apnll!J92, for the final phase of work The scope of work included: 0 A review of the information provided by Mr Sherriff and information collected from the public record, induding topographic and geologic maps and land titles infomation; DAMES& MOORE 9 of 44 Mr D Shenjff - Enrironmental Audit RW,MUpve Pqge 2 29 May 1992 0 An inspection of the site to determine potential sources of contamination and the most appropriate soil sampling locations; 0 A phased site investigation including sampling of soils for investigative and validation putposes and laboratory testing by MGT Environmental consultants Pty Ltd (MGT), a laboratory accredited with the National Associatian of Testing Authorities of Australia (NATA); 0 An additional site inspection was required for engineering geological purposes to examine some areas of suspected land slip and dope stability problems; and 0 Advising Mr Sherriff on the environmental quality of the site and the need for remedial works to allow for remning of the land. The site was inspected by Dames & Moore on 21 August 1991. The initial site investigation sampling was undertaken on 23 and 24 September 1991. The final phase of validation sampling was &ne on 16 April 1992. In additional to the foregoing the site was also inspected by a Senior Engineering Geologist of Dames & Moore on 28 April 1992, to assess the geotechnical stabiity of parts of the site. This report summarises the results of all of the investigations and testing carried out on the site, and contains the Auditor's Environmental Audit Report and the Certificate of Environmental Audit requested. This report has been compiled utilising information presented in the Preliminary Environmental Site Assessment (Dames & Moore Document Number Rs504.001) presented to Mr Sherriff on 13 November 1991. A separate report has been prepared by Dames & Moore (Doc. No. R6305.001) which covers the assessment of the geotechnical stability of parts of the site where development is proposed. 1.4 STUDY TEAM The Dames & Moore study team Was led initially by Ms Julie Willrinson (Senior Environmental Scientist) and later by Ms Trudi pilz (Senior Geotechnical Engineer), initially under the direction of Mr Nick Withers (former Principal, Hazardous Waste Services) but more recently Mr Anthony Lane (Manager, Geoscience and Engineering). h4r Withers is an EPA appointed Environmental Auditor and has continued to act as quality control consultant to the study and adviser on Environmental Audit matters and has issued the attached Certificate of Audit in his capacity as Auditor. R6295.001 DAMES& MOORE 10 of 44 Mr D Shenff - Enhnmental Audit Repori, Millgrove 29 May 1992 The site interview and inspection was undertaken by Mr Craig Beck The site inspection for engineering geological purposes was undertaken by Mr Ken Mid (MorEngineering Geologist). The investigative field work was carried out by Iha Mantmis (Environmental Scientist) and Neville Wome (Technical Assistant) and subntract services of MGT environmental (a NATA registered laboratory) for laboratory testing. & DAMES MOORE11 of 44 ~ Mr D She?@ - Enhnmenial Audit Repmt, Millgrove pase 4 29 May 1992 2.0 PHYSICAL, SE'ITING OF THE SITE 2.1 LOCATION AND LAND USE The site is located approximately 76 lan to the east of Melbourne and 2 lan west of Warburton. ItWdef&zl awbt+l dn sthe Rlan. ofi Sub-Division No. 3553, Parish of Yuonga in the shire of Upper Yarra on the Certificate of Title Vol. 8251, Fol. 668. A copy of this certificate is induded in Appendix A. The site is located on River Road.which runs along the Yarra River from Warburton Highway to the site. The total property consists of approximately 40 ha, of which the area of land below the 180 m contour, comprising approximately 20 ha is proposed to be rezoned. The site is currently zoned Rural 1. It is understood that the site has been used almost dusivdy for agricultural purposes. It is proposed to rezone the property to a Landscape Living 2 Zone. The property is bordered by other rural properties to the east, a sports camp to the west, the Yarra River to the south and the lower slopes of Mt Donna Buang to the north which are extensively forested. . There are residential sub-divisions on the south side of the Yarra immediately to the south of the property and also other sub-divisions approximately 1 kilometre to the east. 2.2 GEOGRAPHIC SElTING The Warburton area has a temperate climate typical of the south-central region of Victoria having cool wet winters and warm dty summers. Rainfall is approximately twice that of the City of Melbourne and environs. ~Dhh&g~~.~esuIte&tiithe .slightly, acidic nature of$the .soils. in the region. Monthly summaries of meteorological data from the nearest weather station at Powelltown (approximately 15 lan to the south) are presented in the following table. It should be noted that the Powelltown meteorological station is currently non-operational. R6295.001 & DAMES MOORE12 of 44 Mr D Sheniff - Environmental Audit Report, Millgrove Page 5 29 May 1992 TABLE 2.1 METEOROLOGICAL DATA - POWELLTOWN On a regional scale, surface water drainage would be in either a south or south-westerly direction towards the Dee and Yarra Rivers, which abut the western and southern boundaries of the site respectively. The Warburton area lies within the Great Dividing Range and shows variable topographic relief. 23 HYDROGEOLOGY 23.1 GeologyandAquifen The north and northwest parts of the site are underlain by consolidated rock comprising siltstone and minor sandstone of the Hmevale Siltstone Fo~mation,and Rhyodacites of the Acheron Sub-Group, both of Devonian age. Joints and fractures in these rocks provide the pMapal avenue of growlwater movement. A high density of johts and &dent intercOnneCtions allows the formation of a flow system which can be considered a fractured bedrock aquifer. The upper section of the rocks may be weathered to form silty clays and clays which may form a semi-confining layer to the underlying aquifer. R6295.001 & DAMES MOORE13 of 44 Mr D Sheniff - Environmental Audil Report, Mipve Page 6 29 May 1992 In the areas of lower topography adjacent to the Dee and Yarra Rivers, Quaternary age scree fan deposits and stream-deposited sediments comprising grad, sand, silt and clay are present. The water table aquifer in these sediments is in direct hydraulic connection with the streams. The sediments may be up to 15 m thick and are underlain by the dtstone and minor sandstone rock of the HumevaIe Siltstone. Recharge from rainfall infiltration to the bedrock aquifer occurs over much of the bedrock outcrop area and is greatest in areas where soil cover is thin and the land has been cleared of natural vegetation. Groundwater flows away from points of higher elevation to discharge to the stream sediments or as springs or seeps at the juncture of the hill slopes and the river flats. Recharge to the stream sediments occurs directly via rainfall infiltration and indirectly by groundwater flowing from the bedrock aquifer. Seasonal variation in the water table level and adjacent stream levels provides seasonal flow between the watertable aquifer and the streams. In summer months, groundwater discharge to the streams may provide an importaut component of stream flows. 233 Groundwater Quality and Usage Groundwater in the bedrock aquifer would provide low yield bores with a salinity, measured as Total Dissolved Solids (TDS), in the rauge of 500 to lo00 mg/l. This water is of the upper range of the limit that would be acceptable for domestic supply but would be suitable for stock use. The sediments assOciated with the local streams and rivers would contain groundwater suitable for domestic purposes (ie TDS less than 500 mg/l). Bore yields would be variable in the range 05 to greater than 5.0 Lis. The status of groundwater usage in the area is not known, however as the discharge of groundwater from the watertable in the stream sediments provides an integral part of the total stream water balance, this groundwater can be considered as having a benefiaal environmental use. DAMES& MOORE14 of 44 Mr D Shenjff - Enhnmenial Audit Rep,Millgrvve 29 May 1992 3.0 RESULTS OF THE INVESTIGATION 3h&titl'i search iiidicates that-the property was purchased from the Melbourne Cig Newsboys' Society &I 1959 by Mr D S Serfiff. During Mr Sherriff's ownership of the site, it has been used for agricultural purposes only and there is no evidence to suggest that the land has ever been used for industrial purposes. Aerial photographs indicate that the only building on the site between 1946 and 1959 was a timber house and that all of the existing buildings were constructed after Mr Sheapurchased the land. Mr Shedhas indicated that the original timber house was built in 1905 and demolished in 1975 to be replaced by the current brick residence. Mr. Sheniff also confirmed that all of the other buildings on the properly were built after the land was purchased in 1959. From 1966 to 1979 a commercial dairy was operated on the site by the Melbourne City Newsboys' Wety. The dairy building and assOciated yards are not currently utilised but still remain on the site. The piggery operation commend in 1%7 and ceased in late 1991. According to Mr. Shed,qg&&il3M&herbia&es (24-D and 2,4;5-T)-have been used to control Ragwd and Blackbemy in the north-eastem comer of the site. A&spot-sprayingmethod was used which was last conducted approximately 4 years ago. No other pesticides were used. Superphosphate was applied in the years when the dairy was operating but has not been used since. Mr Shed also indicated that no cattle dip tanks are present on the property and no dips have ever been used on the animals he has kept. Disposal of lopped trees, brush and waste oils has been by burning at random locations around the site. During the operation of the dairy, water was used to clean the floors and detergents used to clean equipment. A dam once existed where waste from the piggery would collect 0;igUre 3). At least 10 years ago, this waste material was cleaned out and placed into several pits to a depth of 1 metre. The pits were topped up with fill material of unknown origin. The largest of these waste pits was measured at 11 metres at the longest point and 3 metres at the widest point. This is the only evidence of any landfill on the site and Mr Shed has advised that all rubbish, other than that in the abovementioned burnings, have always been taken to the local municipal landfill site. More recently, waste effluent from the pigs has been spray-irrigated over the lower lying parts of the site to the south of the house and farm buildhp, below the 145 m AHD contour. According to Mr Shed, R629S.Wl DAMES& MOORE 15 of 44 Mr D Shenj6T - EnvironmentaI Audit Repa, Millgrove Pqe 8 29 May I992 three to four thousand gallons of effluent was disposed of every day using a mobile sprinkling system. It is understood thatthe pig sheds were washed down with water and no chemical additives have ever been used for this purpose. A 10oO litre above ground diesel tank remains on the site but, according to the Mr Sherriff, this has not been used for several years and there have been no reported spills in the past. The area around the tank was inspected for indications of past spillage. 3.2 SlTEINSPECIlON Prior to the start of field work on the site, a detailed inspection was carried out of all parts of buildings and of the surrounding land in order to identify where any potential sources of contamination existed on the site and to confirm the information supplied.by Mr Sherriff. Access to the property was provided on 21 August 1991 and attention was given to routes for potential contamination of the soils beneath the buildings. The fabric of the buildings was not examined in detail as this was not included in the brief. However, it should be observed that the walls of the sheds where the pigs were housed are constru& from asbestos cement sheeting. This is not considered to be detrimental with regard to soil contamination, but the potential occupational health and safety hazard assOciated with disturbance of this material should be taken into account when subsequently these buildings are cleared from the site. Note was taken of any indications of potential sources of soil contamination. The site topography ranged from flat land in the south at approximately 135 m AHD to steep slopes in the northern part of the site rising to 215 m AHD. The section of land which has been investigated in this audit and which is being considered for rezoning in the planning amendment, includes only those areas which occuf at or below the 180 m contour 0;gure 2). The site is divided into a number of small paddocks and is transected by two main watercows and a number of smaller gullies which drain into the Yarra River. A gravel road is constructed from River Road, through the central portion of the site to the house and other farm buildings. These other buildings include an old dairy, the pig &eds, a feed storage building and a combined machinery and storage shed (Figure 3). One of the watercourses on the site separates the dairy from the remaining farm buildings. The land, when used as a piggery, had a permit for 10oO head, although there were usually only up to 700 animala on the properly at any one time. The piggery had a breeding stock of 100 sows and young were raised and sold at 4 to 6 months of age. The sows were housed in the two smaller sheds on the site and the young in the larger shed behind these. In addition to these buildings, there are two storage tanks, one used DAMES& MOORE 16 of 44 Mr D Shenff - Enhnmensal Audir Repa, Millgrove Page 9 29 May I992 for feed storage and the other used for temporary storage of effluent from the piggery prior to disposal. Additional use of the site included cattle grazing for the production of calves. There are 5 waste pits on the site which have been used to dispose of effluent, a burn pit for solid wastes and a lime pit for disposal of dead stock (apprmimately 20-25% of young pigs died within the first few weeks of birth and were &ped of in the pit). The waste pits were all inspected for this audit. Inspection of the lime pit uncovered some small bones but no putrescent or obnoxious waste. The fe*dWiedknexttto The large shed nearer the house appears to be used as a general work area. A section of this shed has a cement floor and is where machinery is stored. Dames & Moore was advised by Mr Sherriff that minor repairs on fann automobiles have also been undertaken in this shed and small stains of oil were visible on the floor. The shed was also seen to house small quantities of the following; lubricating oils, mineral turpentine, 2,4-D herbicide, horse feed, waste oil drums, and paht. General photographs of the site are included in Appendix B for reference. 33 SOILSAMPLING soil sampling was carried out in two phases: *Phase-1: An initial investigation was carried out on 23 and 24 September 1992 at the site, during which 21 locations were sampled. This utilised backhoe excavation (7 locations) and hand auger techniques (14 locations) for retrieval of soil samples. The approximate locations of all the sampling holes are indicated on the Sketch Site Plan, Fwe2. sampling intervals were based on field observations. Where possible three samples were taken at each location and generally taken over 05 m intervals. Each auger hole was logged, noting geological and geotechnical descriptions of the soil and any evidence of contamination. The logs of all the sample holes are included in Appendix C. R6295.001 DAMES& MOORE17 of 44 Mr D Sheniff - Environmental Audir Re-, Millpve Page 10 29 May I992 The locations of the Sample holes were chosen on the basis of the results of the site inspection and initial information review to determine areas of potential contamination. A HNu Photoionisation Detector (PID)with a 102 eV lamp, calibrated with 104 ppm isobutylene gas was used to detect possible volatile organic emissions from each of the locations. No such volatile emissions were detected during the field investigation. *EKSe+! Tlfe-secondcLstage~oft field,wor;k ,was carried out on 16 April 1992 following a remediation prog-me undertaken by Mr Sherriff4tomeutmlise the pH of soils at the site and also reduce the sulphate Coqcentrations. wkccmkted.of- sampling at 17 additional locations Using a hand auger for retrieval of samples for investigative and validation purposes. The samples were limited to the surface layer interval only (that is 0 to 05 m). It also included sampling under some buildings that were previously intended to be demolished and have now remained on the site. All field investigations at the site were carried out by Dames & Moore in accordance with a site smc Health and Safety Plan prepared by Dames & Moore that takes into account relevant statutory Health and Safety requirements. The technical quality of the work was assured by compliance with the Dames & Moore Standard Operating Procedures for environmental sampling. Table 3.2 presents a typical soil profile for the site, interpreted from the borehole logs. TABLE 3.2 GENERALISED SOIL PROFILE - Soil Types Depth Range (m) Location Silt 0 to 0.5 Over entire site Clayey SAND 0.1 to 1.5 In vicinity of pig shed/dairy etc Clayey SILT/Silty CLAY 0.5 to 1.5 Over entire site 3.4 LABORATORYTESTlTVG The laboratory testing propamme was based on the review of the site history information which identified a potential for the following list of analytes 0 Heavy Metals (copper, arsenic, lead, nickel, zinc, cadmium, mercury, chromium); 0 Total Petroleum Hyd~ucarbns(TPH); 0 A screen for PolycycJic Aromatic Hydmxbons (PAH); R6295.001 DAMES& MOORE18 of 44 Mr D Shemff- Enh- Audit Reporl, Millgrove Page 11 29 May 1992 A screen for Organochlorine pestiades; e Anions (nitrate, sulphate and chloride); PH; and Monocyclic Aromatic Hydrocarbons: benzene, toluene, ethyl-benzene and xylene (BTEX). Initial laboratoly testing was limited to surface samples (i.e., generally Over the interval 0 to 05 m) only. Eight representative samples from the site were screened for volatile hydrocarbons (including benzene, toluene, ethyl benzene and xylene). The Photoionisation Detector (PID) measurements made during the field work provided no indication of the presence on the site of volatile hydrocarbons, but the screening tests were carried out as a precautionary measure. The laboratoly testing was performed by MGT Environmental Consultants Pty Ltd (MGT), a laboratoly accredited with NATA. AU laboratoly results and analytical methods are presented in Appendix D. TABLE 3.3 LABORATORY TEST METHODS AND REPORTING LIMITS Method I Reporting Limit Nitrate Victorian EPA 0.5 November 1981 Method 11 Sulphate NSW Dept of Main Roads 20 Method T1011 Chloride Victorian EPA 20/5 November 1981 Method 17 O/C Pesticides USEPA Method 8080 0.01 I PAH USEPA Method 8310 1 0.5/0.2 11 Moisture Content Victorian EPA November 1981 Method 4 I Victorian EPA November 1981 Method 5 I II TPH USEPA 418.1 (IR) 50 Petroleum Hydrocarbons MGT 1OOA (GC) (CI5-cd 20 (C lo-c 1J 50 (Cl5%J 100 (C29-Cd 100 & R6295.001 & DAMES MOORE19 of 44 * Mr D Shenff - Envhnmenral Audit Rep,MiugrOve Page 12 29 May 1992 I Method I Reporting Limit Benzene USEPA Methods 8020 and 5030 0.01 Toluene USEPA Methods 8020 and 5030 0.01 Ethyl Benzene USEPA Methods 8020 and 5030 0.01 Xylene USEPA Methods 8020 and 5030 0.05 Total MAH USEPA Methods 8020 and 5030 0.10 Victorian EPA Pub. No. 139 10 Method 13 Victorian EPA Pub. No. 139 10 Method 13 Zinc Victorian EPA Pub. No. 139 10 Method 13 Chromium Victorian EPA Pub. No. 139 10 Method 13 Nickel Victorian EPA Pub. No. 139 10 Method 13 Arsenic Victorian EPA Pub. No. 139 5/10 Method 13 Cadmium Victorian EPA Pub. No. 139 1 II Method 13 Mercury Victorian EPA Pub. No. 139 0.01 10.1 Method 16 The Qdity control (QC) measures applied to the laboratory testing programme comprised the testing of blind duplicate samples submitted by Dames & Moore, and also internal QC checks on batches of analytS by the laboratory. AU analysis of duplicate samples is relevant to the quality of testing by MGT for the project. The results of the @ty control testing blind duplicates are presented in Table 3.4 below. Table 35 presents the results of internal quality control testing by MGT on duplicate samples from the site. The results of the duplicate aualyss are considered to be within acceptable limits for the test methods used by MGT. It is also amsidered that the quality of the data is acceptable with minor variances being attributed to inhomogeneity of the sample soils and equipment errors. R6295.001 DAMES& MOORE 20 of 44 Mr D Sheniff - Environmenial MiRep, Millgrove Page 13 29 May 1992 Note: All results m mg/kg TABLE= Qc RESULTS - p0LwI"WxIC AROMATIC HYDROCARBONS I1 I Sample 11 Analyte I I TPIO-0.5 I TPI 0 - 0.5 Duplicate !I NaPm- C0.5 C0.5 Acenapthyl- C0.5 C0.5 Acsnapthene C0.5 DAMES& MOORE 21 of 44 ~~~ Mr D Sheniff - Environmental Audit Report, Miugrove Pqe 14 29 May 1992 Sample Analyte HA19 0 - 0.5 HA19 0 - 0.5 Duplicate copper e10 c10 Lead 13 13 - zinc 48 39 Arsenic 11 13 Cadmium c1 c1 Nickel 40 c10 Chromium 55 60 TABLE 98b QC RESLLT8: MQT WPLICATES - OR(3ANocHLoRINES Sample - Analyte ’ HA210-M HA210-0.5 TPIO-05 TPIO-0.5 woo2 HA35002 Duplicate Duplicate Duplicate Lindane C0.M Aldrin co.01 Dieldrin C0.M co.01 co.01 co.01 c 0.01 co.01 DDE co.01 c 0.01 co.01 co.01 co.01 co.01 Endrin C0.M co.01 co.01 co.01 co.01 co.01 DDD co.01 co.01 co.01 co.01 co.01 C0.M DDT co.01 co.01 co.01 co.01 co.01 co.01 R6295.001 DAMES& MOORE 22 of 44 Mr D Sw- Entironmental Audit Repout, Millgrove Page 15 29 May 1992 TABLE= Qc RESULTS: MOT WPLICATES - TPH, ANIONS Sample HA19 HA19’ TPS TPS’ HA15 HA15’ HA20 HA#)’ k@35 k@35’ 0-0.5 0-0.5 0-0.5 0-0.6 0-05 0-05 0-0.5 0-05 w2 w2 I1 ANIONS II Note: 1 -Duplicate 41 resUk8 h mQ/kQ TABLE 3bd QC RESULTS: MOT DUPLICATES - PAHS HA36 001 HA35 001 Duplicate Napm- C0.5 cos I AceMpthylene co.5 c 0.5 I I C0.5 I co.5 II 8enzo(€lhi)m- co.1 co.1 hdeno(l.2-3 wrene co.1 co.1 FU29UM1 DAMES&Z MOORE23 of 44 ~ Mr D Sheniff - Environmental Audir Report, Millgrove Page 16 29 May 1992 4.0 ASSESSMENT OF CONTAMINATION 4.1 BASIS OF ASSESSMENT The guidelines for performance of a site contamination assessment which apply in Victoria are those presented in the "Guidelines for the Assessment and Management of Contaminated Sites", Australian and New zealand Environment Gxmcil (January 1992), known as the ANZEC guidelines and the National Health and Medical Research council (NHBiMRC). The guidelines for the management of soil derived from contaminated sites are provided in the EPA waste management circular WM91/01 "Off-site Disposal of contaminated soil". The assessment performed by Dames & Moore at this site has been performed in accordance with the ANZEC guidelines. The results of the laboratory testing have therefore been compared with the soil quality acceptance criteria adopted under these guidelines. These criteria are equivalent to the so-called Dutch "A" "B" & "C" criteria for soil and groundwater contamination. The "Dutch A" criteria are equivalent to natural (low) background levels (although the CSIRO has shown that soils in Australia have a wide range of background "contamination"levels which can exceed those set by these criteria); the "Dutch B" criteria are higher than Dutch A and are levels at which one may have cause to investigate further if the circumstances warran@ the "Dutch C" criteria are higher (generally five to ten times) than the B values and contamination above the c values generally indica& that some form of contamination management strategy is prudent. mg WA~tend~~~~the%tchrBS values~avemged across the whole of the Site (except for the value for lead of up to 300 ppm) as indicativesof a quality suitable for residential land use. The most recent revision of the ANZEC Guidelines, January 1992, has adjusted some of the accepted criteria to be compatible with other international criteria established from a number of sources. According to EPA WM91/01 the maximum levels acceptable for classification of soil as clean fill generally correspond with the Dutch "B" values except for lead which is set higher at 300 mg/kg. However, higher lW&ri3fhwn$imination can be acceptable, such as for industrial land use, as long as leaching of contaminants to gr@pdwater is not unacceptable and EPA can be convinced of the merit of the proposed criteria .alternative. This is compatible with the revised ANZEC guidelines which emphasise a site spedfic approach to relate the nature and degree of contamination to the size of the Site and proximity to sensitive land uses such as residential. considering that the site is to be sold for development and there will be a future change in mning, adoption of the EPA WM91/01-(;lean Fa criteria dkssed above may be the most appropriate. These criteria are included in Appeadix E for reference R6295.Wl DAMES& MOORE24 of 44 Mr D Sw- En&vnntental Audit RepH, MUpve Page 17 29 May I992 42 SOILCONTAMINATION In discussion with the EPA appointed auditor, it was agreed that all soil results for the analytes tested, other than the anions, were considered acceptable for the intended land use, as these were h&wAtheiEWM%& EilldEdteiia focstherespective analyks. Therefore, the risk to human health or potential for environmental I impact due to the possible presence of low levels of contaminants in the soil at the site is considered to be negligible. *TlieWiG pH results and some elevated sulphate results, however, were of some concern. Hqxexer this\ concern relates to the potential for corrosion of concrete due to high sulphate levels. The maximum level of sulphate in a neutral soil (ie pH =7 at WC)considered acceptable in the ANZEC guidelines is 2,m mg/kg. In agreement with the EPA appointed auditor, the criteria adopted for this assessment relates also to the pH of the soil. Eo5 asp&&of&ss-than’ 6, a sulphate level in excess of 300 mg/kg was dderedunacceptable. Prior to remediation a large proportion of the test results did not meet the established criteria. Subsequent to the remediation operation, the following table summarises the few samples from soils that currently remain on site which fail the above mentioned criteria. Sub-Division Sample PH Sulphate Number (mg/kg) 1 HA33 4.56 530 2 HA28 4.69 860 3 HA24 5.40 330 Taking an areal analysis of all soil results available for the site, the average pH and sulphate results for each designated area of the site are presented in the following Table 42below. DAMES& MOORE 25 of 44 Mr D Shenff - Environmental Audit Repn, Millgrove Pqge 18 29 May I992 TABLE 4.2 AREAL ANALYSIS OF pH AND SULPHATE RESULTS Area NoofpH MeanpH Standard No. of Mean Standard Analyses Deviation Sulphate Sulphate Deviation PH Analyses (mg/kg) Sulphate (m g1 kg) 7 1 5.53 1 260 8 1 6.22 1 20 Site 25 5.51 0.66 19 209 201 Average considering each subarea and the site as a whole, these results are considered acceptable within the ANZEC guidelines and by the EPA appointed auditor. Concrete structures constructed in the soil at the site should not be adversely affected by the moderate sulphate concentrations in the soil. If there is any 1 concern for long term performance of concrete structures on the site, these can be designed with concrete resistant to sulphate attack -- It is considered that the remediation undertaken by Mr SheM has been successful, and the current condition of all the soils on site is considered to be acceptable for the proposed beneficial land use in the form of residential subdivisions. 43 GROUTUDWATER CONTAMINATION Groundwater contamination was not investigated as it was considered not to be an issue on this site because: 0 the relatively low led of soil amtamination would not provide a source of contamination &dent to affect groundwater. and 0 the clayey nature of the lower strata of alluvial and residual soils in the area would retard contaminant transport in the soil to potential aquifers. R6295.001 DAMES& MOORE 26 of 44 Mr D Shet@ - EnhnmentaJ Auciir RepH, Mlgrove Pqt? 19 29 May 1992 5.0 CONCLUSIONS 5.1 QUALITY OF WORK COMPLETED One of the critical aspects of site contamination assessment is establishing the quality and therefore the reliability of the data used in the assessment. This can normally be assured by adopting proper quality assurance/qualitycontrol(QA/QC) procedures and controls for the site assessment. These prdurescover the definition of contaminant sources by qualified staff: 0 review of site histoy, 0 use of written procedures for soil sampling; 0 decOntamination of sample equipment; 0 documentation of the sampling chain of custody; 0 duplication of samples and other quality control procedures for the laboratory testing; and 0 use of qualified personnel to perform the work according to the prdures. Dames & Moore undertook all of the above QA/QC procedures in exemtion of this contamination assessment axtd therefore the reliability of the results is confirmed. AU the work was carried out under the direct supervision of an EPA appointed Auditor. 5.2 ENVIRONMENTAL QUALITY OF THE SITE The site is considered to be acceptable for the intended rezoning for more sensitive usage (residential). A few areas showing elevated sulphate levels (greater than 300 ppm) and low pH levels (less than six) exist on site, but in the context of the site as a whole are considered insignificant. 53 CERTIFICATE OF ENVIRONMENTAL AUDIT As discussed with Mr Sherriff, this assessment and the second stage validation of the remediation measures was required as a step towards the issue of a Certificate of Audit under Section 57AA of the Environment Protection Act. Mr sherriff has formally requested the validation of the clean-up of the site and the production of an audit certificate from Mr NJ. Withers in his personal capacity as an EPA appointed environmental auditor in a letter dated 14 April 1992. The EPA was informed of the request by Mr Nick Withers as required by the auditors guidelines. This assessment report is now issued to the EPA for their information. The Certificate of Audit is included at the end of this report in Section 7 and is issued for the whole of the site. R6295.001 DAMES& MOORE 27 of 44 Mr D Sheniff - Enlrironmental Audit Repn, Millpve Page 20 29 May 1992 6.0 LIMITATIONS OF THIS REPORT We have prepared this report for Mr David Sherriff in accordance with generally accepted consulting practice. No other warranty, expressed or implied, is made as to the professional advice indicated in this report. This report has not been prepared for the use by parties other than the client, the leasees of the site, and their respective consulting advisers. It may not contain sufficient information for the purposes of other parties or for other uses. It is recommended that any plans and spedications prepared by others and relating to the content of this report, or any amendments to those plans and specifications, be reviewed by Dames & Moore as part of this report, also be reviewed by Dames & Moore to verify that the intent of our recommendations is properly reflected in the design or specifications. Whilst to the best of our knowledge information contained in this report is accurate at the date of issue, subsurface conditions, including groundwater levels and contaminant concentrations can change in a limited time. This should be borne in mind if the report is used after a protracted delay. There are always some variations in subsurface conditions across a site which cannot be fully defined by investigation. Hence it is unlikely that the measurements and values obtained from sampling and testing during the investigation will represent he extremes of conditions which exist within the site. R6295.001 Q DAMES MOORE28 of 44 Mr D Shem'ff - Enlrironmenral Audit Rep,Millgrove Pqe 21 29 May 1992 7.0 ENVIRONMENTAL AUDITOR'S REPORT AND CERTIFICATE OF ENVIRONMENTAL AUDIT The Environmental Auditor's Report and the Certificate of Environmental Audit are attached on the following pages. DAMES &MOORE PTYLTD Manager - Geoscience and Engineering Senior Engineering Geologist R62!B.O01 DAMES6r MOORE 29 of 44 ENVIRONMENT PROTECTION ACT 1970 SECTION 57AA CERTIFICATEOFENVIRONMENTALAUDIT DAMES& MOORE 30 of 44 424 St Kilda Road Melbourne Vic 3004 Tel: (03)867 2400 Fax: (03)820 1940 ICF PTY. LTD. AC.N.052 328 239 3 June 1992 Mr A P Lane Dames & Moore Pty Ltd 25 Buckhurst Street SOUTH MELBOURNE 3205 Dear Sirs, Re: Environmental Audit Report for Lot 1, River Road, Millqrove, Victoria I have reviewed the work performed by Dames & Moore Pty Ltd and their Report No.23251/001/R6295.001 of 29 May, 1992 for the assessment of the conditions of land at Lot 1, River Road, Millgrove, Victoria. The purpose of this review was to ascertain whether or not a Certificate of Audit could be issued for this land, pursuant to Section 57 AA(2) of the Environment Protection Act, 1970. My findings are described in the attached Audit Report with attached notes. Please ensure this letter and its attachments are bound into your report, which should then be submitted to EPA. Yours faithfully, N.J. Withers Manager Environmental Engineering Enc . 31 of 44 ICF PTY. LTD. X3DIT REPORT for LO^ 1, River Road, Millgrove, Victoria a. Name of Auditor Mr N J Withers b. Date of AppoinLment as 15 January, 1991 Auditor Last Reconfirmed 16.4.92 C. iqame of Person Requesting Mr D Sherriff A Certificate of Audit d. Address of the Site Lot 1, River Road, Millgrove, Victoria 5. Completion Date of Audit 29 May, 1992 11 ~ ~~ f, Documentation Reviewed Dames €iMoore Proposals of 7 lily 1991 and 14 Apr 1992 D&M Report No.R5504.001 dated 13 Nov 1991 D&M Report No.R6295.001 dated 29 May 1992 rg, Quality & Completeness of Both are acceptable - see Prior Assessments attached notes h. Verification of Assessors conclusions - nature and extent of Acceptable - see attached I contamination notes - potential effects of Acceptable - see attached 1 contaminated soil/ground notes Acceptable - see attached notes See attached notes, and Acceptable Acceptable Acceptable Not Applicable j. comment on any risks for The site is understood to be ongoing site activity currently inactive P k. Assessment of ComFat- A Certificate of Audit may ibility of proposed be issued development with site 32 of 44 ICF PTY. LTD Attached Notes for Audit Report for Lot 1, River Road, Millqrove, Victoria 1. The contents of Dames & Moore Report R6295.001 of 29 May, 1992 include : (1) an adequate description of the history of the site; (2) records of observations from visual site inspection; (3) sufficient details of the hydrogeology of the site; (4) maps indicating the location of buildings, water courses, tanks, waste disposal areas and site activities; (5) the results of the sampling and analysis programme, reported in an acceptable way. 2. The scope of the sampling and analytical programme is acceptable. I am satisfied the procedures used for sampling and analysis conformed to those specified which themselves were acceptable. The level of quality control applied by Dames & Moore is acceptable. The quality control results for the analyses indicate the results are of acceptable quality. 3. I endorse Dames & Moore's assessment of the contamination at this site. Specifically : J7 (1) The only matter of concern for the soil was its low pH and elevated sulphate levels. This has now been remedied to acceptable levels. (2) The soil acceptance criteria cited in the Dames & Moore report are those I approved for this site. J (3) The area/analysis method for comparing the soil pH and sulphate data with the criteria is endorsed. (4) The concentrations of all contaminants measured are considered to pose negligible threats to surface or ground water at the site. 4. The combination of analytical results, with the visual and visual/olf actory observations reported by Darnes & Moore provide sufficient basis to decide that a Certificate of Audit may be issued for this site. 33 of 44 ENVIROIWEN" PROTECTION ACT 1970 SECIlON 51M CERTIFICATE OF ENVIRONMENTAL AUDIT I, N. J. Withen of ICF Pty Ltd, formerly of Dames & Moore Pty Ltd, a person appointed by the Environment Protection Authority ("the Authority) under the Environment Protection Act 1970 ("the Act") as an environmental auditor for the purposes of the Act, having: 1. been requested by Mr DWSw, of Lot 1 River Road, Millgrove, Viina, to issue a certificate of environmental audit in relation to the land located at the above addms on Lot No I of Sub- Dieon No 3553 of the Parish of Yuonga in the Shire of Upper Ymon the Ckri@cate of me Vdume 8251 Fdio 668 in the Stale of Victoria ("the site") owned and presently Occupied by Mr David S-. 2. had regard to, amongst other things: 0) guidelines issued by the Authority for the purposes of Section 57AA of the Act; (i) the beneficial uses that may be made of the land at the site; and (i) relevant State environment protection policies/industrial waste management policies, 0 EPA Information Bulletin "Interim Advice on Approaches to Determine whether a Site is Potentially Contaminated" Public No. 269, December 1989. 0 EPA Information Bulletin "offsite Disposal of Contaminated Soil", WM91/01. 0 EPA Information Bulletin "Environmental Auditors Contaminated Land", WM90/04,February 1991. 0 EPA Explanatory Notes "Environmental Auditor System Contaminated Land", WM90/04,March 1991. 0 ANZEC "Australian Guidelines for the Assessment and Management of contaminated Sites", Jan 1992. 0 State Environment Protection Policy No. W-29.(Waters of the Yarra River and Tributaries). 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 relevant segment at the site by any industrial process or activity, waste or substance (including any chemical substance); and 3. completed an environmental audit report in accordance with Section 57AA(2) of the Act, a copy of which has been sent to the Authority. HEREBY CERTIFY that I am of the opinion that the condition of the land at the site is neither detrimental nor potentially detrimental to any beneficial use of the land at the site. Dated: Signed: NJ. Withers of ICF Pty Ltd ENVIRONIvlENTAL AUDITOR Put 01 Report 23251\W1 \RB286.W1 DAMES& MOORE 34 of 44 FIGURES DAMES& MOORE 35 of 44 DRAWN LM Mr DAVID SHERRIFF TRACED KM LOT 1 RIVER ROAD, MILLGROVE CHECKED ENVIRONMENTAL AUDIT OF PIGGERY SB DATEMAY 1992 LOCALITY PLAN JOR NUMBER SCALE NOT TO SCALE CAD FILE MIL117 23251 -001 Figure 1 36 of 44 LEGEND APPROXIMATE EXTfNT OF AREA REMEDIATED / f I 35 APPROXIMATE LOCATION OF SAMPLE 8 BOREHOLE OR TEST PIT fi APPROXIMATE LOCATION OF EXISTING FARM BUILDINGS INDICATES PROPOSED SUB-DIVISIOJ LOT NUMBER INDICATES OUTLINE OF EXISTING LOT 1 AND OUTLINES OF PWPOSED SUB-DIVISIONS INDICATES APPROXIMATE LOCATION OF PROPOSED BUILDING ENVELOPES INDICATES APPROXIMATE LOCATION OF EFFLUENT DISPOSAL ENVELOPES 37 of 44 LEGEND Dead Stock Pit LOCATION OF TRACKS i I APPROXIMATE LOCATION OF HAND AUGER SAMPLE HOLE APPROXIMATE LOCATION OF TEST e5 PIT SeMPLE HOLE APPROXIMATE LOCATION OF EXISTING FARM BUILDINGS NOTE: Sample hole numbers 1 to 22 were completed for the initial assessment Sample hole numbers 23 to 40 were completed for the validation of the clean up. 0 IO 20 M 111 I I I I1 1 1.J APPROX SCALE Engineering Excellence DAMES & MOORE Environmental Responsibility Mr DAVID SHERRIFF LOT 1 RIVER ROAD, MILLGROVE ENVIRONMENTAL AUDIT OF PIGGERY DATE MAY 1992 SKETCH SITE PLAN JOE NUMBER APPROX. SCALE AS INDICATED CAD FILE MIL119 Figure 23251-001 3 38 of 44 APPENDIX A ‘ITIZES INFORMATION DAMES&Z MOORE39 of 44 VICTOIl1,A . i 1 ..I .. i 1 ! ! . 4; David'Smedley 3herriff of 10 Roeedale Orove Ivanhoe Accountant le ------. *I I * .. -1. nou the proprielor ------01 an Eslalc in Fee-simple suljccf lo the Eiicumbrances no1if;ed hereunder in j.:.. lhnt rcd and blue on thimep in I *-._ : au piece of Land, dclincaled and coloured r : -.: 1 .: .. the mlrrgln containing Ninety-eevon acme and 31x perchoo or thereaboute being part- .b Daled /he Twentle th d0Y of Augue t One I .. 7ll .. 40 of 44 APPENDIX B PHOTOGRAPHIC RECORD DAMES& MOORE41 of 44 OX mt ~1~i.ooi/~119bpi.nti PAQEPI AUDIT INVESTIGATION : SITE PHOTOGRAPHS AT 1 LOT 1, RIVER ROAD, MILLGROVE. 1 )HOTOGRAPH Nol: General view of central part of site towards the north east corner from the access track, showing the existing house in background and stream In foreground 'HOTOGRAPH No2 View looking South west towards the machinery shed from below pig sheds 42 of 44 RX mt z125i.ooimsasmrti PAWR AUDtT INVESTIGATION : SITE PHOTOGRAPHS AT LOT 1. RIVER ROAD. MILLGROVE. 'HOTOGRAPH No3 General view of pig sheds and north eastern pan of site from the access track from the machinery shed to the pig shed 'HOTOGRAPH No4: View looking east showing the pig sheds and effluent and feed tanks in foreground I 43 of 44 DX mt azst.mimrzsm.rtr PAOE PJ AUDIT INVESTIGATION : SITE PHOTOGRAPHS AT I LOT 1 , RIVER ROAD, MILLGROVE. WOTOGRAPH No5: Paddock in north east corner of site, sampling in progress. 'HOTOGRAPH No6: Dead stock pit to east of pig sheds. 44 of 44