Planning Proposal

Zoning & minimum lot size changes for Culcairn

November 2020

Prepared for

Greater Hume Council

Habitat Planning 409 Kiewa Street SOUTH ALBURY NSW 2640 p. 02 6021 0662 e. [email protected] w. habitatplanning.com.au

Document Control Version Date Purpose Approved A 14/05/20 Draft for client review WH B 09/06/20 Final for Council endorsement WH C 27/11/20 Revised final post-Gateway WH

The information contained in this document produced by Habitat Planning is solely for the use of the person or organisation for which it has been prepared and Habitat Planning undertakes no duty to or accepts any responsibility to any third party who may rely upon this document. All rights reserved. No section or element of this document may be removed from this document, reproduced, electronically stored or transmitted in any form without the written permission of Habitat Planning.

Contents

Introduction...... 1 PART 1. Intended outcomes ...... 2 PART 2. Explanation of the provisions ...... 4 PART 3. Justification ...... 5 Section A. Need for the planning proposal ...... 5 Section B. Relationship to strategic planning framework ...... 5 Section C. Environmental, social & economic impact ...... 8 Section D. State & Commonwealth interests ...... 9 PART 4. Mapping ...... 10 PART 5. Community consultation ...... 17 PART 6. Project Timeline ...... 18 Conclusion ...... 19

Attachments

A. Consistency with local Strategic Land Use Plan B. Consideration of State Environmental Planning Policies C. Consideration of Ministerial Directions D. Consideration of Riverina Murray Regional Plan 2036 E. Desktop Local Environmental Study for candidate sites F. Preliminary Site Investigations for Soil Contamination G. Additional information post-Gateway determination

Introduction

This is a Planning Proposal seeking amendments to the Greater Hume Local Environmental Plan 2012 (GHLEP). The amendments relate to a change of land use zoning and Minimum Lot Size (MLS) for four parcels of land in the township of Culcairn (see Figure 1). Aerial views of the four parcels are shown in Figures 2, 3, 4 & 5.

The changes propose to reinstate some township and rural small holdings zones originally intended for the GHLEP but later excluded due to a lack of flooding information following the 2012 major flood event in the Shire. This information is now available following completion of the Culcairn Floodplain Risk Management Study and Plan in 2017 that can be viewed using the following link https://www.greaterhume.nsw.gov.au/files/sharedassets/public/enviroment-and-planning/flood- studies/wma-water-culcairn-floodplain-risk-management-study-and-plan-apr-2017-adopted- finala.pdf

The Planning Proposal has been structured and prepared in accordance with the Department of Planning and Environment’s (DPE) A guide to preparing planning proposals (“the Guide”).

Culcairn township is located on the Olympic Highway and Main Southern Railway 514 kilometres south of Sydney and 362 kilometres north of Melbourne. The nearest regional centre is Albury 53 kilometres to the south and Wagga Wagga is slightly further away to the north. The township itself had a population of 1,136 at the 2016 census that increases to 1,473 people when the surrounding area is included. There were 641 residences recorded in Culcairn at the 2016 Census. Both the number of residents and dwellings has been increasing at a small rate.

The commercial activities in Culcairn are focused on the main street and include a supermarket, motels, hotels and a range of other local and specialty shops and services. There is no defined industrial area for Culcairn, although there has been an increase in industrial type activities on the northern side of town as well as the large feedlot further north. Community services include two primary schools, a secondary school, churches, post office, land fill depot, public hall, nursing home/aged care hostel, rural transaction centre and a hospital.

Culcairn provides a broad range of open space and recreational facilities for residents and visitor including an oval (Australian football/cricket), netball courts, tennis courts, golf club, swimming pool and lawn bowls club. More passive open space is provided in local parks around the township including along the Olympic Highway and Billabong Creek.

The water treatment plant services 571 rateable properties and has spare capacity. The sewerage treatment plant was commissioned in the 1960’s and is an ‘extended aeration plant’ utilising a pacifier channel. The system is designed for 1,000 equivalent persons (EP’s) and 365 equivalent tenements (ET’s) or households. Based on these raw figures, it would appear that Culcairn’s sewerage system is already over capacity, but this is dependent on Council’s settings for the program which can be adjusted to provide for a larger number of ET’s. Electricity and telecommunications are readily available and not considered to be a constraint to the future development of Culcairn.

Culcairn’s history and pace of development over time (lack of pressure for redevelopment) has resulted in a large number of heritage buildings for a town of its size, including the significant Culcairn Hotel. In addition to specific heritage items, parts of Balfour Street are also designated as

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Conservation Areas that recognises an area or precinct as having heritage significance. There are 19 Aboriginal objects or Aboriginal places recorded in and around Culcairn according to the OEH Aboriginal Heritage Information Management System (AHIMS). PART 1. Intended outcomes

The intended outcome of this Planning Proposal is principally to create additional opportunities for a range of residential development in Culcairn. A portion of one parcel requested for rezoning (CU2) is preferred for industrial development.

The Planning Proposal seeks to reinstate changes to land zoning and lot size maps in around Culcairn. These changes were previously proposed as part of the new Standard Instrument GHLEP but deferred because of a major flood event in 2012 that raised questions as to the suitability of some land. The subsequent preparation of a flood study for Culcairn now provides a definitive assessment as the impact of flooding on the nominated areas.

A summary of the intended outcomes of the Planning Proposal is provided in Table 1.

Table 1: Summary of potential increase in lot supply resulting from rezoning in Culcairn. Location Area Intended Estimated Qualification on yield calculation outcome lot yield1 Baird Street 63ha RU4 Primary 13 Is likely to be less as new roads (CU1) Production Small will be required to maximise lot Lots yield. 4ha MLS Railway 15ha RU5 Village 70 Note a portion of this area is Parade (CU2) preferred in the SLUP for industrial 600m2 MLS development. The yield for the residential component is based on a typical density for a country town of 10 lots per hectare. Walbundrie 10ha RU5 Village 100 Based on a typical density for a Road (CU3) country town of 10 lots per hectare. 600m2 MLS Likely to be less given the configuration of the parcel and points of access. Balfour Street 5ha R2 Low Density 10 Likely to be less when flooding (CU4) Residential constraint factored in. 4,000m2 MLS

1. The purpose of this column is to give an indication as to the number of additional lots that might be achieved in the proposed zone. Calculating lot yields by mathematical division is misleading as there is nearly always a range of factors that will prevent the theoretical maximum number being achieved.

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As part of the process for drafting the current 2012 GHLEP, a Strategic Land Use Plan (SLUP) was prepared to review land use planning in the Shire’s towns and villages. From this exercise a number of land parcels were identified as having development potential and consequently recommended for further assessment through a Local Environmental Study (LES).

An LES was undertaken for each parcel to consider the environmental consequences of ‘up zoning’ and compliance with State planning requirements. Several drafts of the LES were prepared in consultation with DPE and as a result a number of parcels were removed from consideration of ‘up zoning’ or modified for the GHLEP. In 2011 the LES was finalised with DPE and Council in agreeance as to which parcels were to be rezoned. Extracts from the LES where it relates to the candidate sites for Culcairn are included at Attachment E for reference purposes.

Following the major 2012 flood event and comments from government agencies, the final version of the LES was again amended to remove areas that had previously been deemed suitable for ‘up zoning’ by DPE but were now under suspicion of flooding in a major event. The changes proposed to zoning and minimum lot size provisions in this Planning Proposal seek to reinstate these agreed areas in Culcairn now that they have been confirmed in the flood studies as either flood free or subject to minimal low risk flooding (see Figure 9). These areas can now be considered as presenting little risk to life and property during a major flood event.

Recent demand for residential land in the Shire is steady with around four new dwellings approved per annum in the RU5, RU4, R2 and R5 zones of Culcairn. In terms of current actual supply1 there is just one lot available in Culcairn. This situation reveals a significant shortage of actual supply in Culcairn.

It is important to acknowledge that the dynamics of residential development in smaller country towns is different to larger urban centres such as Albury and Wagga Wagga. A straight analysis of supply based on a yield for a given area of zoned land for smaller town tends to distort the actual situation on the ground. What is most important for smaller towns is that there is a number of different opportunities to ensure that supply is not restricted to a small number of land owners or sites for which there may be no intention of development or release of land to someone willing to create some actual supply. Increasing the options can result in a theoretical over supply of zoned land in some towns, but necessary to create opportunities for development. There is no harm in this because if the land is not developed it generally remains in agricultural use despite the zoning (i.e. it does not become underutilised).

1 Actual vacant lots available for sale.

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PART 2. Explanation of the provisions The intended outcomes of the Planning Proposal will be achieved by changes to zoning and lot size maps within the GHLEP. A summary of those changes and the land to which they apply is provided in Table 2. Maps of the proposed changes are provided in Figures 6 & 7.

Table 2: Summary of changes sought in the Planning Proposal. Location LEP Map Land description Current zoning Requested Sheet & MLS zoning & MLS reference Baird Street LZN_003B Lots 1, 2, 3, 4, 5, 6, 7, & 8 DP RU1 Primary RU4 Primary (CU1) 7064 Production Production LSZ_003B Small Lots Lots 9 & 10 DP 11290 100ha 4ha Lot 291 DP 1124610 Part Lot 5 DP 250901 Railway LZN_003B Lot A DP 385255 RU1 Primary RU5 Village Parade (CU2) Production LSZ_003B 600m2 100ha Walbundrie LZN_003B Part Lot 3 DP 1105775 RU1 Primary RU5 Village Road (CU3) Production LSZ_003B 600m2 100ha Balfour Street LZN_003B Lots 96, 97, 98, 99 & 105 DP RU1 Primary R2 Low Density (CU4) 753757 Production Residential LSZ_003B Lot 126 DP 721063 100ha 4,000m2

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PART 3. Justification

This section of the Planning Proposal sets out the justification for the intended outcomes and provisions, and the process for their implementation. The questions to which responses have been provided are taken from the Guide.

Section A. Need for the planning proposal

Q1. Is the planning proposal a result of any strategic study or report?

The Planning Proposal is the result of recommendations made for Culcairn in the SLUP (see Attachment A) and now supported by the recommendations in the Flood Study for three of the four candidate sites (see Table 3). The fourth candidate site (CU3) was not included in the list of sites for specific assessment but is within the study area for the Flood Study.

The study provides the opportunity to adjust land use zones where the flood status of land is now confirmed, including the reinstatement of some zonings originally proposed for the GHLEP in 2012.

Q2. Is the planning proposal the best means of achieving the objectives or intended outcomes, or is there a better way?

The objective of reinstating zonings proposed for the GHLEP cannot be achieved without a Planning Proposal. By not proceeding, land on the fringe of Culcairn now confirmed as ‘flood free’ or at minimal risk of flooding would remain in the RU1 Primary Production Zone and prevent the opportunity for the town to grow and benefit the community.

Section B. Relationship to strategic planning framework

Q3. Is the planning proposal consistent with the objectives and actions of the applicable regional, sub-regional or district plan or strategy (including any exhibited draft plans or strategies)?

The Riverina Murray Regional Plan 2036 (RMRP) was adopted by the NSW government in 2017. The Minister’s foreword to the document states that the RMRP “encompasses a vision, goals, directions and actions that were developed with the community and stakeholders to deliver greater prosperity for this important region.”

Direction 16 of the RMRP is to “increase resilience to natural hazards and climate change” within which it is acknowledged that:

Managing flooding is an important priority for the NSW Government and councils. Most councils currently include flood planning area mapping in local plans and hydraulic and hazard category mapping of flood prone land, which provides government, developers and landowners with a level of certainty about the risks for particular sites.

Action 16.1 in the RMRP is to:

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Locate developments, including new urban release areas, away from areas of known high biodiversity value, high bushfire and flooding hazards, contaminated land, and designated waterways, to reduce the community’s exposure to natural hazards.

The Planning Proposal is consistent with action as it seeks to act on the availability of information relating to flooding in Culcairn and rule in or rule out land for development based on its known flood status.

In addition, to implement Goal 4 of the RMRP, the following directions are given:

Direction 22 – Promote the growth of regional cities and local centres.

Direction 23 – Build resilience in towns and villages.

Direction 25 – Build housing capacity to meet demand.

Direction 26 – Provide greater housing choice.

The Planning Proposal is consistent with all of these as it is advocating population growth in Culcairn.

Q4. Is the planning proposal consistent with a council’s local strategy or other local strategic plan?

The 2007-2030 Strategic Land Use Plan (SLUP) for the Shire was undertaken as a precursor to the 2012 GHLEP. In establishing the context for the SLUP, flooding was identified as a key, but not a major, issue for the Shire. It should be noted that the SLUP was completed prior to the record flooding that occurred in the district early in 2012. The strategic response in the SLUP to the flooding issue was nominated as “review flood data and policies”. The undertaking of a flood study for Culcairn leading to this Planning Proposal is taken as a direct response to that declared action.

The table and plan extracts at Attachment A provides a review of the recommendations for future land use in the SLUP for Culcairn against the changes proposed in the Planning Proposal. The areas to which the recommendations relate are depicted in Part 4 of the Planning Proposal.

Council has prepared a draft Local Strategic Planning Statement (LSPS) in accordance with the requirements of amendments to the EP&A Act in 2018. The LSPS is intended to shift the NSW planning system into a more strategic-led planning framework. One of the planning priorities for the Greater Hume LSPS relates to housing and land supply. To deliver on this planning priority Council has stated it will:

Monitor the uptake of residential land in the towns and villages and investigate future residential areas (as identified on the town maps). These areas will: • Be located to avoid areas that are identified as important agricultural land or areas that create potential for land use conflict; • Align with the utility infrastructure network and its capabilities; • Avoid or mitigate the impacts of hazards, including the implications of climate change;

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• Protect areas with high environmental value and/ or cultural heritage value and important biodiversity corridors; • Not hinder development or urban expansion and will contribute to the function of existing townships; • Create new neighbourhoods that are environmentally sustainable, socially inclusive, easy to get to, healthy and safe.

Investigate a mixture of smaller and larger residential lots in the towns and villages to create opportunity, respond to future demand, and to provide a range of housing options.

The planning priority is to be actioned by (amongst other things):

• Investigate and identify future potential for varied housing options in the townships of Henty, Holbrook, Morven and Culcairn – Short Term (refer plans)

The preparation and submission of this Planning Proposal is a direct response to this stated intention of Council for strategic planning.

Q5. Is the planning proposal consistent with applicable State Environmental Planning Policies?

Attachment B provides an assessment of the Planning Proposal against all State Environmental Planning Policies (SEPP’s). In summary, many of the SEPP’s are not applicable to the Greater Hume local government area and even less are applicable to the circumstances of the Planning Proposal.

The assessment concludes that the Planning Proposal is not inconsistent with any of the relevant SEPP’s.

Q6. Is the planning proposal consistent with applicable Ministerial Directions (s.9.1 directions)?

Section 9.1 of the Environmental Planning and Assessment Act 1979 (EP&A Act) provides for the Minister for Planning to give directions to Councils regarding the principles, aims, objectives or policies to be achieved or given effect to in the preparation of LEP’s. A Planning Proposal needs to be consistent with the requirements of the Direction but in some instances can be inconsistent if justified using the criteria stipulated such as a Local Environmental Study or the proposal is of “minor significance”.

An assessment of all Section 9.1 Directions is undertaken in Attachment C. In summary, the Planning Proposal is either consistent or has some minor inconsistencies with the relevant Directions. Where there is an inconsistency, it has been justified utilising the provisions within each of the Directions.

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Section C. Environmental, social & economic impact

Q7. Is there any likelihood that critical habitat or threatened species, populations or ecological communities, or their habitats, will be adversely affected as a result of the proposal?

With the exception of part of CU4, none of the land the subject of this Planning Proposal is mapped on the Terrestrial Biodiversity Map in the GHLEP as ‘Biodiversity’. The purpose of the Terrestrial Biodiversity Map is to identify land exhibiting natural characteristics that require protection from the impacts of development.

The CU4 parcel is proposed for the R2 zone with a minimum lot size of 4,000m2. This lower density will minimise the impact on the vegetation in this location and create the opportunity for development to be designed sympathetically.

In addition to federal and state legislation, the provisions of clause 6.2 of the GHLEP ensure that the impacts of development on terrestrial biodiversity are taken into account. These provisions are unaffected by the Planning Proposal.

Q8. Are there any other likely environmental effects as a result of the planning proposal and how are they proposed to be managed?

As mentioned earlier, the parcels of land the subject of this Planning Proposal were previously considered for ‘upzoning’ at the time the Standard Instrument LEP for Greater Hume was being prepared but withdrawn following a major flood event. As part of that process a Local Environmental Study (LES) was undertaken to consider the environmental effects of a change in zoning for each parcel of land.

Extracts from the LES as they apply to the parcels of land the subject of this Planning Proposal are included at Attachment E. The highlighted rows in the table considering the environmental impacts indicate matters relevant to the proposed zoning. Whilst this assessment is a desktop exercise, it is a relevant reference for identifying any environmental constraints to future development. Where flooding is referenced in the assessment table, the conclusions drawn in the current flood study for Culcairn now replace that response.

A summary of the conclusions reached in the flood study for Culcairn for the candidate sites in the Planning Proposal is provided in Table 3.

Table 3: Recommendations in Culcairn Flood Study for candidate sites in Planning Proposal

Location Flood Study conclusions (paraphrased) Baird Street (CU1) Examination of the Culcairn Flood Planning Area (FPA) indicates that approximately half of the proposed rezoning area is outside of the FPA extent, with the exception of two areas bordering the Olympic Highway. Therefore, from a flooding perspective this land is suitable for rezoning to RU4 Rural Small Holdings.

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Railway Parade Examination of the Culcairn FPA indicates that the majority of the (CU2) proposed rezoning area is outside of the FPA extent, with minor pockets of FPA situated on the rezoning area extent. Therefore, from a flooding perspective this land is suitable for rezoning to RU5 Village. Walbundrie Road Not specifically addressed in terms of rezoning but Figure 9 shows (CU3) that only small portions at the northern and southern ends would be subject to inundation in a 1% event and the hazard this presents is ‘low’. Figure 3 in the Flood Study indicates that the depth of this flooding would be at the lowest mapped scale of between 100 and 500mm. Balfour Street (CU4) Examination of the Culcairn FPA indicates that the majority of the proposed rezoning area is outside of the FPA extent, however the Billabong Creek anabranch flows through the site and is classed as a high hazard flow area and as a floodway in the 1% AEP event. Areas situated outside of the Culcairn FPA and the Billabong Creek anabranch are suitable for rezoning to RU5 Village. Note: The proposed zone for this site is now R2 Low Density Residential to better reflect the density of development envisaged (MLS of 4,000m2). The conclusions reached in the flood study for this site are equally relevant to the appropriateness of the R2 zone.

Q9. Has the planning proposal adequately addressed any social and economic effects?

There is a positive economic impact from the Planning Proposal courtesy of there now being greater certainty as to the flood prone status of land in Culcairn. This significantly reduces the risk and cost of future development being inundated and damaged by floodwaters. This will also result in a positive social impact for the town.

On balance, the social and economic impact of the proposal is considered positive.

Section D. State & Commonwealth interests

Q10. Is there adequate public infrastructure for the planning proposal?

The four land parcels nominated in this Planning Proposal are all adjoining the urban area of Culcairn, of which three can be provided with all urban public infrastructure. The parcel proposed for the RU4 zone (CU1) will have minimum lot size 4ha that allows for a lower level for some infrastructure (e.g. on-site wastewater disposal as against connection to reticulated sewerage).

Q11. What are the views of state and Commonwealth public authorities consulted in accordance with the Gateway determination?

No public authorities have been consulted prior to submitting the Planning Proposal to Council for support and subsequent request for a Gateway Determination.

It is acknowledged that the Gateway determination may specify consultation with public authorities.

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PART 4. Mapping

The following maps and figures are provided in support of the Planning Proposal.

Figure 1: Location map for candidate sites

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Figure 2: Aerial view of candidate site CU1

Figure 3: Aerial view of candidate site CU2

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Figure 4: Aerial view of candidate site CU3

Figure 5: Aerial view of candidate site CU4

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Figure 6: Proposed zoning for candidate areas

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Figure 7: Proposed minimum lot size for candidate areas

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Figure 8: Proposed Flood Planning Area for Culcairn with areas assessed for rezoning (Source: Culcairn Floodplain Risk Management Study & Plan April 2017)

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Figure 9: True Hydraulic 1% Flood Hazard Area for Culcairn with candidate areas shown (Source: Culcairn Floodplain Risk Management Study & Plan April 2017)

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PART 5. Community consultation

The Planning Proposal will be subject to public exhibition following the Gateway process. The Gateway determination will specify the community consultation that must be undertaken for the Planning Proposal, if any. As such, the exact consultation requirements are not known at this stage.

This Planning Proposal will be exhibited for a period of 28 days in accordance with the requirements of Clause 4 in Schedule 1 of the EP&A Act and the Guide. At a minimum, the future consultation process is expected to include:

• written notification to landowners adjoining the subject land;

• consultation with relevant Government Departments and agencies, service providers and other key stakeholders, as determined in the Gateway determination;

• public notices to be provided on Councils’ website;

• static displays of the Planning Proposal and supporting material in Council public buildings; and

• electronic copies of all documentation being made available to the community free of charge (preferably via downloads from Council’s website).

At the conclusion of the public exhibition period Council staff will consider submissions made with respect to the Planning Proposal, undertake any alterations and prepare a report to Council.

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PART 6. Project timeline

The project timeline for the Planning Proposal is outlined in Table 4. There are many factors that can influence adherence with the timeframe including the cycle of Council meetings, consequences of agency consultation (if required) and outcomes from public exhibition. Consequently, the timeframe should be regarded as indicative only.

Table 4: – Project timeline

Milestone Date/timeframe

Anticipated commencement date (date 4 weeks following Council resolution to of Gateway determination) request Gateway determination. Anticipated timeframe for the completion No required studies are anticipated. of required studies Timeframe for government agency 6 weeks from Gateway determination. consultation (pre and post exhibition as required by Gateway determination) Commencement and completion dates 6 weeks from Gateway determination. for public exhibition period Dates for public hearing (if required) At some point within the public exhibition period. Timeframe for consideration of 2 weeks following completion of submissions exhibition. Timeframe for the consideration of a 4 weeks following completion of proposal post exhibition exhibition. Anticipated date RPA will make the plan To be set by Gateway determination. (if delegated) Anticipated date RPA will forward to the To be confirmed. department for notification (if delegated).

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Conclusion

Nearing the completion of the new Standard Instrument GHLEP in 2012, parts of the Shire experienced to a major flood event. As a result, several areas proposed in the GHLEP for a change in zoning were removed subject to further investigation being undertaken relating to flooding.

The Culcairn Floodplain Risk Management Study and Plan was prepared and adopted in April 2017 and provides the necessary analysis of flooding for the Planning Proposal. The flood study confirms that candidate sites CU1, CU2 and CU4 are suitable for rezoning from a flooding perspective. The analysis undertaken in the flood study also confirms that flooding does not present as an unacceptable risk for site CU3.

The Planning Proposal is also strategically supported by the Riverina-Murray Regional Plan 2036, the Greater Hume Strategic Land Use Plan and the draft Greater Hume Local Strategic Planning Statement. There are no major environmental constraints that would prevent the development of the candidate sites in some capacity.

In conclusion, support for the Planning Proposal is considered warranted.

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Attachment ‘A’ Consistency with local Strategic Land Use Plan

Area SLUP recommendations Zone & MLS proposed Consistency in Planning Proposal

CULCAIRN

Baird Street Low density residential RU4 Primary Production The density of development envisaged in the SLUP is higher than the 13 lot maximum (CU1) (future) Small Lots & 4ha yield achievable under the proposed MLS. In essence, this area is now considered more suitable for rural living purposes and will reduce the pressure for such development in more isolated rural locations away from Culcairn. The eastern boundary of the proposed zone is located 70 metres from the boundary of the town’s sewerage treatment works to provide a buffer. The more limited low-density residential market in Culcairn will be catered for in location CU4. Railway Part residential (future) RU5 Village & 600m2 Consistent with the future land uses preferred in the SLUP. Parade (CU2) & part industrial (future) It is noted that the urban areas of all townships within the Shire have been provided with the ‘generic’ RU5 zone with the location of the various types of urban land uses guided by a Structure Plan in the Greater Hume Development Control Plan, based on the SLUP. Walbundrie Residential (future) RU5 Village & 600m2 Consistent with the future land use preferred in the SLUP. Road (CU3) Balfour Street Low density residential R2 Low Density Whilst the Planning Proposal originally advocated an RU5 zone for this proposed lower (CU4) (future) Residential & 4,000m2 density residential enclave, the R2 zone is more appropriate having regard for its use in other towns with an associated MLS of 2,000 to 4,000m2. This is now consistent with the recommendations of the SLUP.

Attachment ‘B’ Consistency with State Environmental Planning Policies

No. Title Consistency 19 Bushland in Urban Areas Not applicable to the local government area of Greater Hume. 21 Caravan Parks The Planning Proposal does not conflict with the aims, development consent requirements, number of sites being used for long term or short term residents, permissibility of moveable dwellings where caravan parks or camping grounds are also permitted, and subdivision of caravan parks for lease purposes as provided in the SEPP. 33 Hazardous & Offensive The Planning Proposal does not conflict with the aims and Development provisions of this SEPP relating to the definition and process of assessing potentially hazardous and offensive industry. 36 Manufactured Home The Planning Proposal does not conflict with the aims, strategies, Estate development consent, assessment and location provisions as provided in the SEPP. 47 Moore Park Showground Not applicable to the local government area of Greater Hume. 50 Canal Estate The Planning Proposal does not conflict with the aims and canal Development estate development prohibitions as provided in the SEPP. 55 Remediation of Land As the Planning Proposal will create the opportunity for residential development, Clause 6 of this SEPP requires Council to consider whether the subject land is potentially contaminated. A preliminary site investigation for soil contamination has been undertaken for CU1, CU2 and CU3. The results of this assessment are generally supportive of the proposed zoning, with some areas in CU1 and CU3 recommended for further testing at the time of development. 64 Advertising & Signage The Planning Proposal does not conflict with the aims, development consent requirements and assessment criteria for advertising and signage as provided in the SEPP. 65 Design Quality of The Planning Proposal does not conflict with the aims, Residential Flat development consent, assessment, information and notification Development requirements as provided in the SEPP. Affordable Housing The Planning Proposal does not conflict with the aims and (Revised Schemes) functions of this SEPP as changes do not discriminate against the provision of affordable housing. Aboriginal Land 2019 The subject land is not identified on the Land Application Map for this SEPP, hence it is not applicable to the Planning Proposal. Affordable Rental The Planning Proposal does not conflict with the aims and Housing 2009 functions of this SEPP as changes do not discriminate against the provision of affordable housing (and consequently affordable rental housing). The GHLEP cannot influence the provision of rental housing. Building Sustainability The Planning Proposal does not conflict with the aims and Index (BASIX) 2004 development consent requirements relating to BASIX affected building(s) that seeks to reduce water consumption, greenhouse gas emissions and improve thermal performance as provided in the SEPP. Coastal Management Not applicable to the local government area of Greater Hume. 2018

No. Title Consistency Concurrences and Not applicable. consents 2018 Educational The Planning Proposal does not conflict with the aims, Establishments & Child permissibility, development assessment requirements relating to Care Facilities 2017 educational establishments and childcare facilities as provided in the SEPP. Exempt & Complying The Planning Proposal does not conflict with the aims and Development Codes 2008 functions of this SEPP with respect to exempt and complying development provisions. Gosford City Centre 2018 Not applicable to the local government area of Greater Hume. Housing for Seniors & The Planning Proposal does not conflict with the aims, People with a Disability development consent, location, design, development standards, 2004 service, assessment, and information requirements as provided in the SEPP. Infrastructure 2007 The Planning Proposal does not conflict with the aims, permissibility, development consent, assessment and consultation requirements, capacity to undertake additional uses, adjacent, exempt and complying development provisions as provided in the SEPP. Koala Habitat Protection Greater Hume is one of the Councils to which this SEPP applies, 2019 however the subject land is not located within the Koala Development Application Map. Consequently, Council is not prevented from granting consent to development as long as it satisfied that the land is not ‘core koala habitat’. Having regard for the history of the candidate sites, their current circumstances and lack of any koala sitings in the area; none are considered to represent ‘core koala habitat. Kosciuszko National Park Not applicable to the local government area of Greater Hume. – Alpine Resorts 2007 Kurnell Peninsula 1989 Not applicable to the local government area of Greater Hume. Mining, Petroleum The Planning Proposal does not conflict with the aims, Production & Extractive permissibility, development assessment requirements relating to Industries 2007 mining, petroleum production and extractive industries as provided in the SEPP. Murray Regional The subject land is not within the area to which MREP2 applies. Environmental Plan No. 2 – Riverine Land Penrith Lakes Scheme Not applicable to the local government area of Greater Hume. 1989 Primary Production & Not applicable as the subject land is not identified as state Rural Development 2019 significant agricultural land and does not propose any artificial waterbodies. State & Regional Not applicable as the Planning Proposal is not for State significant Development 2011 development. State Significant Precincts Not applicable as the subject land is not within a State significant precinct. Sydney Drinking Water Not applicable to the local government area of Greater Hume. Catchment 2011

No. Title Consistency Sydney Region Growth Not applicable to the local government area of Greater Hume. Centres 2006 Three Ports 2013 Not applicable to the local government area of Greater Hume. Urban Renewal 2010 Not applicable as the subject land is not within a nominated urban renewal precinct. Vegetation in Non-Rural This SEPP is relevant as it applies to the RU5 and R2 zones (but Areas 2017 not the proposed RU4 zone). The provisions of the SEPP will be relevant if trees are proposed to be removed as part of the future development within the candidate sites. This consideration would be made as part of a development application and does not preclude the proposed zoning of the land. Western Sydney Not applicable to the local government area of Greater Hume. Employment Area 2009 Western Sydney Not applicable to the local government area of Greater Hume. Parklands 2009

Attachment ‘C’ Consistency with Ministerial Directions

No. Title Consistency 1. Employment & Resources 1.1 Business & Industrial Not applicable as the Planning Proposal does not involve business Zones or industrial zones. 1.2 Rural Zones This Direction requires consideration because it applies to all Councils and the Planning Proposal affects land within an existing or proposed rural zone. Only the provisions of clause 4(a) relating to zoning changes are relevant as Greater Hume is not nominated as one of the Councils to which clause 4(b) relating to an increase in density applies. CU1 The proposal for this land parcel is not inconsistent as it will remain in a rural zone (RU4). CU2, CU3 & CU4 These three land parcels are inconsistent with the Direction because the proposal advocates a change in zoning from rural to residential (or in the case of the RU5 which is bracketed as a rural zone, likely to be developed for residential). This inconsistency is justified by a land use strategy prepared as a precursor to Council’s Standard instrument LEP in 2012 (the Greater Hume Strategic Land Use Plan 2007-2030). Whilst this has not been literally endorsed as per this Direction, it was accepted by the Department in order to progress to the LEP. It is also noted that at the time of the GHLEP (and other LEP’s) being prepared, there was no requirement for a formal endorsement of the SLUP. In addition, the preparation of the SLUP was funded and managed by the Department; not by Council. The table at Attachment A shows for each parcel of land the recommendation of the strategy versus the proposed zone in the Planning Proposal. The table demonstrates that the Planning Proposal for all candidate sites is generally consistent with an adopted strategy. The Direction also allows for a proposal to be inconsistent in the circumstances set out in clause (5). In this instance the inconsistency is justified because the proposal is in accordance with the Riverina-Murray Regional Plan 2036 prepared by the Department of Planning (see Attachment D) and in particular Goal 4 – Strong, connected and healthy communities. Notwithstanding the above, these four land parcels have been subjected to a local environmental study when they were proposed, but subsequently withdrawn, as part of the GHLEP in 2012. Details of the environmental study as it applies to the candidate sites is included at Attachment E. These details remain relevant to the current Planning Proposal with the exception of the analysis of flooding and potential soil contamination that have since been interrogated in significantly more detail. The impact of the flood study for Culcairn on the candidate sites is summarised in Table 3 of the Planning Proposal and replaces the analysis provided in the environmental studies. 1.3 Mining, Petroleum Not applicable as the Planning Proposal does not impact on mining. Production & Extractive Industries 1.4 Oyster Aquaculture Not applicable as the subject land is not within a Priority Oyster Aquaculture Area.

1.5 Rural Lands This Direction requires consideration because Greater Hume is not one of the Councils excluded from it and the Planning Proposal advocates changes to rural zones and minimum lot sizes. CU1 This parcel is consistent as the proposal retains the land in a rural zone (RU4). Whilst it will result in the fragmentation of rural land by reducing the MLS, at 4 hectares the bulk of the land will remain in agriculture as this lot size is simply too large to do nothing on. Smaller rural lots also present the opportunity for owners to undertake diversified and innovative agricultural activities for which a large land holding is unsuitable. The land is relatively unconstrained as is demonstrated in the environmental study at Attachment E. It is also not State significant agricultural land and additional lots will provide a social and economic benefit to the Culcairn community. CU2, CU3 & CU4 These three land parcels are arguably inconsistent with the Direction as the proposed RU5 and R2 zoning does not sit well with some of the criteria Council must consider such proposals against. However, the inconsistency is justified by a strategy prepared as a precursor to Council’s Standard instrument LEP in 2012 (the Greater Hume Strategic Land Use Plan 2007-2030). The table at Attachment A shows for these three land parcels the recommendation of the strategy versus the proposed zone in the Planning Proposal. This demonstrates that the Planning Proposal is generally consistent with a strategy accepted by the Department for the purposes of the GHLEP. It is also consistent with direction of the Riverina-Murray Regional Plan 2036 prepared by the Department of Planning (see Attachment D) where actions to increase the population of the Culcairn will achieve “strong, connected and healthy communities” (Goal 4). 2. Environment & Heritage 2.1 Environment Protection This Direction requires consideration because it applies to all Zones Planning Proposals. The Planning Proposal is consistent as it does not propose any change to the provisions of the GHLEP (namely clause 6.2) relating to biodiversity protection. 2.2 Coastal Protection Not applicable as the subject land is not within a coastal zone. 2.3 Heritage Conservation This Direction requires consideration because it applies to all Planning Proposals. The Planning Proposal is consistent with this Direction because the subject parcels do not contain any known “items, places, buildings, works, relics, moveable objects or precincts of environmental heritage significance” or Aboriginal objects. 2.4 Recreation Vehicle This Direction requires consideration because it applies to all Areas Planning Proposals. The Planning Proposal is consistent with the Direction because it does not advocate the designation of the subject land as a recreation vehicle area pursuant to an order in force under section 11 (1) of the Recreation Vehicles Act 1983.

2.5 Application of E2 and Not applicable. E3 Zones and Environmental Overlays in Far North Coast LEPs. 3. Housing Infrastructure & Urban Development 3.1 Residential Zones This Direction is relevant because the Planning Proposal is advocating zones within which residential development will be permitted. The Planning Proposal is consistent with this Direction because it will provide the opportunity for a greater choice and supply of housing in Culcairn and make use of existing urban infrastructure. In addition, the GHLEP already contains a provision (clause 6.7) requiring development to be adequately serviced. 3.2 Caravan Parks & This Direction requires consideration because it applies to all Manufactured Home Planning Proposals. Estates The Planning Proposal is consistent with this Direction because it does not reduce the opportunities for caravan parks and manufactured homes estates on the subject lands. 3.3 Home Occupations This Direction requires consideration because it applies to all Planning Proposals. The Planning Proposal will not prevent future dwellings being used for ‘home occupations’ and hence is consistent with this Direction. 3.4 Integrating Land Use This Direction is relevant because three of the parcels in the and Transport Planning Proposal are creating an urban zone. The Planning Proposal will facilitate residential development at an urban scale and within the township Culcairn. Recreational facilities are available in close proximity. Having regard for these circumstances, the Planning Proposal is considered consistent with this Direction. 3.5 Development Near Not applicable as none of the lots are in the vicinity of a licensed Licensed Aerodromes aerodrome. 3.6 Shooting Ranges Not applicable as none of the lots are in the vicinity of a shooting range. 4. Hazard & Risk 4.1 Acid Sulphate Soils Not applicable as none of the lots contain acid sulphate soils. 4.2 Mine Subsidence & Not applicable as none of the lots are within Mine Subsistence Unstable Land District.

4.3 Flood Prone Land This Direction is relevant as it applies to ‘flood prone land’, which is defined in the Floodplain Development Manual 2005 as land “susceptible to flooding by the PMF event”. A PMF or Probable Maximum Flood is more significant than a 1 in 100 year event. The requirements of this Direction however relate to the Flood Planning Areas (FPA) and not flood prone land, which is defined as land below the level of the 1 in 100 year event plus 500mm. According to the flood study, pockets of some candidate sites are within the FPA. This Direction prevents changing ‘flood prone land’ from a rural zone to a residential zone. As the Flood Study for Culcairn indicates that the whole of the township would be inundated in a PMF, sites CU2, CU3 and CU4 in the Planning Proposal are inconsistent with this Direction (CU1 is not advocating a residential zone). However, the Direction allows for a Planning Proposal to be inconsistent if it is in accordance with a floodplain risk management plan. In this case a floodplain risk management plan has been prepared for Culcairn that supports the proposed zonings for CU1, CU2 and CU4 and therefore the inconsistency for these parcels is justified. The inconsistency for CU3 is justified by the low flood risk this land represents as demonstrated in Figures 8 & 9 relating to the FPA and hydraulic flood risk. These figures indicate the majority of the land in CU3 is flood free and therefore suitable for residential development. In fact, most of this parcel would be one of the few in Culcairn that would not be inundated in a 1 in 200 year flood event (see maps within the Culcairn Flood Study). 4.4 Planning for Bushfire Not applicable as none of the sites are mapped as bushfire prone. Protection 5. Regional Planning 5.1 Implementation of Revoked in 2017. Regional Strategies 5.2 Sydney Drinking Water Not applicable as the lots are not within the Sydney Drinking Water Catchment Catchment. 5.3 Farmland of State & Not applicable as the lots are not within one of the local government Regional Significance areas nominated in this Direction. on the NSW Far North Coast 5.4 Commercial and Retail Not applicable as none of the lots are near the Pacific Highway. Development along the Pacific Highway, North Coast 5.5 Development in the Revoked in 2010. Vicinity of Ellalong, Paxton and Millfield (Cessnock LGA) 5.6 Sydney to Canberra Revoked in 2008. Corridor 5.7 Central Coast Revoked in 2008. 5.8 Second Sydney Airport: Not applicable as none of the lots are near the site for a second Badgerys Creek Sydney airport. 5.9 North West Rail Link Not applicable as none of the lots are near this corridor. Corridor Strategy

5.10 Implementation of This Direction requires consideration because it applies to all Regional Plans Planning Proposals. The Planning Proposal complies with this Direction because it is not inconsistent with the Riverina Murray Regional Plan 2036 (see Attachment D). 6. Local Plan Making 6.1 Approval and Referral This Direction requires consideration because it applies to all Requirements Planning Proposals. The Planning Proposal is consistent with this Direction because it does not propose any referral requirements or nominate any development as ‘designated development’. 6.2 Reserving Land for This Direction requires consideration because it applies to all Public Purposes Planning Proposals. The Planning Proposal is consistent with this Direction because it does not remove or propose any public land. 6.3 Site Specific Provisions Not applicable as the proposal does not propose any site-specific provisions. 7. Metropolitan Planning 7.1 Implementation of A Not applicable as the lots are not within one of the local government Plan for Growing areas nominated in this Direction. Sydney 7.2 Implementation of Not applicable as the lots are not within one of the local government Greater Macarthur Land areas nominated in this Direction. Release Investigation 7.3 Parramatta Road Not applicable as the lots are not within one of the local government Corridor Urban areas nominated in this Direction. Transformation Strategy 7.4 Implementation of North Not applicable as the lots are not within the North West Priority West Priority Growth Growth Area. Area Land Use and Infrastructure Implementation Plan 7.5 Implementation of Not applicable as the lots are not within the Greater Parramatta Greater Parramatta Priority Growth Area. Priority Growth Area Interim Land Use and Infrastructure Implementation Plan 7.6 Implementation of Not applicable as the lots are not within the Wollondilly Shire Wilton Priority Growth Council. Area Interim Land Use and Infrastructure Implementation Plan

Attachment ‘D’ Consistency with the Riverina-Murray Regional Plan 2036

Goal, Direction & Action Title Relevance to the Planning Proposal Consistency

Goal 1 – A growing and diverse economy

Direction 1 – Protect the region’s Relevant because the Planning The Planning Proposal will result in a loss of land used for agriculture for diverse and productive agricultural Proposal relates to land zoned RU1. sites CU2 and CU3. These sites are however located on the fringe of the land. Culcairn township and to some extent are already constrained for the type of agriculture than can be undertaken because of potential land use conflicts. The loss of land for agriculture as a result of urban growth is not unreasonable as it is a very minor impact having regard for the availability of other land in the Shire for this purpose. Direction 2 – Promote and grow the Not applicable, as the proposal does N/A agribusiness sector. not relate to or affect agribusiness. Direction 3 – Expand advanced and Not applicable, as the proposal does N/A value-added manufacturing. not relate to or affect value-added manufacturing.

Direction 4 – Promote business Not applicable, as the proposal does N/A activities in industrial and not relate to or affect business commercial areas. activities. Direction 5 – Support the growth of Not applicable, as the proposal does N/A the health and aged care sectors. not relate to or affect the health and aged care sectors. Direction 6 – Promote the expansion Not applicable, as the proposal does N/A of education and training not relate to or affect education or opportunities. training. Direction 7 – Promote tourism Not applicable, as the proposal does N/A opportunities. not relate to or affect tourism. Direction 8 – Enhance the economic Not applicable, as the proposal does N/A self-determination of Aboriginal not relate to or affect Aboriginal communities. communities.

Direction 9 – Support the forestry Not applicable, as the proposal does N/A industry. not relate to or affect forestry. Direction 10 – Sustainably manage Not applicable as the proposal does N/A water resources for economic not relate to or affect water opportunities. resources. Direction 11 – Promote the Not applicable as the proposal does N/A diversification of energy supplies not relate to or affect energy through renewable energy supplies. generation. Direction 12 – Sustainably manage Not applicable, as the subject land is N/A mineral resources. not known to contain any significant mineral resources.

Goal 2 – A healthy environment with pristine waterways

Direction 13 – Manage and conserve Not applicable, as the subject land is N/A water resources for the environment. not known to contain any water resources. Direction 14 – Manage land uses Not applicable as the subject land is N/A along key river corridors. not located within a key river corridor such as the Murray River. Direction 15 – Protect and manage Not applicable as the subject land N/A the region’s many environmental has no environmental assets within assets. the context of this Direction. Direction 16 – Increase resilience to Relevant because portions of land in The flood study undertaken for Culcairn provides some definitive natural hazards and climate change. the Planning Proposal are flood information relating to flooding in these towns. Whilst the studies show prone. portions of land subject to flooding within the areas proposed for ‘upzoning’, they are not so significant that it is increasing the risk to life and property. The flood study will be used to influence the type of future development to ensure this.

Goal 3 – Efficient transport and infrastructure networks

Direction 17 – Transform the region Not relevant, as the proposal does N/A into the eastern seaboard’s freight not relate to or affect industry or and logistics hub. freight. Direction 18 – Enhance road and rail Not relevant, as the proposal does N/A freight links. not relate to or affect freight. Direction 19 – Support and protect Not relevant, as the proposal will not N/A ongoing access to air travel. affect air travel. Direction 20 – Identify and protect Not relevant to the subject proposal. N/A future transport corridors. Direction 21 – Align and protect Relevant as the proposal will result in All land proposed for the RU5 and R2 zones can be provided with the utility infrastructure investment. vacant land being developed. urban infrastructure servicing Culcairn. That land proposed for a lower density of development will not require some of these services such as reticulated sewerage.

Goal 4 – Strong, connected and healthy communities

Direction 22 – Promote the growth of Relevant because the proposal The Planning Proposal will support and promote the growth of Culcairn regional cities and local centres. affects land within the Culcairn by making available additional land for residential development. township. Direction 23 – Build resilience in Relevant because the proposal By providing additional land for residential development as a result of the towns and villages. affects land within the Culcairn Planning Proposal, the population of Culcairn will be increased, and this township. builds resilience. Direction 24 – Create a connected Not relevant as Culcairn is not a N/A and competitive environment for border town. cross-border communities. Direction 25 – Build housing Relevant because the proposal is The Planning Proposal supports this Direction because as a capacity to meet demand. creating the opportunity for consequence it will increase the supply of residential land in Culcairn. residential development.

Direction 26 – Provide greater Relevant because the proposal is Additional land will provide addition choice in living environments. housing choice. creating the opportunity for residential development. Direction 27 – Manage rural Relevant because some of the land The land proposed for the RU4 zone (CU1) is located within the context residential development. in the Planning Proposal is proposed of the Culcairn township. for rural residential development. Direction 28 – Deliver healthy built Not applicable as the rezoning in N/A environments and improved urban itself does not influence urban design. design. Direction 29 – Protect the region’s Relevant because all development All future development should be subject to the ‘due diligence’ process Aboriginal and historic heritage. on ‘greenfields’ land should consider for ascertaining the likelihood or otherwise of Aboriginal artefacts being the prospect of Aboriginal artefacts present. This process assists in the protection Aboriginal heritage. being present.

Attachment ‘E’ Extracts from the Local Environmental Study associated with the preparation of the Greater Hume Local Environmental Plan 2012

LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2011

Culcairn Site 1 Map reference number: ...... CLN001 Subject land: ...... Lots 1, 2, 3, 4, 5, 6, 7, 8 DP7064, Lot 9, DP11290, Part Lot 5,

DP250901, Lot 29, DP753757 Area ...... 65ha Proposed change in land use: ...... Rural to Low Density Residential Description: ...... Vacant rural and to east of Olympic Highway on northern fringe of town.

Change instigated by: ...... Greater Hume Strategic Land Use Plan. Recommendation: ...... Support

Ministerial Directions (to extent of inconsistency):

No. Title Justification for inconsistency Inconsistent because the Direction prohibits any rezoning from rural to residential. 1.2 Rural Zones The inconsistency is justified by the LES (including the assessment of rural lands at Appendix A. State Environmental Planning Policies (to extent of relevance):

No. Title Consistency SEPP55 requires Council to “consider” whether land proposed in an LEP for residential use is potentially contaminated. A “preliminary investigation” under the Contaminated Remediation of Lands Planning Guideline is only required if there is either “no knowledge” of the history of the land or it is known the land was previously used for one of the nominated activities 55 land that may lead to soil contamination. This site has mostly been used for cropping and grazing and there is no evidence of any more intensive agricultural or other activity that may lead to contamination. DECCW’s contaminated sites register does not show anything for this land. Rural Lands 2008 The assessment of rural lands at Appendix A demonstrates compliance with this SEPP.

HABITAT PLANNING 31 LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2011

Environmental impact:

Environmental Basis of assessment Potential impacts matters The subject land is not noted as having a high agriculture or existing land use and is currently used for low scale stock grazing. Rezoning of Context Anticipated the land would not remove high quality agricultural land from production. Loss of habitat. The land is cleared of vegetation and retains only a light cover of paddock trees. Remnant vegetation should be retained Aerial photograph and NPWS Wildlife Flora where possible. Atlas NPWS Wildlife Atlas listed no threatened species sightings (since 1980) in the vicinity of the site. Fauna NPWS Wildlife Atlas NPWS Wildlife Atlas listed no threatened species sightings (since 1980) in the vicinity of the site or township. Flooding Anticipated Flood prone land information for Greater Hume Shire is limited. This site is unlikely to be affected by a flood event. Bushfire Council Bushfire Prone Land Map None. Land is not identified as bushfire prone. Heritage Council Heritage Study 2009 There are no listed heritage items within this area. AHIMS database, Council Heritage Archaeology There are no recorded archaeological sites. Study 2009 Class I - No special soil conservation works or practices. Land suitable for a wide variety of uses. Where soils are fertile, this is land with the Land DECC mapping highest potential for agriculture, and may be cultivated for vegetation and fruit production, cereal and other grain crops, energy crops, fodder capability and forage crops, and sugar cane in specific areas. Includes "prime agricultural land". Infrastructure Council officers Township water supply and sewage treatment by Council. Social Anticipated Potential positive impact through provision of increased residential availability and population growth. Economic Anticipated Anticipated positive influence through the availability of a variety of lot sizes and an increase in local population.

HABITAT PLANNING 32 LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2011

Culcairn Site 2

Map reference number: ...... CLN002 Subject land: ...... Lot A, DP385255 (Western section) Area ...... 10ha Proposed change in land use: ...... Rural to Residential Description: ...... Vacant rural land near Hamilton Street on eastern edge of town. Change instigated by: ...... Greater Hume Strategic Land Use Plan. Recommendation: ...... Support Ministerial Directions (to extent of inconsistency):

Environmental impact:

HABITAT PLANNING 33 LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2011

Environmental Basis of assessment Potential impacts matters Flooding Anticipated Flood prone land information for Greater Hume Shire is limited. This site is unlikely to be affected by a flood event. Bushfire Council Bushfire Prone Land Map None. Land is not identified as bushfire prone. Heritage Council Heritage Study 2009 There are no listed heritage items within this area. AHIMS database, Council Heritage Archaeology There are no recorded archaeological sites. Study 2009 Class I - No special soil conservation works or practices. Land suitable for a wide variety of uses. Where soils are fertile, this is land with the Land DECC mapping highest potential for agriculture, and may be cultivated for vegetation and fruit production, cereal and other grain crops, energy crops, fodder capability and forage crops, and sugar cane in specific areas. Includes "prime agricultural land". Infrastructure Council officers Township water supply and sewage treatment by Council. Social Anticipated Potential positive impact through provision of increased residential availability and population growth. Economic Anticipated Anticipated positive influence through the availability of a variety of lot sizes and an increase in local population.

HABITAT PLANNING 34 LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2011

Culcairn Site 3

Map reference number: ...... CLN003 Subject land: ...... Lot A, DP385255 (Eastern section) Area ...... 5ha Proposed change in land use: ...... Rural to Industrial Description: ...... Vacant rural land on western side of Main Southern Railway. Change instigated by: ...... Greater Hume Strategic Land Use Plan. Recommendation: ...... Support Ministerial Directions (to extent of inconsistency):

No. Title Justification for inconsistency Inconsistent because the Direction prohibits any rezoning from rural to industrial (village). 1.2 Rural Zones The inconsistency is justified by the LES (including the assessment of rural lands at Appendix A.

State Environmental Planning Policies (to extent of relevance):

No. Title Consistency Rural Lands 2008 The assessment of rural lands at Appendix A demonstrates compliance with this SEPP.

Environmental impact:

HABITAT PLANNING 35 LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2011

Environmental Basis of assessment Potential impacts matters Heritage Council Heritage Study 2009 There are no listed heritage items within this area. AHIMS database, Council Heritage Archaeology There are no recorded archaeological sites. Study 2009 Class I - No special soil conservation works or practices. Land suitable for a wide variety of uses. Where soils are fertile, this is land with the Land DECC mapping highest potential for agriculture, and may be cultivated for vegetation and fruit production, cereal and other grain crops, energy crops, fodder capability and forage crops, and sugar cane in specific areas. Includes "prime agricultural land". Infrastructure Council officers Township water supply and sewage treatment by Council. Social Anticipated Potential positive impact through provision of increased industrial activity and availability. Anticipated positive influence through the availability of a variety of land uses encouraging new business in local area and associated Economic Anticipated increase in local population. Rezoning of the land will increase the availability of industrial land in the area and allow increased investment in the local industrial sector.

HABITAT PLANNING 36 LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2009

Culcairn Site 4

Map reference number:...... CLN004

Subject land:...... Lot 1, DP311778, Lot 2, DP865572, Lot 3, DP753757 Area ...... 27ha Proposed change in land use zone: .... 1(a) General Rural to R1 General Residential Description: ...... 27 ha Walbundrie Road Change instigated by:...... Greater Hume Strategic Land Use Plan. Recommendation:...... Rezone southern half (approx. 17ha shown coloured in image) Environmental impact:

Environmental Basis of assessment Potential impacts matters The subject land is not noted as having a high agriculture or existing land use and is currently used for low scale stock grazing. Rezoning of the Context Anticipated land would not remove high quality agricultural land from production. Aerial photograph and NPWS Loss of habitat The land is cleared of vegetation and retains only a light cover of paddock trees which should be retained where possible. Flora Wildlife Atlas NPWS Wildlife Atlas listed a threatened species siting (Silky Swainson pea Swainsona sericea since 1980) in the vicinity of the site. Fauna NPWS Wildlife Atlas NPWS Wildlife Atlas listed no threatened species sitings (since 1980) in the vicinity of the site or township. Flooding Flood Planning Area map Flood prone land information for Greater Hume Shire is limited. This site could be affected by a flood event. Bushfire Council Bushfire Prone Land Map Land is not located within identified Bushfire Prone Lands NSW Heritage Council & Culcairn Heritage There are no listed heritage items within this area. Council is undertaking a heritage study. LEP Archaeology AHIMS database AHIMS recognises no sites within this area. Class I - No special soil conservation works or practices. Land suitable for a wide variety of uses. Where soils are fertile, this is land with the highest potential for agriculture, and may be cultivated for Land DECC mapping vegetation and fruit production, cereal and other grain crops, energy crops, fodder and forage crops, and sugar cane in specific areas. Includes capability "prime agricultural land". Some sections are already Urban. Township water supply and sewage treatment by Council. Sites outside of the township may require extensions to services or on site water and/or Infrastructure Council officers sewage. Social Anticipated Potential positive impact through provision of increased residential availability and population growth.

HABITAT PLANNING 22 LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2009

Environmental Basis of assessment Potential impacts matters Economic Anticipated Anticipated positive influence through the availability of a variety of lot sizes and an increase in local population.

HABITAT PLANNING 23 LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2011

Culcairn Site 7

Map reference number: ...... CLN007

Subject land: ...... Lots 98, 99 DP753757, DP1060914 Holbrook Road Area ...... 3ha Proposed change in land use: ...... Rural to Low Density Residential Description: ...... Part developed low density residential land. Infill opportunity.

Change instigated by: ...... Greater Hume Strategic Land Use Plan. Recommendation: ...... Rezone eastern section (approx. 3ha) defer remaining due to tree cover and proximity to creek

Ministerial Directions (to extent of inconsistency):

No. Title Justification for inconsistency Inconsistent because the Direction prohibits rezoning rural to residential. 1.2 Rural Zones The inconsistency is justified by the LES (including the assessment of rural lands at Appendix A).

State Environmental Planning Policies (to extent of relevance):

No. Title Consistency SEPP55 requires Council to “consider” whether land proposed in an LEP for residential use is potentially contaminated. A “preliminary investigation” under the Contaminated Remediation of Lands Planning Guideline is only required if there is either “no knowledge” of the history of the land or it is known the land was previously used for one of the nominated activities 55 land that may lead to soil contamination. This site historically may have been used for cropping and grazing but has been lying vacant in more recent times. There is no evidence of any more intensive agricultural or other activity that may lead to contamination. DECCW’s contaminated sites register does not show anything for this land. Rural Lands 2008 The assessment of rural lands at Appendix A demonstrates compliance with this SEPP.

Environmental impact:

Environmental Basis of assessment Potential impacts matters

HABITAT PLANNING 41 LOCAL ENVIRONMENTAL STUDY DRAFT GREATER HUME LOCAL ENVIRONMENTAL PLAN 2011

Environmental Basis of assessment Potential impacts matters The subject land is not noted as having a high agriculture or existing land use and is currently used for low scale stock grazing. Rezoning Context Anticipated of the land would not remove high quality agricultural land from production. The site has been cleared and is unlikely to have significance as habitat. Flora Aerial photograph and NPWS Wildlife Atlas NPWS Wildlife Atlas listed no threatened species sightings (since 1980) in the vicinity of the site. Fauna NPWS Wildlife Atlas NPWS Wildlife Atlas listed no threatened species sightings (since 1980) in the vicinity of the site or township. Flooding Anticipated There is no flooding information available but it is anticipated that part of the site could be affected in a flood event. Bushfire Council Bushfire Prone Land Map None. Land is not identified as bushfire prone. Heritage Council Heritage Study 2009 There are no listed heritage items within this area. AHIMS database, Council Heritage Study Archaeology There are no recorded archaeological sites. 2009 Class I - No special soil conservation works or practices. Land suitable for a wide variety of uses. Where soils are fertile, this is land with the highest potential for agriculture, and may be cultivated for vegetation and fruit production, cereal and other grain crops, energy crops, fodder Land DECC mapping and forage crops, and sugar cane in specific areas. Includes "prime agricultural land". capability Some land already classified “Urban”.

Infrastructure Council officers Township water supply and sewage treatment by Council. Social Anticipated Potential positive impact through provision of increased residential availability and population growth. Economic Anticipated Anticipated positive influence through the availability of a variety of lot sizes and an increase in local population.

HABITAT PLANNING 42

Attachment ‘F’ Preliminary Site Investigations for Soil Contamination

BAIRD STREET CULCAIRN NSW

PRELIMINARY SITE INVESTIGATION

OCTOBER 2020

REFERENCE: 7326

DM McMahon Pty Ltd 6 Jones St (PO Box 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 www.dmmcmahon.com.au

Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 Report type Preliminary Site Investigation

Site address Baird Street Culcairn NSW 2660

Report number 7326

Prepared for Colin Kane Director Environment & Planning Greater Hume Council 39 Young St (PO Box 99) Holbrook NSW 2644 Tel: 0260 448 928 Email: [email protected]

Prepared by DM McMahon Pty Ltd 6 Jones Street (PO Box 6118) Wagga Wagga NSW 2650 Tel: 0269 310 510 Email: [email protected]

Document control

Role Name Signed Date Revision Author Zach Bradley 30/10/2020 0 BEnvSc MALGA MEIANZ Certifier David McMahon CEnvP SC 30/10/2020 0 BAppSc SA GradDip WRM MEnvMgmt MALGA MEIANZ MSSA

DM McMahon Pty Ltd – October 2020 Page 2 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 Contents 1.0 Executive summary ...... 4 2.0 Objectives ...... 5 3.0 Scope of work ...... 6 4.0 Site identification ...... 7 5.0 Site history ...... 8 6.0 Site condition and surrounding environment ...... 11 7.0 Conceptual site model ...... 14 8.0 Sampling and analysis quality plan and sampling methodology ...... 16 9.0 Results ...... 20 10.0 Quality assurance/quality control data evaluation ...... 21 11.0 Conclusions and recommendations...... 23 12.0 Unexpected findings ...... 24 13.0 Limitations and disclaimer ...... 24 14.0 Notice of copyright ...... 24 15.0 References ...... 25 16.0 Attachments ...... 25

List of Tables Table 1: Site identification ...... 7 Table 2: Ownership ...... 8 Table 3: Sample media and analytes ...... 17 Table 4: Tier 1 analysis acceptance criteria ...... 17 Table 5: Sampling rationale ...... 18 Table 6: Sampling Data Quality Indicators ...... 21 Table 7: Analysis Data Quality Indicators ...... 22

DM McMahon Pty Ltd – October 2020 Page 3 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 1.0 Executive summary DM McMahon Pty Ltd (McMahon) conducted a Preliminary Site Investigation (PSI) at Baird Street Culcairn NSW (the site). The 60ha (approx.) site, identified by Council as CU1, is currently occupied by three houses and three sheds with the remaining vacant land having a history of broad acre agriculture or Council use. The site is subject to a planning proposal for rezoning from RU1 primary production to RU4 primary production small lots and reduction of the minimum lot size from 100ha to 4ha. Surrounding land uses include agricultural, residential, and commercial. A map of the site location can be seen in Attachment A.

The objective of this investigation is to assess whether contamination has the potential to exist on the site and whether further investigation is needed.

The scope of work includes: • A desktop study used to collect basic site information and identify the site characteristics. • A site inspection of accessible areas with limited soil sampling using Data Quality Objectives (DQOs). • An assessment of the potential contamination source-pathway-receptor linkages. • Interpretation of data collected to conduct a risk assessment for site suitability regarding the proposed development.

Findings of the investigation include: • The site has a history of agricultural land use as far as records can ascertain. • Areas of potential environmental concern include: o Pesticide and herbicide use on agricultural land. o Pesticide use in the Council pound on Lot 291 DP1124610. o Uncontrolled fill material on the 2ha south eastern corner on Lot 5 DP250901. • Sampling of the accessible agricultural areas and the Council pound returned results below the adopted criteria for residential land use and as such the potential contaminants that may be present in these areas are assessed to be of low significance in terms of risk to future residential site users. • The uncontrolled fill material on the 2ha south eastern corner on Lot 5 DP250901 requires further investigation if development is to occur in this area. • An inspection of Lots 1, 2, and 5-8 (DP 7064) and Lots 9-10 (DP 11290) including the houses and sheds was not undertaken owing to no access, further inspection and assessment of these areas is recommended if future development is proposed or as they become accessible.

In summary McMahon assess there is no gross contamination of the inspected and tested agricultural areas across the site and the Council pound. These areas are considered suitable for the proposed primary production small lots land use, with a low risk of harm to human health and the environment regarding potential contamination. Further investigation and assessment of the area of uncontrolled fill material is required if development is to occur. The Lots not inspected require further investigation and assessment if development is to occur or as they become accessible.

This executive summary and the findings of this PSI is subject to limitations as stated in Section 13.

DM McMahon Pty Ltd – October 2020 Page 4 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 2.0 Objectives The objective of this investigation is to: • Provide information regarding potential contamination on site. • Provide a factual record of the works completed and results. • Undertake a risk assessment for health risk to future site users and the environment. • Provide a statement of recommendations for further investigation, remediation, and/or ongoing site management or alternatively, suitability of the site for the proposed land use. • To prepare the PSI in general accordance with the relevant guidelines and legislation, namely: o NSW EPA Contaminated land guidelines for Consultants reporting on contaminated sites (2020). o State Environmental Planning Policy 55 – Remediation of Land (SEPP 55). o National Environment Protection (Assessment of Site Contamination) Measure (NEPM), (2013).

DM McMahon Pty Ltd – October 2020 Page 5 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 3.0 Scope of work The scope of work includes the following: • Review the available information regarding historical, current, and proposed land use of the site and surrounds. • Review the environmental setting of the site and surrounds. • Assess the potential contamination sources and Chemicals of Potential Concerns (CoPCs). • Assess the potential contamination source-pathway-receptor linkages from the CoPCs, environmental setting and land use. • Formulate a Sampling, Analysis & Quality Plan (SAQP) to investigate the potential contamination. • Conduct limited soil sampling across the site for the CoPCs to assess the requirement for further investigation. • Collect soil samples for laboratory analysis of the CoPCs. • Compare the laboratory results against the adopted criteria. • Evaluate Quality Assurance/Quality Control (QA/QC) data to assess the sampling and analysis procedure. • Refine a Conceptual Site Model (CSM) to assess potential contamination risk from the source-pathway-receptor linkages. • Provide a clear statement on site suitability for the proposed land use or the need for further investigation, remediation, and/or ongoing site management.

DM McMahon Pty Ltd – October 2020 Page 6 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 4.0 Site identification The site identification can be seen as follows, Table 1.

Table 1: Site identification Identifier Details Baird Street (CU1) Property identification/address Culcairn NSW 2660 Lots 1, 2, 3, 4, 5, 6, 7, & 8 DP 7064 Lots 9 & 10 DP 11290 Real property description Lot 291 DP 1124610 Lot 5 DP 250901 Centre co-ordinate 504160E 6054435N MGA GDA z55 Property size 60ha (approx.) Lot 1 DP 7064 A & B Mackie Lot 2 DP 7064 P & J Clancy Lot 3 DP 7064 J & L Honeywill Lot 4 DP 7064 S Sulic & M Secerbegovic Owner(s) Lot 5 & 6 DP 7064 A & B Mackie Lot 7 & 8 DP 7064 R & N Pope Lot 9 & 10 DP 11290 A & B Mackie Lot 291 DP 1124610 Greater Hume Council Lot 5 DP 25091 Greater Hume Council Local Government Area Greater Hume Council Present use Agricultural/residential Present zoning RU1 Primary Production Proposed zoning RU4 Primary Production Small Lots

A map of the Lots can be seen in Attachment B.

DM McMahon Pty Ltd – October 2020 Page 7 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 5.0 Site history From research of land titles, Council records, EPA records, aerial photography, and information provided by the owner, the following site history is offered:

Ownership Council records and the land titles database were investigated for land use, ownership history and other notes of interest, Table 2.

Table 2: Ownership Year Lot/DP Owner/occupier Reference owned/occupied Lot 1 DP 7064 A & B Mackie - Council

Lot 2 DP 7064 Patrick & Julie Clancy 2018 Title search

Lot 3 DP 7064 John & Sharon Honeywill 2018 Title search

Lot 4 DP 7064 S Sulic & M Secerbegovic - Council

Lot 5 DP 250901 S Hamson (leased) Greater - Council Hume Council (owner)

Lot 5 DP 7064 A & B Mackie Council

Lot 6 DP 7064 A & B Mackie - Council

Lot 7 DP 7064 R & N Pope - Council

Lot 8 DP 7064 R & N Pope - Council

Lot 9 DP 11290 A & B Mackie - Council

Lot 10 DP 11290 A & B Mackie - Council

Lot 291 DP 1124610 Greater Hume Council - Council

Council records A search of the Council records returned the following: Lot 2 DP 7064 • DA231-06/07 Dwelling alterations and additions Lot 3 DP7064 • DA/CDC Dwelling, shed and pool Lot 5 DP 250901 • DA22-07/08 Effluent reuse scheme • CDC16-07/08 Pump shed Lot 7 & 8 DP 7064 • DA86-07/08 Dwelling (expired) • CDC18.2018.54 Dwelling

DM McMahon Pty Ltd – October 2020 Page 8 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 There is a 2ha (approx.) area of land on Lot 5 DP250901 that is on the Council contaminated land register. This area in the south eastern corner of the site is adjacent to the Culcairn Sewage Treatment Plant and has uncontrolled fill material stockpiled on it.

EPA records There are no records on the Contaminated Land Record Database for the site pertaining to Preliminary Investigation Orders, Declaration of Significantly Contaminated Land, Approved Voluntary Management Plans, Management Orders, Ongoing Maintenance Orders, Repeal Revocation or Variation Notice, Site Audit Statement, or Notice of Completion or Withdrawal of Approved VMP. The site has not been “notified” to the EPA on the list of NSW Contaminated sites as of September 2020. One service station in Culcairn (2883 Olympic Highway) is notified but regulation under the CLM Act is not required.

Aerial photos McMahon observed the following from a review of the available aerial photography. 1959 – The site is broadacre agricultural land with scattered trees and three small dams. The trees and dams are consistent with current site features. Surrounding land use is predominantly agricultural. The Culcairn cemetery is visible to the east and large lot residential to the south. 1966 – No change. 1972 – A large dam has been built to the east of the site below the cemetery. Assumed to be the Culcairn STP. No other changes. 1980 – No change. 1991 – A house and two sheds have been built in the middle of the site on Lot 2 DP 7064. The house and sheds reflect current site conditions. 1996 – A third shed has been built behind the house and two sheds visible in the 1991 aerial photograph on Lot 9 DP11290. This reflects current site conditions. 1998 – No change. 2007 – A house and garage have been built on Lot 3 DP7064. The house and garage reflect current site conditions. Two livestock feeders or shipping containers have been placed on Lot 8 DP7064. 2010 – Some excavation has occurred on site adjacent to the STP (Lot 5 DP 250901). 2013 – Some hay bales have been placed Lot 8 DP7064 and Lot 1 DP7064. 2014 – No change. 2015 – The smallest of the three original dams (1959) on Lot 2 DP 7064 has been infilled. 2016 – The feeders/containers on Lot 8 DP7064 have been removed. No other changes. 2017 – Some rudimentary yards have been built in the south west corner of Lot 291 DP1124610. 2018 – No change. 2019 – Some machinery is parked in the south west corner of Lot 3 DP7064.

The aerial photographs can be seen in Attachment C.

Interviews McMahon conducted an interview with Colin Kane of Greater Hume Council and the following was forthcoming. • Council own majority of the eastern side of the site.

DM McMahon Pty Ltd – October 2020 Page 9 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 • The 2ha south eastern corner of on Lot 5 DP250901 Council’s contaminated lands register due to the sewage treatment plant. • Council use Lot 291 as a pound paddock. • The western lots are privately owned. • The use of site has been farm land until the recent residential developments.

McMahon assesses that the information supplied by Colin Kane is reliable based on comparable findings from the site inspection, research, and multiple lines of evidence.

DM McMahon Pty Ltd – October 2020 Page 10 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 6.0 Site condition and surrounding environment McMahon notes the following observations of the site condition as part of this PSI:

Layout • The site consists of 17 paddocks and two smaller yards around the houses and sheds. • The paddocks range in size from 4ha to 20ha. • There are three farm dams: o One large dam on Lot 4 DP7064. o One small dam on Lot 9 DP11290. o One small dam on Lot 2 DP7064. • There is a Council livestock pound on Lot 291 DP1124610 around 0.6ha in area.

Buildings • A brick clad and Colorbond roofed house on Lot 3 DP7064. • A Colorbond garage on Lot 3 DP7064 next to the shed. • A brick clad and Colorbond roofed house on Lot 2 DP7065. • Two corrugated iron sheds on Lot 2 DP7065. • One corrugated iron shed on Lot 9 DP11290. • One new brick clad and Colorbond roofed house on Lot 6 DP7064.

Septic systems • There are three septic systems associated with the three houses. These systems are regulated by Greater Hume Council.

Site surface • The inspected agricultural paddocks and the Council pound are natural soil. • The vegetation in the inspected agricultural areas and the Council pound consisted of oats, canola, lucerne and grass pasture. • The 2ha area of uncontrolled fill material on Lot 5 DP250901 consisted of stockpiled asphalt, soil and aggregate. • Driveways to the houses are gravelled with quarried 20mm material. • There is a gravelled track from Baird Street to the large dam on Lot 3 DP7064. • No chemical or hydrocarbon staining was observed on the investigated areas.

Surrounds • The site fronts Baird Street. • The site is bound by the Olympic Highway to the West and Baird Street to the South. • The Main Southern Railway lies to the west of the Olympic Highway. • The Culcairn cemetery lies adjacent to the site on the east. • The Culcairn STP lies adjacent to the site on the east and south of the cemetery. • Culcairn township lies to the South of Baird Street and is bound by The Billabong Creek to the South. • Broad acre agricultural land lies to the wider north, east, and west.

A map of the site features and surrounding land uses can be seen in Attachment D.

Site photographs can be seen in Attachment E.

DM McMahon Pty Ltd – October 2020 Page 11 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 A summary of the site environmental setting is as follows.

Topography The Culcairn 1:25,000 Topographic Map (8326-4S) indicates that the site is located at an elevation range of approximately 215 to 220m AHD. The site landform is classed as an alluvial plain and the slope is level to very gently inclined towards the west south west.

Vegetation Vegetation in the inspected paddocks and Council pound is in healthy condition.

Natural Resources Sensitivity A search of the Great Hume Council Local Environment Plan (LEP) (2012) found that the site is not located in a riparian lands, watercourse or wetlands area nor a terrestrial biodiversity area.

Climate The Bureau of Meteorology (BoM) database records the average rainfall for Albury (40km away) is approximately 691mm per annum, with the wettest months being June, July and August. Annual mean evaporation for the region is 1424mm with mean daily evaporation ranges from 1.0mm in June to 7.8mm in January. Culcairn is characterised by cold wet winters and hot dry summers.

Hydrology The nearest named waterway is the Billabong Creek located around 1.8km to the south of the site. An unnamed drainage (a tributary of the Billabong Creek) lies around 400m to the south west of the site with a very widely spaced stream channel occurrence. Flow direction is generally to the west with a convergent, integrated, and tributary channel patterns. Due to the relative incline of the site, rainfall will both infiltrate into the soil and run off the surface.

Soil & Landform The site lies within the Culcairn (cu) mapping unit from the Soil Landscapes of the Holbrook- Tallangatta 1:100 000 Sheet, (Doughty, 2003). The mapping unit cu is described as follows: Landform - extensive level alluvial plains of Billabong Creek near Culcairn. Local relief <5 m; altitude 200–250 m; slopes 0–1%. Extensive to broad plains with sparse narrow drainage lines. Extensively cleared yellow box woodland. Soils - very deep (>1.5 m), moderately well-drained Red and Brown Chromosols and Kurosols (Red and Brown Podzolic Soils). Yellow and Grey Sodosols (Soloths) occur on the higher, older terraces, with deep (1.0–1.5 m), moderately well-drained Grey and Brown Dermosols (Grey Podzolic Soils) occurring on lower younger terraces. Deep (1.0–1.5 m), imperfectly drained Stratic Rudosols (Alluvial Soils) occur in the recent channels. Limitations - localised high gully erosion hazard; localised acidity; localised waterlogging and poor drainage; localised sodicity; locally hardsetting; foundation hazard where sodic.

Geology & Regolith The underlying geology consists of unconsolidated Quaternary riverine deposits of clay, silt, sand and gravel including the floodplain, ancient channel deposits and alluvial terraces.

DM McMahon Pty Ltd – October 2020 Page 12 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 Hydrogeology The site lies within the Lower Billabong Hydrogeological Landscape (HGL). As described by Muller et. al. (2015), aquifers within the Lower Billabong HGL are unconfined to semi-confined, with groundwater flow occurring primarily through unconsolidated alluvial sediments. Hydraulic conductivity is high, and transmissivity is moderate to high. Groundwater recharge rates are estimated to be high.

Groundwater systems are typically intermediate to regional with intermediate to long flow lengths and are loosely defined by topographic catchments. Water quality within these systems is brackish to saline. Water table depths are intermediate to deep. Localised perching of water tables occurs above clay lenses during wetter periods.

Medium to long residence times are typical. These landscapes have a slow to medium response time to changes in land management.

From a search of the Water NSW database there is one groundwater bore located in the south west corner of the site (GW016506) which is constructed into granite with a water bearing zone at 35m to 55m depth, the use of this bore is unknown. There is another registered stock/domestic groundwater bore located 300m west of the site (GW003879) constructed into sandstone with a water bearing zone from 38m to 53m depth. From this McMahon assess that a groundwater resource on site is likely to be deep and in the underlying geology (30m+).

DM McMahon Pty Ltd – October 2020 Page 13 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 7.0 Conceptual site model A Conceptual Site Model (CSM) is a representation of site-related information regarding contamination sources, receptors and exposure pathways between those sources and receptors.

Herbicide and pesticide application are diffuse in nature with small quantities applied and periodic use. Based on the above and the moderate persistence of the chemicals used in herbicides and pesticides, the potential for contamination from these is assessed as low. No available information on historical herbicides which are typically more persistent and toxic herbicides than modern herbicides. The organic component of these historical herbicides may have attenuated, however heavy metal residues may still remain.

List of contaminants of potential concern

The preliminary nature of the sampling in this PSI is to assess the requirement for further investigation across the wider rezoning area, therefore the CoPCs reflect the persistent chemicals from the agricultural land use, namely: • Heavy metals- Arsenic (As), Cadmium (Cd), Chromium (Cr), Copper (Cu), Nickel (Ni), Lead (Pb), Zinc (Zn), Mercury (Hg). • Organochlorines (OCPs). • Organophosphates (OPPs).

Potential and known sources of contamination • Pesticide and herbicide use on agricultural land. • Pesticide use in the Council pound on Lot 291 DP1124610. • Uncontrolled fill material on the 2ha south eastern corner on Lot 5 DP250901.

Mechanism of contamination The mechanism of contamination from the primary source is predominantly top down vertical migration into soil.

Potentially affected environmental media • Surface and near surface soil. • Groundwater through soil media from surface spills but unlikely owing to deep depths (>30m).

Consideration of spatial and temporal variations Spatial variation is possible owing to the limited nature of the sampling plan. Temporal variations are likely owing to the seasonal nature of agricultural land use. Short to medium term temporal variations of heavy metals are unlikely owing to the persistent nature of these chemicals.

Actual or potential exposure pathways • Direct skin contact with soil. • Inhalation and/or ingestion of soil, vapour, and dust. • Direct groundwater contact but groundwater is deep (>30m) and unlikely to be contacted. • Groundwater ingestion but no domestic groundwater bores are known to currently exist on site.

DM McMahon Pty Ltd – October 2020 Page 14 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 Human and ecological receptors • Current and future on-site residents. • Future on-sites workers. • Domestic groundwater users but no domestic groundwater bores are known to currently exist on site. Future domestic groundwater use is possible. • Down gradient ecological receptors such as the Billabong Creek. • Current and future landscaping and ecological receptors.

Frequency of exposure • Current and future residents are assessed to have a medium to long-term exposure risk. • Future workers are assessed to be a short-term exposure risk. • Future potential groundwater users are a medium to long-term exposure risk. • Ecological receptors are assessed to be a medium to long-term exposure risk.

Source pathway receptor linkage assessment • Current and future residents are at risk from contact with contaminated soil. • Workers are at risk from contact with contaminated soil during shallow and intrusive works. • Groundwater contact or ingestion is unlikely owing to deep depths (>30m) and no domestic bores being known to exist on site. • On site ecological receptors.

Discussion of multiple lines of evidence A multiple lines of evidence approach is the process for evaluating and integrating information from different sources of data and uses best professional judgement to assess the consistency and plausibility of the conclusions which can be drawn, NEPM (2013).

Definitive information concerning the site history and sources of potential contamination on site is satisfactory therefore the risk assessment will rely on the information provided by this PSI and will be supplemented by analytical data collected from the sampling program.

DM McMahon Pty Ltd – October 2020 Page 15 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 8.0 Sampling and analysis quality plan and sampling methodology The Data Quality Objectives (DQOs) of the site assessment have been developed to define the type and quality of data to meet the project objectives. The DQOs have been developed generally in accordance with the seven-step process as outlined in AS 4482.1:2005 and the USA EPA: Guidance on Systematic Planning Using the Data Quality Objectives Process (2006a). These DQOs are as follows: 1. The problem 2. The goal of the study 3. Information inputs 4. Study boundaries 5. The analytical approach 6. Performance and acceptance criteria 7. Obtaining data

These objectives have been further outlined in the following sections.

DQO 1 - The problem There are possible sources of contamination from historical land uses which may pose risk to current and future users of the site. Insufficient data relating to these sources is currently available to determine residential land use suitability with the necessary level of confidence.

DQO 2 - The goal of the study Goals of the study include: • Undertake intrusive investigations to determine if there is contamination within soil associated with the identified potential contamination sources. • Determine if any contamination, should it be identified, poses a risk to current and/or future receptors at the site or within potential exposure pathways from the site. • Determining whether the site is currently, or can be made, suitable for the proposed rezoning regarding contamination.

DQO 3 - Information inputs • Desktop data provided by this PSI, including site inspections, site condition, history, geology, hydrogeology to characterise the site. • Soil observational data including visual and olfactory conditions obtained from the proposed sampling program. • Soil analytical data relative to assessment criteria.

DQO 4 - Study boundaries • Site walkover and intrusive soil investigations in the near surface soil will be conducted across the accessible areas on site. • Temporal boundaries are limited to the proposed fieldwork timeframes.

DQO 5 - The analytical approach Soil were tested against the following parameters as identified in the Conceptual Site Model (see Section 7.0), summarised in Table 3.

DM McMahon Pty Ltd – October 2020 Page 16 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 Table 3: Sample media and analytes Material Analytes ALS suite code Test method Heavy metals S-2 APHA 3120 Organochlorine & S-12 USEPA 3510/8270 Soil Organophosphate Pesticides (OCP/OPP)

DQO 6 - Performance and acceptance criteria Specific limits for the investigation are in accordance with the appropriate guidance made or endorsed by state and national regulations, appropriate indicators of data quality, and industry standard procedures for field sampling and handling.

To assess the validity of data for decision making, the data will be assessed against a set of data quality indicators, the following predetermined data quality indicators have been adopted.

The key decision rules for the investigation are: 1) Has the analytical data been collected as part of the testing and met the data quality indicators? If they have then the data can be used to answer the decision rule/s and the decision statements developed in Step 2 of the DQOs. If not, then the need to collect additional data may be required. 2) Do contaminant concentrations exceed the investigation and screening criteria? If not, then the potential contamination does not pose an above low level of risk. Where results exceed the investigation and screening criteria, this may indicate an unacceptable level of risk. Further risk assessment and investigations may be warranted to determine the potential for impacts.

The key decision errors for the investigation are: i. deciding that soil on site is contaminated when it truly is not, and ii. deciding that soil on site is not contaminated when it truly is. The true state of nature for decision error (i) is that soil is not contaminated. The true state of nature for decision error (ii) is that soil is contaminated.

The site acceptance criteria were specifically derived and incorporate the following: • The samples were not composited so as the direct reading of contaminant levels will be found from each sample point on which an appropriate decision can be based off. • QAQC duplicate should have a Relative Percentage Difference (RPD) for metals of <30% and <50% for all other analytes. • If contaminant levels exceed acceptance criteria further investigation may be required. • Specific Tier 1 acceptance criteria are as follows, Table 4.

Table 4: Tier 1 analysis acceptance criteria Material Analytes Criteria Health Investigation Levels (HILs) -Residential A NEPM (2013) Heavy metals -Table 1A(1) Heavy metals, OCPs, OPPs OCPs Soil -Soils within 3m of surface OPPs Added Contaminants Limits (ACLs)

-Residential A (NEPM 2013) -Table 1B(1) Zinc

DM McMahon Pty Ltd – October 2020 Page 17 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 -Table 1B(2) Copper -Table 1B(3) Nickel -Table 1B(4) Lead -Soils within 2m of surface

-pH of 6.0 (CaCl2) assumed from Doughty (2003) -CEC of 10 assumed from Doughty (2003) Environmental Investigation Levels (EILs) -Residential A (NEPM 2013) -Table 1B(5) Arsenic and DDT -Soils within 2m of surface

The Tier 1 assessment criteria will be used as an initial screening of the data to determine whether further assessment is required. Where exceedances of Tier 1 criteria indicate a risk to human health or the environment, site specific risk assessment or remediation will be carried out as appropriate.

DQO 7 - Obtaining data The sampling pattern and strategy identifies the occurrence of potential contamination for suitable site characterisation. The sampling pattern and strategy has been devised based on site history, land uses, aerial imagery, site inspections, McMahon PSI, sampling, amendments during field works, database searches and NEPM (2013).

Sampling pattern A judgemental sampling pattern has been chosen based on potential contamination sources and previous land use. From this judgmental sampling a quantitative assessment of results compared to the adopted criteria can be made.

McMahon assesses that the sampling pattern is suitable to be used for decision making and site characterisation.

Key features of the sampling pattern include: • Eight soil sampling points. • One near surface sample collected from each sample point. • One soil duplicate. • One rinsate sample

By reference to the DQOs, a map of the sampling pattern can be seen in Attachment F.

The following table presents a summary of the sampling locations and rationale behind their selection, Table 5.

Table 5: Sampling rationale Sample locations Rationale To assess the potential contamination of the natural soil across Points 1 - 8 the agricultural area and Council pound. Heavy metals and OCPs/OPPS, may be persistent in the soil if pesticide and herbicide application has occurred.

DM McMahon Pty Ltd – October 2020 Page 18 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 Soil sampling method The sampling officers wore unused disposable nitrile gloves to extract samples directly from the test pit and placed into Teflon lined glass sample jars. Collected sample containers were placed into a chilled esky for preservation prior to analysis. All in-field observations and any relevant comments were detailed in the field sheets/bore logs and a Chain of Custody form produced to accompany the samples to the laboratory.

Soil sampling standards Soil sampling and soil descriptions were undertaken by reference to: • AS 4482.1:2005 - Guide to the investigation and sampling of sites with potentially contaminated soil Part 1: Non-volatile and semi-volatile compounds. • AS 4482.2:1999 - Guide to the sampling and investigation of potentially contaminated soil Part 2: Volatile substances; and • AS1726:2017 – Geotechnical Site Investigations.

DM McMahon Pty Ltd – October 2020 Page 19 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 9.0 Results Sampling was conducted over one day on Wednesday 21 October 2020. The weather was warm and dry with light winds. A summary of the field observations and sample analytical results are as follows.

Soil The surface and near surface natural soils on site are synonymous with the Quaternary alluvium of the Culcairn soil landscape. The soil profile presented below is a generalised model of the conditions encountered to the investigated depth of 0.3m. 1. 0.0-0.1m OL silt CLAY, brown, low plasticity, soft-firm. Trace fine sand. Moist < PL, TOPSOIL, Culcairn soil landscape. 2. 0.1-0.3m CL sand CLAY, yellow-brown, low plasticity, firm. Moist < PL, Alluvial, Culcairn soil landscape.

General soil observations are: • Soil was natural material with no chemical staining or odours. • Soil descriptions, sampling depths, and observations can be seen in the field notes, Attachment G.

Analytical results A summary of the soil analytical results are as follows: • Heavy metals are below the adopted criteria. • OCPs & OPPs are below LORs and the adopted criteria.

The tabulated soil results with comparison against the adopted criteria can be seen in Attachment H.

Laboratory certificates and QA/QC reports can be seen in Attachment I.

DM McMahon Pty Ltd – October 2020 Page 20 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 10.0 Quality assurance/quality control data evaluation

Data quality indicators To assess the validity of data for decision making, the data has been assessed against a set of Data Quality Indicators (DQIs), the following predetermined DQIs have been adopted, Table 6 and Table 7.

Table 6: Sampling Data Quality Indicators

Adopted practices Completeness Comparability Representativeness Precision Accuracy Details of sampling team – David McMahon (Principal). ✓ ✓ Reference to sampling plan/method, including any deviations from it – ✓ sampling and analysis quality plan. Decontamination procedures carried out between sampling events. ✓ ✓ ✓ Logs for each sample collected, including date, time, location (with GPS coordinates), sampler, duplicate samples, chemical analyses to be ✓ ✓ performed, site observations and weather/environmental (i.e. surroundings) conditions. Include any diagrams, maps, photos. Chain of Custody fully identifying – for each sample – the sampler, nature of the sample, collection date, analyses to be performed, sample ✓ ✓ preservation method, departure time from the site and dispatch courier(s) (where applicable). Field quality assurance/quality control results (not adopted as limited - - sampling to assess the requirement for further investigation). Statement of duplicate and other QAQC sample frequencies – 1 per 20 ✓ ✓ samples for duplicates. Field instrument calibrations (when used) with supporting - - documentation. Sampling devices and equipment appropriate to sampling requirements. ✓ ✓

DM McMahon Pty Ltd – October 2020 Page 21 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 Table 7: Analysis Data Quality Indicators

Adopted practices Completeness Comparability Representativeness Precision Accuracy A copy of signed Chain of Custody forms acknowledging receipt date ✓ ✓ and time, and identity of samples included in shipments. Analytical methods used, including any deviations. ✓ ✓ Calculation of Relative Percentage Difference for duplicate comparison ✓ ✓ ✓ - <30% for metals and <50% for organics. Laboratory accreditation for analytical methods used, also noting any ✓ ✓ methods used which are not covered by accreditation. Surrogates and spikes used throughout the full method process, or ✓ ✓ only in parts. Results are corrected for the recovery. A list of what spikes and surrogates were run with their recoveries and ✓ ✓ acceptance criteria (tabulate). Practical quantification limits (PQL). ✓ ✓ Laboratory duplicate results (tabulated). ✓ ✓ Evaluation of all quality assurance/control information listed above against the stated data quality objectives, including a quality ✓ ✓ ✓ ✓ ✓ assurance/control data evaluation.

In consideration of the adopted QA/QC procedures and the results from their subsequent analysis, McMahon assesses the QA/QC results are suitable for the investigation undertaken and reflect the analytical data is of a suitable quality to determine contamination risk with an appropriate level of confidence. Tabulated RPD calculations can be seen in Attachment J.

DM McMahon Pty Ltd – October 2020 Page 22 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 11.0 Conclusions and recommendations This investigation met the objective of assessing whether contamination has the potential to exist on the site and whether further investigation is needed.

Around half of the site was inaccessible at the time of the site inspection (Lots 1, 2, and 5- 8 DP 7064 and Lots 9-10 DP 11290), therefore these areas need to be investigated and assessed when future development occurs or as they become accessible.

The uncontrolled fill material on the 2ha south eastern corner on Lot 5 DP250901 requires further investigation if development is to occur in this area.

Soil analysed had contaminant levels below the adopted human health and environmental criteria for residential land use. This investigation identified no gross contaminating historical activities on accessible agricultural areas of the site.

DM McMahon Pty Ltd – October 2020 Page 23 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 12.0 Unexpected findings If any unconsolidated, odorous, stained or deleterious soils are encountered during any further excavation, suspected historical contaminating activities are encountered, or conditions that are not alike the above descriptions, the site supervisor should be informed, the work stopped, and this office be contacted immediately for further evaluation by an appropriately qualified environmental consultant. The unexpected findings may trigger the need for more investigation and assessment dependant on the scope and context of the unexpected finding.

13.0 Limitations and disclaimer DM McMahon Pty Ltd has prepared this report in accordance with the usual care and thoroughness of the consulting profession for the use of the Greater Hume Council and only those third parties who have been authorises by DM McMahon Pty Ltd to rely on this report.

The information contained in this report has been extracted from field and laboratory source believed to be reliable and accurate. DM McMahon Pty Ltd nor the Certified Site Contamination Specialist assume any responsibility for the misinterpretation of information supplied in this report. The accuracy and reliability of recommendations identified in this report need to be evaluated with due care according to individual circumstances. It should be noted that the recommendations and findings in this report are based solely upon the said site location and conditions at the time of testing. The results of the said investigations undertaken are an overall representation of the conditions encountered. The properties of the soil and groundwater within the location may change due to variations in ground conditions outside of the tested area. The author has no control or liability over site variability that may warrant further investigation that may lead to significant design changes.

14.0 Notice of copyright The information contained in this report must not be copied, reproduced, or used for any purpose other than a purpose approved by DM McMahon Pty Ltd, except as permitted under the Copyright Act 1968. Information cannot be stored or recorded electronically in any form without such permission.

DM McMahon Pty Ltd – October 2020 Page 24 of 25 Preliminary Site Investigation: Baird Street Culcairn NSW 2660 Report 7326 15.0 References AS 1726, (2017). Geotechnical site investigations.

AS 4482.1, (2005). Guide to the investigation and sampling of sites with potentially contaminated soil Part 1: Non-volatile and semi-volatile compounds.

AS 4482.2, (1999). Guide to the sampling and investigation of potentially contaminated soil Part 2: Volatile substances.

BoM, (2020). Climate Data Online.

Doughty, D, (2003). Soil Landscapes of the Holbrook-Tallangatta 1:100,000 Sheets map and report, Department of Sustainable Natural Resources, Sydney.

Muller, R, Nicholson, A, Wooldridge, A, Jenkins, B, Winkler, M, Cook, W, Grant, S, and Moore CL, (2015). Hydrogeological Landscapes for the Eastern Murray Catchment, Office of Environment and Heritage, Sydney, NSW.

National Environment Protection (Assessment of Site Contamination) Measure, (2013).

NSW Department of Urban Affairs and Planning, (1998). Managing Land Contamination Planning Guidelines SEPP 55–Remediation of Land.

NSW EPA, (1995). Sampling Design Guidelines.

NSW EPA, (2020). Contaminated Land Guidelines, Consultants Reporting on Contaminated Land.

Water NSW, (2020). Water insights. Real-time data.

16.0 Attachments

Attachments Details A. Location map 1 page B. Lot and DP map 1 page C. Aerial photographs 16 pages D. Site map 1 page E. Site photographs 4 pages F. Sample location map 1 page G. Field notes 2 pages H. Tabulated results 1 page I. Laboratory reports 20 pages J. QA/QC assessment 1 page

DM McMahon Pty Ltd – October 2020 Page 25 of 25 REPORT 7326

DM McMahon Pty Ltd 6 Jones Street, (PO Box 6118) Wagga Wagga NSW 2650

t (02) 6931 0510 www.dmmcmahon.com.au Attachment A : Location map

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Baird St Culcairn NSW Legend Aerial photograph 2019 CU1 boundary Report No. 7326 ➤ © 2020 Google ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies N © 2020 Google ImageImage ©© 20202020 CNESCNES // AirbusAirbus 1 km Image © 2020 Maxar Technologies Image © 2020 CNES / Airbus Attachment B : Lot and DP map

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au

Attachment C : Aerial photographs

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Baird St Culcairn NSW Legend Aerial photograph 1959 Baird St Report No. 7326 CU1 boundary ➤ © 2020 Google ImageImage ©© 20202020 CNESCNES // AirbusAirbus N © 2020 Google ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies 500 m Image © 2020 CNES / Airbus Image © 2020 Maxar Technologies Baird St Culcairn NSW Legend Aerial photograph 1966 Baird St Report No. 7326 CU1 boundary ➤ © 2020 Google ImageImage ©© 20202020 CNESCNES // AirbusAirbus N © 2020 Google ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies 600 m Image © 2020 CNES / Airbus Image © 2020 Maxar Technologies Baird St Culcairn NSW Legend Aerial photograph 1972 Baird St Report No. 7326 CU1 boundary ➤ © 2020 Google ImageImage ©© 20202020 CNESCNES // AirbusAirbus N © 2020 Google ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies 600 m Image © 2020 CNES / Airbus Image © 2020 Maxar Technologies Baird St Culcairn NSW Legend Aerial photograph 1980 Baird St Report No. 7326 CU1 boundary ➤ © 2020 Google ImageImage ©© 20202020 CNESCNES // AirbusAirbus N © 2020 Google ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies 600 m Image © 2020 CNES / Airbus Image © 2020 Maxar Technologies Baird St Culcairn NSW Legend Aerial photograph 1991 Baird St Report No. 7326 CU1 boundary ➤ © 2020 Google ImageImage ©© 20202020 CNESCNES // AirbusAirbus N © 2020 Google ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies 600 m Image © 2020 CNES / Airbus Image © 2020 Maxar Technologies Baird St Culcairn NSW Legend Aerial photograph 1996 Baird St Report No. 7326 CU1 boundary ➤ © 2020 Google ImageImage ©© 20202020 CNESCNES // AirbusAirbus N © 2020 Google ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies 600 m Image © 2020 CNES / Airbus Image © 2020 Maxar Technologies Baird St Culcairn NSW Legend Aerial photograph 1998 Baird St Report No. 7326 CU1 boundary ➤ © 2020 Google ImageImage ©© 20202020 CNESCNES // AirbusAirbus N © 2020 Google ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies 600 m Image © 2020 CNES / Airbus Image © 2020 Maxar Technologies Baird St Culcairn NSW Legend Aerial photograph 2007 CU1 boundary Report No. 7326 ➤ N

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Baird St Culcairn NSW Legend Aerial photograph 2019 Boundary (CU1) Report No. 7326 Building(s) Council pound Stockpiled material ➤ ImageImage ©© 20202020 CNESCNES // AirbusAirbus ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies N Image © 2020 CNES / Airbus © 2020 Google 600 m Image © 2020 Maxar Technologies © 2020 Google Attachment E : Site photographs

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Site photographs Baird Street Culcairn (CU1) Report No. 7326

Photograph 1: The large dam on Lot 4 DP 7064.

Photograph 2: The Council livestock pound on Lot 291 DP 1124610.

October 2020 Page 1 of 4 Site photographs Baird Street Culcairn (CU1) Report No. 7326

Photograph 3: The house and garage on Lot 3 DP 7064.

Photograph 4: House and driveway on Lot 2 DP 7065.

October 2020 Page 2 of 4

Site photographs Baird Street Culcairn (CU1) Report No. 7326

Photograph 5: House and driveway on Lot 6 DP7064.

Photograph 6: The 2ha area of uncontrolled fill material on Lot 5 DP250901.

October 2020 Page 3 of 4

Site photographs Baird Street Culcairn (CU1) Report No. 7326

Photograph 7: Oats crop on Lot 5 DP 250901.

Photograph 8: The Canola crop on Lot 5 DP 7064 (left) and grass pasture on Lot 4 DP 7064 (right).

October 2020 Page 4 of 4

Attachment F : Sample location map

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Baird St Culcairn NSW Legend Aerial photograph 2019 CU1 boundary Reprot No. 7326 Sample point ➤ ImageImage ©© 20202020 CNESCNES // AirbusAirbus ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies N Image © 2020 CNES / Airbus © 2020 Google 500 m Image © 2020 Maxar Technologies © 2020 Google Attachment G : Field notes

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au

Attachment H : alated reslts

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au EILs EILs - Table 1B(5) Residential, (2013) <2M NEPM depth ACLs - Table 1B(1-5) Residential (2013) A,<2M NEPM depth , pH ofof 10 CEC 6.0, HILs A - Table 1A(1) Residential (2013) A,<3M NEPM depth Sample Point Point 8 Point 7 Point 6 Point 5 Point 4 Point 3 Point 2 Point 1 Point Sample ID 7326/8 7326/7 7326/6 7326/5 7326/4 7326/3 7326/2 7326/1 Limit ofReporting Unit ofMeasure Sample depth 0.1-0.2m 0.1-0.2m 0.1-0.2m 0.1-0.2m 0.1-0.2m 0.1-0.2m 0.1-0.2m 0.1-0.2m HILs A HILs ACLs EILs mg/kg 100 100 10 10 8 8 8 8 6 7 5 - Arsenic mg/kg 20 <1 <1 <1 <1 <1 <1 <1 <1 1 - - Cadmium mg/kg 400 22 18 18 13 16 14 17 14 2 - - Chromium mg/kg 6000 190 10 10 8 9 8 8 8 8 5 - Copper mg/kg 1100 300 14 16 16 16 18 14 22 15 5 - Lead mg/kg 170 400 11 11 10 9 9 7 8 8 2 - Nickel mg/kg 7400 400 10 20 17 29 19 16 16 16 5 - Zinc mg/kg <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1 0.1 40 - - Mercury mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.05 10 - - HCB mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.05 6 - - Heptachlor mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.1 50 - - Chlordane mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.05 10 - - Endrin mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.05 270 - - Endosulfan mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 300 0.2 - - Methoxychlor mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.05 6 - - Aldrin + Dieldrin mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.05 240

- - DDT + DDE +DDT mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 <0.05 0.05 160 - - Chlorpyrifos mg/kg 0.05 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 <0.2 180 - - DDT Attachment I : Laorator reports

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au 0 0.00 True

Environmental CERTIFICATE OF ANALYSIS Work Order : ES2037100 Page : 1 of 8 Client : DM MCMAHON PTY LTD Laboratory : Environmental Division Sydney Contact : ADMIN Contact : Grace White Address : 6 JONES ST Address : 277-289 Woodpark Road Smithfield NSW Australia 2164 Wagga Wagga NSW, AUSTRALIA 2650 Telephone : +61 02 6931 0510 Telephone : +61 2 8784 8555 Project : BAIRD ST CULCAIM Date Samples Received : 22-Oct-2020 11:40 Order number : 7326 Date Analysis Commenced : 23-Oct-2020 C-O-C number : ---- Issue Date : 28-Oct-2020 15:48 Sampler : DAVID MCMAHON Site : ---- Quote number : EN/222 No. of samples received : 10 No. of samples analysed : 10 This report supersedes any previous report(s) with this reference. Results apply to the sample(s) as submitted. This document shall not be reproduced, except in full. This Certificate of Analysis contains the following information: l General Comments l Analytical Results l Surrogate Control Limits Additional information pertinent to this report will be found in the following separate attachments: Quality Control Report, QA/QC Compliance Assessment to assist with Quality Review and Sample Receipt Notification. Signatories This document has been electronically signed by the authorized signatories below. Electronic signing is carried out in compliance with procedures specified in 21 CFR Part 11. Signatories Position Accreditation Category Edwandy Fadjar Organic Coordinator Sydney Organics, Smithfield, NSW Ivan Taylor Analyst Sydney Inorganics, Smithfield, NSW

R I G H T S O L U T I O N S | R I G H T P A R T N E R Page : 2 of 8 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM General Comments

The analytical procedures used by ALS have been developed from established internationally recognised procedures such as those published by the USEPA, APHA, AS and NEPM. In house developed procedures are fully validated and are often at the client request. Where moisture determination has been performed, results are reported on a dry weight basis. Where a reported less than (<) result is higher than the LOR, this may be due to primary sample extract/digestate dilution and/or insufficient sample for analysis.

Where the LOR of a reported result differs from standard LOR, this may be due to high moisture content, insufficient sample (reduced weight employed) or matrix interference.

When sampling time information is not provided by the client, sampling dates are shown without a time component. In these instances, the time component has been assumed by the laboratory for processing purposes. Where a result is required to meet compliance limits the associated uncertainty must be considered. Refer to the ALS Contact for details.

Key : CAS Number = CAS registry number from database maintained by Chemical Abstracts Services. The Chemical Abstracts Service is a division of the American Chemical Society. LOR = Limit of reporting ^ = This result is computed from individual analyte detections at or above the level of reporting ø = ALS is not NATA accredited for these tests. ~ = Indicates an estimated value. l EP068: Where reported, Total Chlordane (sum) is the sum of the reported concentrations of cis-Chlordane and trans-Chlordane at or above the LOR. l EP068: Where reported, Total OCP is the sum of the reported concentrations of all Organochlorine Pesticides at or above LOR. Page : 3 of 8 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM Analytical Results

Sub-Matrix: SOIL Client sample ID 7326/1 7326/2 7326/3 7326/4 7326/5 (Matrix: SOIL) Client sampling date / time 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 Compound CAS Number LOR Unit ES2037100-001 ES2037100-002 ES2037100-003 ES2037100-004 ES2037100-005 Result Result Result Result Result EA055: Moisture Content (Dried @ 105-110°C) Moisture Content ---- 1.0 % 6.2 12.0 8.5 13.6 8.7 EG005(ED093)T: Total Metals by ICP-AES Arsenic 7440-38-2 5 mg/kg 7 10 6 8 8 Cadmium 7440-43-9 1 mg/kg <1 <1 <1 <1 <1 Chromium 7440-47-3 2 mg/kg 14 17 14 16 13 Copper 7440-50-8 5 mg/kg 8 8 8 10 8 Lead 7439-92-1 5 mg/kg 15 22 14 18 16 Nickel 7440-02-0 2 mg/kg 8 10 8 11 7 Zinc 7440-66-6 5 mg/kg 16 16 16 19 29 EG035T: Total Recoverable Mercury by FIMS Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 <0.1 <0.1 <0.1 EP068A: Organochlorine Pesticides (OC) alpha-BHC 319-84-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 beta-BHC 319-85-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 gamma-BHC 58-89-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 delta-BHC 319-86-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Heptachlor 76-44-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Aldrin 309-00-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 ^ Total Chlordane (sum) ---- 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Dieldrin 60-57-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Endrin 72-20-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 ^ Endosulfan (sum) 115-29-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 Endrin ketone 53494-70-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Page : 4 of 8 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM Analytical Results

Sub-Matrix: SOIL Client sample ID 7326/1 7326/2 7326/3 7326/4 7326/5 (Matrix: SOIL) Client sampling date / time 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 Compound CAS Number LOR Unit ES2037100-001 ES2037100-002 ES2037100-003 ES2037100-004 ES2037100-005 Result Result Result Result Result EP068A: Organochlorine Pesticides (OC) - Continued Methoxychlor 72-43-5 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 ^ Sum of Aldrin + Dieldrin 309-00-2/60-57-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 ^ Sum of DDD + DDE + DDT 72-54-8/72-55-9/5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 0-2 EP068B: Organophosphorus Pesticides (OP) Dichlorvos 62-73-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Monocrotophos 6923-22-4 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 Dimethoate 60-51-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Diazinon 333-41-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Parathion-methyl 298-00-0 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 Malathion 121-75-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Fenthion 55-38-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Parathion 56-38-2 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Fenamiphos 22224-92-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Prothiofos 34643-46-4 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Ethion 563-12-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Carbophenothion 786-19-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 EP068S: Organochlorine Pesticide Surrogate Dibromo-DDE 21655-73-2 0.05 % 90.5 95.0 92.6 89.0 89.9 EP068T: Organophosphorus Pesticide Surrogate DEF 78-48-8 0.05 % 93.6 90.1 91.0 86.4 78.6 Page : 5 of 8 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM Analytical Results

Sub-Matrix: SOIL Client sample ID 7326/6 7326/7 7326/8 7326/D ---- (Matrix: SOIL) Client sampling date / time 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 ---- Compound CAS Number LOR Unit ES2037100-006 ES2037100-007 ES2037100-008 ES2037100-009 ------Result Result Result Result ---- EA055: Moisture Content (Dried @ 105-110°C) Moisture Content ---- 1.0 % 8.6 15.7 12.6 7.3 ---- EG005(ED093)T: Total Metals by ICP-AES Arsenic 7440-38-2 5 mg/kg 8 10 8 7 ---- Cadmium 7440-43-9 1 mg/kg <1 <1 <1 <1 ---- Chromium 7440-47-3 2 mg/kg 18 18 22 15 ---- Copper 7440-50-8 5 mg/kg 9 10 8 8 ---- Lead 7439-92-1 5 mg/kg 16 16 14 16 ---- Nickel 7440-02-0 2 mg/kg 9 11 9 8 ---- Zinc 7440-66-6 5 mg/kg 17 20 10 18 ---- EG035T: Total Recoverable Mercury by FIMS Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 <0.1 <0.1 ---- EP068A: Organochlorine Pesticides (OC) alpha-BHC 319-84-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- beta-BHC 319-85-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- gamma-BHC 58-89-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- delta-BHC 319-86-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Heptachlor 76-44-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Aldrin 309-00-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- ^ Total Chlordane (sum) ---- 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Dieldrin 60-57-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Endrin 72-20-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- ^ Endosulfan (sum) 115-29-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- Endrin ketone 53494-70-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Page : 6 of 8 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM Analytical Results

Sub-Matrix: SOIL Client sample ID 7326/6 7326/7 7326/8 7326/D ---- (Matrix: SOIL) Client sampling date / time 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 ---- Compound CAS Number LOR Unit ES2037100-006 ES2037100-007 ES2037100-008 ES2037100-009 ------Result Result Result Result ---- EP068A: Organochlorine Pesticides (OC) - Continued Methoxychlor 72-43-5 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- ^ Sum of Aldrin + Dieldrin 309-00-2/60-57-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- ^ Sum of DDD + DDE + DDT 72-54-8/72-55-9/5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- 0-2 EP068B: Organophosphorus Pesticides (OP) Dichlorvos 62-73-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Monocrotophos 6923-22-4 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- Dimethoate 60-51-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Diazinon 333-41-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Parathion-methyl 298-00-0 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- Malathion 121-75-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Fenthion 55-38-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Parathion 56-38-2 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Fenamiphos 22224-92-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Prothiofos 34643-46-4 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Ethion 563-12-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Carbophenothion 786-19-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- EP068S: Organochlorine Pesticide Surrogate Dibromo-DDE 21655-73-2 0.05 % 97.5 113 94.9 89.2 ---- EP068T: Organophosphorus Pesticide Surrogate DEF 78-48-8 0.05 % 85.3 94.1 79.0 81.8 ---- Page : 7 of 8 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM Analytical Results

Sub-Matrix: WATER Client sample ID 7326/R ------(Matrix: WATER) Client sampling date / time 21-Oct-2020 00:00 ------Compound CAS Number LOR Unit ES2037100-010 ------Result ------EG020T: Total Metals by ICP-MS Arsenic 7440-38-2 0.001 mg/L <0.001 ------Cadmium 7440-43-9 0.0001 mg/L <0.0001 ------Chromium 7440-47-3 0.001 mg/L <0.001 ------Copper 7440-50-8 0.001 mg/L <0.001 ------Nickel 7440-02-0 0.001 mg/L <0.001 ------Lead 7439-92-1 0.001 mg/L <0.001 ------Zinc 7440-66-6 0.005 mg/L <0.005 ------EG035T: Total Recoverable Mercury by FIMS Mercury 7439-97-6 0.0001 mg/L <0.0001 ------Page : 8 of 8 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM Surrogate Control Limits

Sub-Matrix: SOIL Recovery Limits (%) Compound CAS Number Low High EP068S: Organochlorine Pesticide Surrogate Dibromo-DDE 21655-73-2 49 147 EP068T: Organophosphorus Pesticide Surrogate DEF 78-48-8 35 143 True2.00 2 False Environmental QUALITY CONTROL REPORT

Work Order : ES2037100 Page : 1 of 7

Client : DM MCMAHON PTY LTD Laboratory : Environmental Division Sydney Contact : ADMIN Contact : Grace White Address : 6 JONES ST Address : 277-289 Woodpark Road Smithfield NSW Australia 2164 Wagga Wagga NSW, AUSTRALIA 2650 Telephone : +61 02 6931 0510 Telephone : +61 2 8784 8555 Project : BAIRD ST CULCAIM Date Samples Received : 22-Oct-2020 Order number : 7326 Date Analysis Commenced : 23-Oct-2020 C-O-C number : ---- Issue Date : 28-Oct-2020 Sampler : DAVID MCMAHON Site : ---- Quote number : EN/222 No. of samples received : 10 No. of samples analysed : 10 This report supersedes any previous report(s) with this reference. Results apply to the sample(s) as submitted. This document shall not be reproduced, except in full. This Quality Control Report contains the following information: l Laboratory Duplicate (DUP) Report; Relative Percentage Difference (RPD) and Acceptance Limits l Method Blank (MB) and Laboratory Control Spike (LCS) Report; Recovery and Acceptance Limits l Matrix Spike (MS) Report; Recovery and Acceptance Limits Signatories This document has been electronically signed by the authorized signatories below. Electronic signing is carried out in compliance with procedures specified in 21 CFR Part 11. Signatories Position Accreditation Category

Edwandy Fadjar Organic Coordinator Sydney Organics, Smithfield, NSW Ivan Taylor Analyst Sydney Inorganics, Smithfield, NSW

R I G H T S O L U T I O N S | R I G H T P A R T N E R Page : 2 of 7 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM General Comments The analytical procedures used by ALS have been developed from established internationally recognised procedures such as those published by the USEPA, APHA, AS and NEPM. In house developed procedures are fully validated and are often at the client request. Where moisture determination has been performed, results are reported on a dry weight basis. Where a reported less than (<) result is higher than the LOR, this may be due to primary sample extract/digestate dilution and/or insufficient sample for analysis. Where the LOR of a reported result differs from standard LOR, this may be due to high moisture content, insufficient sample (reduced weight employed) or matrix interference.

Key : Anonymous = Refers to samples which are not specifically part of this work order but formed part of the QC process lot CAS Number = CAS registry number from database maintained by Chemical Abstracts Services. The Chemical Abstracts Service is a division of the American Chemical Society. LOR = Limit of reporting RPD = Relative Percentage Difference # = Indicates failed QC Laboratory Duplicate (DUP) Report The quality control term Laboratory Duplicate refers to a randomly selected intralaboratory split. Laboratory duplicates provide information regarding method precision and sample heterogeneity. The permitted ranges for the Relative Percent Deviation (RPD) of Laboratory Duplicates are specified in ALS Method QWI-EN/38 and are dependent on the magnitude of results in comparison to the level of reporting: Result < 10 times LOR: No Limit; Result between 10 and 20 times LOR: 0% - 50%; Result > 20 times LOR: 0% - 20%. Sub-Matrix: SOIL Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EG005(ED093)T: Total Metals by ICP-AES (QC Lot: 3326117) ES2037099-002 Anonymous EG005T: Arsenic 7440-38-2 5 mg/kg 1140 1110 2.80 0% - 20% ES2037099-002 Anonymous EG005T: Cadmium 7440-43-9 1 mg/kg <1 <1 0.00 No Limit EG005T: Chromium 7440-47-3 2 mg/kg 18 20 10.7 0% - 50% EG005T: Nickel 7440-02-0 2 mg/kg 14 12 8.89 No Limit EG005T: Copper 7440-50-8 5 mg/kg 11 11 0.00 No Limit EG005T: Lead 7439-92-1 5 mg/kg 20 20 0.00 No Limit EG005T: Zinc 7440-66-6 5 mg/kg 47 44 5.85 No Limit ES2037100-008 7326/8 EG005T: Cadmium 7440-43-9 1 mg/kg <1 <1 0.00 No Limit EG005T: Chromium 7440-47-3 2 mg/kg 22 21 4.97 0% - 50% EG005T: Nickel 7440-02-0 2 mg/kg 9 12 30.2 No Limit EG005T: Arsenic 7440-38-2 5 mg/kg 8 8 0.00 No Limit EG005T: Copper 7440-50-8 5 mg/kg 8 10 24.5 No Limit EG005T: Lead 7439-92-1 5 mg/kg 14 15 0.00 No Limit EG005T: Zinc 7440-66-6 5 mg/kg 10 15 38.6 No Limit EA055: Moisture Content (Dried @ 105-110°C) (QC Lot: 3326121) ES2037099-004 Anonymous EA055: Moisture Content ---- 0.1 % 9.6 9.2 4.42 No Limit ES2037101-002 Anonymous EA055: Moisture Content ---- 0.1 % 13.0 12.6 3.39 0% - 50% EG035T: Total Recoverable Mercury by FIMS (QC Lot: 3326118) ES2037099-002 Anonymous EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 0.00 No Limit ES2037100-008 7326/8 EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 0.00 No Limit EP068A: Organochlorine Pesticides (OC) (QC Lot: 3324913) ES2037100-001 7326/1 EP068: alpha-BHC 319-84-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: beta-BHC 319-85-7 0.05 mg/kg <0.05 <0.05 0.00 No Limit Page : 3 of 7 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM

Sub-Matrix: SOIL Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EP068A: Organochlorine Pesticides (OC) (QC Lot: 3324913) - continued ES2037100-001 7326/1 EP068: gamma-BHC 58-89-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: delta-BHC 319-86-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Heptachlor 76-44-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Aldrin 309-00-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Dieldrin 60-57-1 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endrin 72-20-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endrin ketone 53494-70-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068: Methoxychlor 72-43-5 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068B: Organophosphorus Pesticides (OP) (QC Lot: 3324913) ES2037100-001 7326/1 EP068: Dichlorvos 62-73-7 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Dimethoate 60-51-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Diazinon 333-41-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Malathion 121-75-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Fenthion 55-38-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Fenamiphos 22224-92-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Prothiofos 34643-46-4 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Ethion 563-12-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Carbophenothion 786-19-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Monocrotophos 6923-22-4 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068: Parathion-methyl 298-00-0 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068: Parathion 56-38-2 0.2 mg/kg <0.2 <0.2 0.00 No Limit

Sub-Matrix: WATER Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EG020T: Total Metals by ICP-MS (QC Lot: 3325972) ES2036999-001 Anonymous EG020A-T: Cadmium 7440-43-9 0.0001 mg/L 0.0197 0.0198 0.00 0% - 20% EG020A-T: Arsenic 7440-38-2 0.001 mg/L 0.007 0.007 0.00 No Limit EG020A-T: Chromium 7440-47-3 0.001 mg/L 0.001 0.002 0.00 No Limit EG020A-T: Copper 7440-50-8 0.001 mg/L 0.174 0.177 1.40 0% - 20% EG020A-T: Lead 7439-92-1 0.001 mg/L 0.010 0.010 0.00 No Limit EG020A-T: Nickel 7440-02-0 0.001 mg/L 0.003 0.003 0.00 No Limit EG020A-T: Zinc 7440-66-6 0.005 mg/L 0.309 0.314 1.60 0% - 20% ES2037064-008 Anonymous EG020A-T: Cadmium 7440-43-9 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit EG020A-T: Arsenic 7440-38-2 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Chromium 7440-47-3 0.001 mg/L 0.002 0.002 0.00 No Limit EG020A-T: Copper 7440-50-8 0.001 mg/L 0.018 0.018 0.00 0% - 50% EG020A-T: Lead 7439-92-1 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Nickel 7440-02-0 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Zinc 7440-66-6 0.005 mg/L 0.009 0.009 0.00 No Limit EG035T: Total Recoverable Mercury by FIMS (QC Lot: 3325960) ES2036947-004 Anonymous EG035T: Mercury 7439-97-6 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit ES2037064-009 Anonymous EG035T: Mercury 7439-97-6 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit Page : 5 of 7 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM Method Blank (MB) and Laboratory Control Spike (LCS) Report The quality control term Method / Laboratory Blank refers to an analyte free matrix to which all reagents are added in the same volumes or proportions as used in standard sample preparation. The purpose of this QC parameter is to monitor potential laboratory contamination. The quality control term Laboratory Control Spike (LCS) refers to a certified reference material, or a known interference free matrix spiked with target analytes. The purpose of this QC parameter is to monitor method precision and accuracy independent of sample matrix. Dynamic Recovery Limits are based on statistical evaluation of processed LCS.

Sub-Matrix: SOIL Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EG005(ED093)T: Total Metals by ICP-AES (QCLot: 3326117) EG005T: Arsenic 7440-38-2 5 mg/kg <5 121.1 mg/kg 104 88.0 113 EG005T: Cadmium 7440-43-9 1 mg/kg <1 0.74 mg/kg 108 70.0 130 EG005T: Chromium 7440-47-3 2 mg/kg <2 20.2 mg/kg 92.0 68.0 132 EG005T: Copper 7440-50-8 5 mg/kg <5 52.9 mg/kg 109 89.0 111 EG005T: Lead 7439-92-1 5 mg/kg <5 62.1 mg/kg 96.3 82.0 119 EG005T: Nickel 7440-02-0 2 mg/kg <2 15.4 mg/kg 95.3 80.0 120 EG005T: Zinc 7440-66-6 5 mg/kg <5 162 mg/kg 81.8 66.0 133 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326118) EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 0.0847 mg/kg 73.4 70.0 105 EP068A: Organochlorine Pesticides (OC) (QCLot: 3324913) EP068: alpha-BHC 319-84-6 0.05 mg/kg <0.05 0.5 mg/kg 92.5 69.0 113 EP068: Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 0.5 mg/kg 92.9 65.0 117 EP068: beta-BHC 319-85-7 0.05 mg/kg <0.05 0.5 mg/kg 79.4 67.0 119 EP068: gamma-BHC 58-89-9 0.05 mg/kg <0.05 0.5 mg/kg 97.7 68.0 116 EP068: delta-BHC 319-86-8 0.05 mg/kg <0.05 0.5 mg/kg 87.5 65.0 117 EP068: Heptachlor 76-44-8 0.05 mg/kg <0.05 0.5 mg/kg 90.8 67.0 115 EP068: Aldrin 309-00-2 0.05 mg/kg <0.05 0.5 mg/kg 92.7 69.0 115 EP068: Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 0.5 mg/kg 87.6 62.0 118 EP068: trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 0.5 mg/kg 89.5 63.0 117 EP068: alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 0.5 mg/kg 83.1 66.0 116 EP068: cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 0.5 mg/kg 77.0 64.0 116 EP068: Dieldrin 60-57-1 0.05 mg/kg <0.05 0.5 mg/kg 79.9 66.0 116 EP068: 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 0.5 mg/kg 82.6 67.0 115 EP068: Endrin 72-20-8 0.05 mg/kg <0.05 0.5 mg/kg 82.5 67.0 123 EP068: beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 0.5 mg/kg 88.0 69.0 115 EP068: 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 0.5 mg/kg 83.9 69.0 121 EP068: Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 0.5 mg/kg 86.6 56.0 120 EP068: Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 0.5 mg/kg 87.7 62.0 124 EP068: 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 0.5 mg/kg 91.7 66.0 120 EP068: Endrin ketone 53494-70-5 0.05 mg/kg <0.05 0.5 mg/kg 85.0 64.0 122 EP068: Methoxychlor 72-43-5 0.2 mg/kg <0.2 0.5 mg/kg 86.7 54.0 130 EP068B: Organophosphorus Pesticides (OP) (QCLot: 3324913) EP068: Dichlorvos 62-73-7 0.05 mg/kg <0.05 0.5 mg/kg 95.9 59.0 119 EP068: Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 0.5 mg/kg 85.7 62.0 128 Page : 6 of 7 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM

Sub-Matrix: SOIL Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EP068B: Organophosphorus Pesticides (OP) (QCLot: 3324913) - continued EP068: Monocrotophos 6923-22-4 0.2 mg/kg <0.2 0.5 mg/kg 90.6 54.0 126 EP068: Dimethoate 60-51-5 0.05 mg/kg <0.05 0.5 mg/kg 88.5 67.0 119 EP068: Diazinon 333-41-5 0.05 mg/kg <0.05 0.5 mg/kg 76.2 70.0 120 EP068: Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 0.5 mg/kg 83.6 72.0 120 EP068: Parathion-methyl 298-00-0 0.2 mg/kg <0.2 0.5 mg/kg 85.9 68.0 120 EP068: Malathion 121-75-5 0.05 mg/kg <0.05 0.5 mg/kg 80.4 68.0 122 EP068: Fenthion 55-38-9 0.05 mg/kg <0.05 0.5 mg/kg 87.6 69.0 117 EP068: Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 0.5 mg/kg 91.2 76.0 118 EP068: Parathion 56-38-2 0.2 mg/kg <0.2 0.5 mg/kg 90.3 64.0 122 EP068: Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 0.5 mg/kg 86.1 70.0 116 EP068: Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 0.5 mg/kg 86.7 69.0 121 EP068: Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 0.5 mg/kg 85.7 66.0 118 EP068: Fenamiphos 22224-92-6 0.05 mg/kg <0.05 0.5 mg/kg 86.9 68.0 124 EP068: Prothiofos 34643-46-4 0.05 mg/kg <0.05 0.5 mg/kg 80.1 62.0 112 EP068: Ethion 563-12-2 0.05 mg/kg <0.05 0.5 mg/kg 80.6 68.0 120 EP068: Carbophenothion 786-19-6 0.05 mg/kg <0.05 0.5 mg/kg 94.5 65.0 127 EP068: Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 0.5 mg/kg 81.6 41.0 123

Sub-Matrix: WATER Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EG020T: Total Metals by ICP-MS (QCLot: 3325972) EG020A-T: Arsenic 7440-38-2 0.001 mg/L <0.001 0.1 mg/L 94.1 82.0 114 EG020A-T: Cadmium 7440-43-9 0.0001 mg/L <0.0001 0.1 mg/L 94.6 84.0 112 EG020A-T: Chromium 7440-47-3 0.001 mg/L <0.001 0.1 mg/L 92.5 86.0 116 EG020A-T: Copper 7440-50-8 0.001 mg/L <0.001 0.1 mg/L 93.2 83.0 118 EG020A-T: Lead 7439-92-1 0.001 mg/L <0.001 0.1 mg/L 92.8 85.0 115 EG020A-T: Nickel 7440-02-0 0.001 mg/L <0.001 0.1 mg/L 94.4 84.0 116 EG020A-T: Zinc 7440-66-6 0.005 mg/L <0.005 0.1 mg/L 93.6 79.0 117 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3325960) EG035T: Mercury 7439-97-6 0.0001 mg/L <0.0001 0.01 mg/L 86.2 77.0 111

Matrix Spike (MS) Report The quality control term Matrix Spike (MS) refers to an intralaboratory split sample spiked with a representative set of target analytes. The purpose of this QC parameter is to monitor potential matrix effects on analyte recoveries. Static Recovery Limits as per laboratory Data Quality Objectives (DQOs). Ideal recovery ranges stated may be waived in the event of sample matrix interference. Sub-Matrix: SOIL Matrix Spike (MS) Report Spike SpikeRecovery(%) Recovery Limits (%)

Laboratory sample ID Client sample ID Method: Compound CAS Number Concentration MS Low High Page : 7 of 7 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM

Sub-Matrix: SOIL Matrix Spike (MS) Report Spike SpikeRecovery(%) Recovery Limits (%)

Laboratory sample ID Client sample ID Method: Compound CAS Number Concentration MS Low High EG005(ED093)T: Total Metals by ICP-AES (QCLot: 3326117) ES2037099-002 Anonymous EG005T: Arsenic 7440-38-2 50 mg/kg # Not 70.0 130 Determined EG005T: Cadmium 7440-43-9 50 mg/kg 97.6 70.0 130 EG005T: Chromium 7440-47-3 50 mg/kg 89.1 68.0 132 EG005T: Copper 7440-50-8 250 mg/kg 96.6 70.0 130 EG005T: Lead 7439-92-1 250 mg/kg 97.8 70.0 130 EG005T: Nickel 7440-02-0 50 mg/kg 94.6 70.0 130 EG005T: Zinc 7440-66-6 250 mg/kg 97.1 66.0 133 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326118) ES2037099-002 Anonymous EG035T: Mercury 7439-97-6 5 mg/kg 86.6 70.0 130 EP068A: Organochlorine Pesticides (OC) (QCLot: 3324913) ES2037100-001 7326/1 EP068: gamma-BHC 58-89-9 0.5 mg/kg 110 70.0 130 EP068: Heptachlor 76-44-8 0.5 mg/kg 73.8 70.0 130 EP068: Aldrin 309-00-2 0.5 mg/kg 77.2 70.0 130 EP068: Dieldrin 60-57-1 0.5 mg/kg 78.4 70.0 130 EP068: Endrin 72-20-8 2 mg/kg 98.0 70.0 130 EP068: 4.4`-DDT 50-29-3 2 mg/kg 102 70.0 130 EP068B: Organophosphorus Pesticides (OP) (QCLot: 3324913) ES2037100-001 7326/1 EP068: Diazinon 333-41-5 0.5 mg/kg 89.3 70.0 130 EP068: Chlorpyrifos-methyl 5598-13-0 0.5 mg/kg 87.4 70.0 130 EP068: Pirimphos-ethyl 23505-41-1 0.5 mg/kg 74.6 70.0 130 EP068: Bromophos-ethyl 4824-78-6 0.5 mg/kg 73.2 70.0 130 EP068: Prothiofos 34643-46-4 0.5 mg/kg 77.7 70.0 130

Sub-Matrix: WATER Matrix Spike (MS) Report Spike SpikeRecovery(%) Recovery Limits (%)

Laboratory sample ID Client sample ID Method: Compound CAS Number Concentration MS Low High EG020T: Total Metals by ICP-MS (QCLot: 3325972) ES2037047-008 Anonymous EG020A-T: Arsenic 7440-38-2 1 mg/L 89.1 70.0 130 EG020A-T: Cadmium 7440-43-9 0.25 mg/L 92.4 70.0 130 EG020A-T: Chromium 7440-47-3 1 mg/L 91.3 70.0 130 EG020A-T: Copper 7440-50-8 1 mg/L 89.1 70.0 130 EG020A-T: Lead 7439-92-1 1 mg/L 85.1 70.0 130 EG020A-T: Nickel 7440-02-0 1 mg/L 89.1 70.0 130 EG020A-T: Zinc 7440-66-6 1 mg/L 90.7 70.0 130 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3325960) ES2036947-005 Anonymous EG035T: Mercury 7439-97-6 0.01 mg/L 87.9 70.0 130 True

Environmental QA/QC Compliance Assessment to assist with Quality Review

Work Order : ES2037100 Page : 1 of 5

Client : DM MCMAHON PTY LTD Laboratory : Environmental Division Sydney Contact : ADMIN Telephone : +61 2 8784 8555 Project : BAIRD ST CULCAIM Date Samples Received : 22-Oct-2020 Site : ---- Issue Date : 28-Oct-2020 Sampler : DAVID MCMAHON No. of samples received : 10 Order number : 7326 No. of samples analysed : 10

This report is automatically generated by the ALS LIMS through interpretation of the ALS Quality Control Report and several Quality Assurance parameters measured by ALS. This automated reporting highlights any non-conformances, facilitates faster and more accurate data validation and is designed to assist internal expert and external Auditor review. Many components of this report contribute to the overall DQO assessment and reporting for guideline compliance.

Brief method summaries and references are also provided to assist in traceability.

Summary of Outliers Outliers : Quality Control Samples

This report highlights outliers flagged in the Quality Control (QC) Report. l NO Method Blank value outliers occur. l NO Duplicate outliers occur. l NO Laboratory Control outliers occur. l Matrix Spike outliers exist - please see following pages for full details. l For all regular sample matrices, NO surrogate recovery outliers occur.

Outliers : Analysis Holding Time Compliance l NO Analysis Holding Time Outliers exist.

Outliers : Frequency of Quality Control Samples l NO Quality Control Sample Frequency Outliers exist.

R I G H T S O L U T I O N S | R I G H T P A R T N E R Page : 2 of 5 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM Outliers : Quality Control Samples Duplicates, Method Blanks, Laboratory Control Samples and Matrix Spikes

Matrix: SOIL Compound Group Name Laboratory Sample ID Client Sample ID Analyte CAS Number Data Limits Comment Matrix Spike (MS) Recoveries EG005(ED093)T: Total Metals by ICP-AES ES2037099--002 Anonymous Arsenic 7440-38-2 Not ---- MS recovery not determined, Determined background level greater than or equal to 4x spike level.

Analysis Holding Time Compliance If samples are identified below as having been analysed or extracted outside of recommended holding times, this should be taken into consideration when interpreting results. This report summarizes extraction / preparation and analysis times and compares each with ALS recommended holding times (referencing USEPA SW 846, APHA, AS and NEPM) based on the sample container provided. Dates reported represent first date of extraction or analysis and preclude subsequent dilutions and reruns. A listing of breaches (if any) is provided herein. Holding time for leachate methods (e.g. TCLP) vary according to the analytes reported. Assessment compares the leach date with the shortest analyte holding time for the equivalent soil method. These are: organics 14 days, mercury 28 days & other metals 180 days. A recorded breach does not guarantee a breach for all non-volatile parameters. Holding times for VOC in soils vary according to analytes of interest. Vinyl Chloride and Styrene holding time is 7 days; others 14 days. A recorded breach does not guarantee a breach for all VOC analytes and should be verified in case the reported breach is a false positive or Vinyl Chloride and Styrene are not key analytes of interest/concern.

Matrix: SOIL Evaluation: û = Holding time breach ; ü = Within holding time. Method Sample Date Extraction / Preparation Analysis Container / Client Sample ID(s) Date extracted Due for extraction Evaluation Date analysed Due for analysis Evaluation

EA055: Moisture Content (Dried @ 105-110°C) Soil Glass Jar - Unpreserved (EA055) 7326/1, 7326/2, 21-Oct-2020 ------23-Oct-2020 04-Nov-2020 ü 7326/3, 7326/4, 7326/5, 7326/6, 7326/7, 7326/8, 7326/D EG005(ED093)T: Total Metals by ICP-AES Soil Glass Jar - Unpreserved (EG005T) 7326/1, 7326/2, 21-Oct-2020 23-Oct-2020 19-Apr-2021 ü 26-Oct-2020 19-Apr-2021 ü 7326/3, 7326/4, 7326/5, 7326/6, 7326/7, 7326/8, 7326/D EG035T: Total Recoverable Mercury by FIMS Soil Glass Jar - Unpreserved (EG035T) 7326/1, 7326/2, 21-Oct-2020 23-Oct-2020 18-Nov-2020 ü 27-Oct-2020 18-Nov-2020 ü 7326/3, 7326/4, 7326/5, 7326/6, 7326/7, 7326/8, 7326/D Page : 3 of 5 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM

EP068A: Organochlorine Pesticides (OC) Soil Glass Jar - Unpreserved (EP068) 7326/1, 7326/2, 21-Oct-2020 26-Oct-2020 04-Nov-2020 ü 27-Oct-2020 05-Dec-2020 ü 7326/3, 7326/4, 7326/5, 7326/6, 7326/7, 7326/8, 7326/D EP068B: Organophosphorus Pesticides (OP) Soil Glass Jar - Unpreserved (EP068) 7326/1, 7326/2, 21-Oct-2020 26-Oct-2020 04-Nov-2020 ü 27-Oct-2020 05-Dec-2020 ü 7326/3, 7326/4, 7326/5, 7326/6, 7326/7, 7326/8, 7326/D

Matrix: WATER Evaluation: û = Holding time breach ; ü = Within holding time. Method Sample Date Extraction / Preparation Analysis Container / Client Sample ID(s) Date extracted Due for extraction Evaluation Date analysed Due for analysis Evaluation

EG020T: Total Metals by ICP-MS Clear Plastic Bottle - Nitric Acid; Unfiltered (EG020A-T) 7326/R 21-Oct-2020 23-Oct-2020 19-Apr-2021 ü 23-Oct-2020 19-Apr-2021 ü EG035T: Total Recoverable Mercury by FIMS Clear Plastic Bottle - Nitric Acid; Unfiltered (EG035T) 7326/R 21-Oct-2020 ------27-Oct-2020 18-Nov-2020 ü Page : 4 of 5 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM

Quality Control Parameter Frequency Compliance The following report summarises the frequency of laboratory QC samples analysed within the analytical lot(s) in which the submitted sample(s) was(were) processed. Actual rate should be greater than or equal to the expected rate. A listing of breaches is provided in the Summary of Outliers.

Matrix: SOIL Evaluation: û = Quality Control frequency not within specification ; ü = Quality Control frequency within specification. Quality Control Sample Type Count Rate (%) Quality Control Specification Analytical Methods Method QC Regular Actual Expected Evaluation Laboratory Duplicates (DUP) Moisture Content EA055 2 20 10.00 10.00 ü NEPM 2013 B3 & ALS QC Standard Pesticides by GCMS EP068 1 9 11.11 10.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 2 18 11.11 10.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 3 20 15.00 10.00 ü NEPM 2013 B3 & ALS QC Standard Laboratory Control Samples (LCS) Pesticides by GCMS EP068 1 9 11.11 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 1 18 5.56 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 1 20 5.00 5.00 ü NEPM 2013 B3 & ALS QC Standard Method Blanks (MB) Pesticides by GCMS EP068 1 9 11.11 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 1 18 5.56 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 1 20 5.00 5.00 ü NEPM 2013 B3 & ALS QC Standard Matrix Spikes (MS) Pesticides by GCMS EP068 1 9 11.11 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 1 18 5.56 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 1 20 5.00 5.00 ü NEPM 2013 B3 & ALS QC Standard Matrix: WATER Evaluation: û = Quality Control frequency not within specification ; ü = Quality Control frequency within specification. Quality Control Sample Type Count Rate (%) Quality Control Specification Analytical Methods Method QC Regular Actual Expected Evaluation Laboratory Duplicates (DUP) Total Mercury by FIMS EG035T 2 17 11.76 10.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 2 18 11.11 10.00 ü NEPM 2013 B3 & ALS QC Standard Laboratory Control Samples (LCS) Total Mercury by FIMS EG035T 1 17 5.88 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 1 18 5.56 5.00 ü NEPM 2013 B3 & ALS QC Standard Method Blanks (MB) Total Mercury by FIMS EG035T 1 17 5.88 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 1 18 5.56 5.00 ü NEPM 2013 B3 & ALS QC Standard Matrix Spikes (MS) Total Mercury by FIMS EG035T 1 17 5.88 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 1 18 5.56 5.00 ü NEPM 2013 B3 & ALS QC Standard Page : 5 of 5 Work Order : ES2037100 Client : DM MCMAHON PTY LTD Project : BAIRD ST CULCAIM Brief Method Summaries The analytical procedures used by the Environmental Division have been developed from established internationally recognized procedures such as those published by the US EPA, APHA, AS and NEPM. In house developed procedures are employed in the absence of documented standards or by client request. The following report provides brief descriptions of the analytical procedures employed for results reported in the Certificate of Analysis. Sources from which ALS methods have been developed are provided within the Method Descriptions. Analytical Methods Method Matrix Method Descriptions Moisture Content EA055 SOIL In house: A gravimetric procedure based on weight loss over a 12 hour drying period at 105-110 degrees C. This method is compliant with NEPM Schedule B(3). Total Metals by ICP-AES EG005T SOIL In house: Referenced to APHA 3120; USEPA SW 846 - 6010. Metals are determined following an appropriate acid digestion of the soil. The ICPAES technique ionises samples in a plasma, emitting a characteristic spectrum based on metals present. Intensities at selected wavelengths are compared against those of matrix matched standards. This method is compliant with NEPM Schedule B(3) Total Mercury by FIMS EG035T SOIL In house: Referenced to AS 3550, APHA 3112 Hg - B (Flow-injection (SnCl2) (Cold Vapour generation) AAS) FIM-AAS is an automated flameless atomic absorption technique. Mercury in solids are determined following an appropriate acid digestion. Ionic mercury is reduced online to atomic mercury vapour by SnCl2 which is then purged into a heated quartz cell. Quantification is by comparing absorbance against a calibration curve. This method is compliant with NEPM Schedule B(3) Pesticides by GCMS EP068 SOIL In house: Referenced to USEPA SW 846 - 8270 Extracts are analysed by Capillary GC/MS and quantification is by comparison against an established 5 point calibration curve. This technique is compliant with NEPM Schedule B(3). Total Metals by ICP-MS - Suite A EG020A-T WATER In house: Referenced to APHA 3125; USEPA SW846 - 6020, ALS QWI-EN/EG020. The ICPMS technique utilizes a highly efficient argon plasma to ionize selected elements. Ions are then passed into a high vacuum mass spectrometer, which separates the analytes based on their distinct mass to charge ratios prior to their measurement by a discrete dynode ion detector. Total Mercury by FIMS EG035T WATER In house: Referenced to AS 3550, APHA 3112 Hg - B (Flow-injection (SnCl2)(Cold Vapour generation) AAS) FIM-AAS is an automated flameless atomic absorption technique. A bromate/bromide reagent is used to oxidise any organic mercury compounds in the unfiltered sample. The ionic mercury is reduced online to atomic mercury vapour by SnCl2 which is then purged into a heated quartz cell. Quantification is by comparing absorbance against a calibration curve. This method is compliant with NEPM Schedule B(3).

Preparation Methods Method Matrix Method Descriptions Hot Block Digest for metals in soils EN69 SOIL In house: Referenced to USEPA 200.2. Hot Block Acid Digestion 1.0g of sample is heated with Nitric and sediments and sludges Hydrochloric acids, then cooled. Peroxide is added and samples heated and cooled again before being filtered and bulked to volume for analysis. Digest is appropriate for determination of selected metals in sludge, sediments, and soils. This method is compliant with NEPM Schedule B(3). Tumbler Extraction of Solids ORG17 SOIL In house: Mechanical agitation (tumbler). 10g of sample, Na2SO4 and surrogate are extracted with 30mL 1:1 DCM/Acetone by end over end tumble. The solvent is decanted, dehydrated and concentrated (by KD) to the desired volume for analysis. Digestion for Total Recoverable Metals EN25 WATER In house: Referenced to USEPA SW846-3005. Method 3005 is a Nitric/Hydrochloric acid digestion procedure used to prepare surface and ground water samples for analysis by ICPAES or ICPMS. This method is compliant with NEPM Schedule B(3) Attachment J : AC assessment

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Duplicate Sample Sample Sample ID RPD Calculation (%) 7326/D 7326/1 Sample Point 1 Point Point 0.1-0.2m 0.1-0.2m Sample depth

0 7 7 Arsenic <1 <1 0 Cadmium 15 14 7 Chromium Parameter 0 8 8 Copper 16 15 7 Nickel 0 8 8 Lead 12 18 16 Zinc <0.1 <0.1 0 Mercury

RAILWAY PARADE CULCAIRN NSW

PRELIMINARY SITE INVESTIGATION

OCTOBER 2020

REFERENCE: 7363

DM McMahon Pty Ltd 6 Jones St (PO Box 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 www.dmmcmahon.com.au

Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 Report type Preliminary Site Investigation

Site address Railway Parade Culcairn NSW 2660

Report number 7363

Prepared for Colin Kane Director Environment & Planning Greater Hume Council 39 Young St (PO Box 99) Holbrook NSW 2644 Tel: 0260 448 928 Email: [email protected]

Prepared by DM McMahon Pty Ltd 6 Jones Street (PO Box 6118) Wagga Wagga NSW 2650 Tel: 0269 310 510 Email: [email protected]

Document control

Role Name Signed Date Revision Author Zach Bradley 30/10/2020 0 BEnvSc MALGA MEIANZ Certifier David McMahon CEnvP SC 30/10/2020 0 BAppSc SA GradDip WRM MEnvMgmt MALGA MEIANZ MSSA

DM McMahon Pty Ltd – October 2020 Page 2 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 Contents 1.0 Executive summary ...... 4 2.0 Objectives ...... 5 3.0 Scope of work ...... 6 4.0 Site identification ...... 7 5.0 Site history ...... 8 6.0 Site condition and surrounding environment ...... 10 7.0 Conceptual site model ...... 13 8.0 Sampling and analysis quality plan and sampling methodology ...... 15 9.0 Results ...... 19 10.0 Quality assurance/quality control data evaluation ...... 20 11.0 Conclusions and recommendations...... 22 12.0 Unexpected findings ...... 23 13.0 Limitations and disclaimer ...... 23 14.0 Notice of copyright ...... 23 15.0 References ...... 24 16.0 Attachments ...... 24

List of Tables Table 1: Site identification ...... 7 Table 2: Ownership ...... 8 Table 3: Sample media and analytes ...... 16 Table 4: Tier 1 analysis acceptance criteria ...... 16 Table 5: Sampling rationale ...... 17 Table 6: Sampling Data Quality Indicators ...... 20 Table 7: Analysis Data Quality Indicators ...... 21

DM McMahon Pty Ltd – October 2020 Page 3 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 1.0 Executive summary DM McMahon Pty Ltd (McMahon) conducted a Preliminary Site Investigation (PSI) at Railway Parade Culcairn NSW (the site). The 15ha (approx.) site identified by Council as CU2 is vacant land having a history of broad acre agriculture. The site is subject to a planning proposal for rezoning from RU1 primary production to RU5 village and reduction of the minimum lot size from 100ha to 600m2. Surrounding land uses include residential, agricultural, and commercial. A map of the site location can be seen in Attachment A.

The objective of this investigation is to assess whether contamination has the potential to exist on the site and whether further investigation is needed.

The scope of work includes: • A desktop study used to collect basic site information and identify the site characteristics. • A site inspection with limited soil sampling using Data Quality Objectives (DQOs). • An assessment of the potential contamination source-pathway-receptor linkages. • Interpretation of data collected to conduct a risk assessment for site suitability regarding the proposed development.

Findings of the investigation include: • The site is undeveloped with a history of agricultural land use as far as records can ascertain, and as such pesticide use on agricultural land is the environmental concern. • Sampling of the agricultural land returned results below the adopted criteria for residential land use and as such the potential contaminants that may be present in these areas are assessed to be of low significance in terms of risk to future residential site users.

In summary McMahon assess there is no gross contamination across the site. The site is considered suitable for the proposed residential land use, with a low risk of harm to human health and the environment, regarding potential contamination from the previous land uses.

This executive summary and the findings of this PSI is subject to limitations as stated in Section 13.

DM McMahon Pty Ltd – October 2020 Page 4 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 2.0 Objectives The objective of this investigation is to: • Provide information regarding potential contamination on site. • Provide a factual record of the works completed and results. • Undertake a risk assessment for health risk to future site users and the environment. • Provide a statement of recommendations for further investigation, remediation, and/or ongoing site management or alternatively, suitability of the site for the proposed land use. • To prepare the PSI in general accordance with the relevant guidelines and legislation, namely: o NSW EPA Contaminated land guidelines for Consultants reporting on contaminated sites (2020). o State Environmental Planning Policy 55 – Remediation of Land (SEPP 55). o National Environment Protection (Assessment of Site Contamination) Measure (NEPM), (2013).

DM McMahon Pty Ltd – October 2020 Page 5 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 3.0 Scope of work The scope of work includes the following: • Review the available information regarding historical, current, and proposed land use of the site and surrounds. • Review the environmental setting of the site and surrounds. • Assess the potential contamination sources and Chemicals of Potential Concerns (CoPCs). • Assess the potential contamination source-pathway-receptor linkages from the CoPCs, environmental setting and land use. • Formulate a Sampling, Analysis & Quality Plan (SAQP) to investigate the potential contamination. • Conduct limited soil sampling across the site for the CoPCs to assess the requirement for further investigation. • Collect soil samples for laboratory analysis of the CoPCs. • Compare the laboratory results against the adopted criteria. • Evaluate Quality Assurance/Quality Control (QA/QC) data to assess the sampling and analysis procedure. • Refine a Conceptual Site Model (CSM) to assess potential contamination risk from the source-pathway-receptor linkages. • Provide a clear statement on site suitability for the proposed land use or the need for further investigation, remediation, and/or ongoing site management.

DM McMahon Pty Ltd – October 2020 Page 6 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 4.0 Site identification The site identification can be seen as follows, Table 1.

Table 1: Site identification Identifier Details Railway Parade (CU2) Property identification/address Culcairn NSW 2660 Real property description Part Lot A DP385255 Centre co-ordinate 503435E 6054010N MGA GDA z55 Property size 15ha (approx.) Owner(s) Bruce Barber Local Government Area Greater Hume Council Present use Agricultural Present zoning RU1 Primary Production Proposed zoning RU5 Village

DM McMahon Pty Ltd – October 2020 Page 7 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 5.0 Site history From research of land titles, Council records, EPA records, aerial photography, and information provided by the owner, the following site history is offered:

Ownership Council records and the land titles database were investigated for land use, ownership history, previous owner occupations and other notes of interest, Table 2.

Table 2: Ownership Year Owner/occupier Occupation/land-use Reference owned/occupied Gordon William Coutts Farmer & Grazier 1947 Title search

Ronald Richard Coutts - 1948 Title search

John Rowe Farmer 1950 Title search

George Leslie Barber Farmer 1950 Title search

Arthur Frederick Piltz Farmer 1954 Title search

Allan Thomas Barber & Farmer 1965 Title search Dorothy May Barber

Bruce Barber Farmer 2020 Title search

Council records No Council records for development applications and building approvals were available at the time of reporting. The site is not on the Council contaminated land register.

Aerial photos McMahon observed the following from a review of the available aerial photography. 1959 – The site is broadacre agricultural land with two trees. Agricultural land use surrounding with two houses to the north of the site. 1966 – A farm dam and drainage line is visible to the south of the two trees. No other change. 1972 – No change. 1980 – Another house has been built north of the site. No other change. 1990 – No change. 1991 – No change. 1996 – Another house has been built north of the site. No other change.

DM McMahon Pty Ltd – October 2020 Page 8 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 1998 – No change. 2007 – More residential and commercial development to the north and east of the site. No other change 2010 – No change. 2013 – No change. 2014 – No change. 2015 – No change. 2016 – No change. 2017 – No change. 2018 – No change. 2019 – No change.

The aerial photographs can be seen in Attachment B.

Interviews McMahon conducted an interview with Bruce Barber (current owner) and the following was forthcoming. • Bruce’s parents owned the property before him, and they purchased the property 55 years ago. • The property has never been for intensive agriculture and has been used as a hobby farm. • No development or improvements have been undertaken on the property nor have existed on the property.

McMahon assesses that the information supplied by Bruce Barber is reliable based on comparable findings from the site inspection, research, and multiple lines of evidence.

DM McMahon Pty Ltd – October 2020 Page 9 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 6.0 Site condition and surrounding environment McMahon notes the following observations of the site condition as part of this PSI:

Layout • The site consists of three paddocks with two trees and a farm dam.

Buildings • None.

Septic systems • None.

Site surface • The surface is natural soil. • The site is planted to forage brassica with some grasses. • There was no surface chemical or hydrocarbons staining.

Other • An unnamed drainage on the southern boundary. • A low-lying area in the south west corner. • The site and paddocks are fenced with wire.

Surrounds • The site fronts Railway Parade. • The site is bound by the Railway Parade to the east, Baird Street to the north and a Stock Road to the west. • Commercial and residential land lies to the north. • Residential land lies to the east. • Agricultural and residential land lies to the south. • Agricultural land lies to the west.

A map of the site features can be seen in Attachment C.

Site photographs can be seen in Attachment D.

A summary of the site environmental setting is as follows.

Topography The Culcairn 1:25,000 Topographic Map (8326-4S) indicates that the site is located at an elevation of approximately 215m AHD. The site landform is classed as an alluvial plain and the slope is level to very gently inclined towards the west south west.

Vegetation Vegetation is forage brassica and grass in healthy condition.

DM McMahon Pty Ltd – October 2020 Page 10 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363

Hydrology The nearest named waterway is the Billabong Creek located around 400m to the south of the site. An unnamed drainage (a tributary of the Billabong Creek) lies on the southern boundary of the site with a very widely spaced stream channel occurrence. Flow direction is generally to the west with a convergent, integrated, and tributary channel patterns. Due to the relative incline of the site, rainfall will both infiltrate into the soil and run off the surface.

Hydrogeology The site lies within the Lower Billabong Hydrogeological Landscape (HGL). As described by Muller et. al. (2015), aquifers within the Lower Billabong HGL are unconfined to semi-confined, with groundwater flow occurring primarily through unconsolidated alluvial sediments. Hydraulic conductivity is high, and transmissivity is moderate to high. Groundwater recharge rates are estimated to be high.

DM McMahon Pty Ltd – October 2020 Page 11 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363

Medium to long residence times are typical. These landscapes have a slow to medium response time to changes in land management.

From a search of the Water NSW database there are no registered groundwater bores located on site. There are four registered groundwater bores located within 500m of the site for general use, stock/domestic and general use. From the available information these bores are 20m to 63m deep and are constructed into the underlying alluvium and rock. From this McMahon assess that a groundwater resource on site is likely to be deep and in the underlying alluvium and rock (14m+).

DM McMahon Pty Ltd – October 2020 Page 12 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 7.0 Conceptual site model A Conceptual Site Model (CSM) is a representation of site-related information regarding contamination sources, receptors and exposure pathways between those sources and receptors.

The CSM is presented as follows.

List of contaminants of potential concern

The preliminary nature of sampling in this PSI is to assess the requirement for further investigation across the wider rezoning area, therefore the CoPCs reflect the persistent chemicals from the agricultural land use, namely: • Heavy metals- Arsenic (As), Cadmium (Cd), Chromium (Cr), Copper (Cu), Nickel (Ni), Lead (Pb), Zinc (Zn), Mercury (Hg). • Organochlorines (OCPs). • Organophosphates (OPPs).

Potential and known sources of contamination • Pesticide and herbicide use on agricultural land.

Mechanism of contamination The mechanism of contamination from the primary source is predominantly top down vertical migration into soil.

Potentially affected environmental media • Surface and near surface soil. • Groundwater through soil media from surface spills but unlikely owing to deep depths (>14m).

Actual or potential exposure pathways • Direct skin contact with soil. • Inhalation and/or ingestion of soil, vapour, and dust. • Groundwater is deep (>20m) and unlikely to be directly contacted. • Groundwater ingestion but no domestic groundwater bores currently exist on site.

Human and ecological receptors • Current and future on-site residents. • Future on-sites workers.

DM McMahon Pty Ltd – October 2020 Page 13 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 • Domestic groundwater users but no domestic groundwater bores currently exist on site. • Down gradient ecological receptors such as the Billabong Creek. • Current and future landscaping and ecological receptors.

Source pathway receptor linkage assessment • Current and future residents are at risk from contact with contaminated soil. • Workers are at risk from contact with contaminated soil during shallow and intrusive works. • Groundwater contact or ingestion is unlikely owing to deep depths (>20m) and no domestic bores on site. • On site ecological receptors.

DM McMahon Pty Ltd – October 2020 Page 14 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 8.0 Sampling and analysis quality plan and sampling methodology The Data Quality Objectives (DQOs) of the site assessment have been developed to define the type and quality of data to meet the project objectives. The DQOs have been developed generally in accordance with the seven-step process as outlined in AS 4482.1:2005 and the USA EPA: Guidance on Systematic Planning Using the Data Quality Objectives Process (2006a). These DQOs are as follows: 1. The problem 2. The goal of the study 3. Information inputs 4. Study boundaries 5. The analytical approach 6. Performance and acceptance criteria 7. Obtaining data

These objectives have been further outlined in the following sections.

DQO 4 - Study boundaries • Intrusive soil investigations in the near surface soil will be conducted across the site. • Temporal boundaries are limited to the proposed fieldwork timeframes.

DQO 5 - The analytical approach Soil were tested against the following parameters as identified in the Conceptual Site Model (see Section 7.0), summarised in Table 3.

DM McMahon Pty Ltd – October 2020 Page 15 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 Table 3: Sample media and analytes Material Analytes ALS suite code Test method Heavy metals S-2 APHA 3120 Organochlorine & S-12 USEPA 3510/8270 Soil Organophosphate Pesticides (OCP/OPP)

To assess the validity of data for decision making, the data will be assessed against a set of data quality indicators, the following predetermined data quality indicators have been adopted.

Table 4: Tier 1 analysis acceptance criteria Material Analytes Criteria Health Investigation Levels (HILs) -Residential A (NEPM 2013) Heavy metals -Table 1A(1) Heavy metals, OCPs, OPPs OCPs Soil -Soils within 3m of surface OPPs Added Contaminants Limits (ACLs)

-Residential A NEPM (2013) -Table 1B(1) Zinc

DM McMahon Pty Ltd – October 2020 Page 16 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 -Table 1B(2) Copper -Table 1B(3) Nickel -Table 1B(4) Lead -Soils within 2m of surface

McMahon assesses that the sampling pattern is suitable to be used for decision making and site characterisation.

Key features of the sampling pattern include: • Four soil sampling points. • One near surface sample collected from each sample point. • One soil duplicate. • One rinsate sample.

By reference to the DQOs, a map of the sampling pattern can be seen in Attachment E.

The following table presents a summary of the sampling locations and rationale behind their selection, Table 5.

Table 5: Sampling rationale Sample locations Rationale To assess the potential contamination of the natural soil across Points 1 - 4 the agricultural area. Heavy metals and OCPs/OPPS, may be persistent in the soil if pesticide and herbicide application has occurred.

DM McMahon Pty Ltd – October 2020 Page 17 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 Soil sampling method The sampling officers wore unused disposable nitrile gloves to extract samples directly from the test pit and placed into Teflon lined glass sample jars. Collected sample containers were placed into a chilled esky for preservation prior to analysis. All in-field observations and any relevant comments were detailed in the field sheets/bore logs and a Chain of Custody form was produced to accompany samples to the laboratory.

DM McMahon Pty Ltd – October 2020 Page 18 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 9.0 Results Sampling was conducted over one day on Wednesday 21 October 2020. The weather was warm and dry with light winds. A summary of the field observations and sample analytical results are as follows.

Soil The surface and near surface natural soils on site are synonymous with the Quaternary alluvium of the Culcairn soil landscape. The soil profile presented below is a generalised model of the conditions encountered to the investigated depth of 0.3m. 1. 0.0-0.1m OL silt CLAY, brown, low plasticity, soft. Trace fine sand. Moist > PL, TOPSOIL, Culcairn soil landscape. 2. 0.1-0.3m CL sand CLAY, yellow-brown, low plasticity, firm. Moist > PL, Alluvial, Culcairn soil landscape.

General soil observations are: • The was natural material with no chemical staining or odours. • Soil descriptions, sampling depths, and observations can be seen in the field notes, Attachment F.

Analytical results A summary of the soil analytical results are as follows: • Heavy metals are below the adopted criteria. • OCPs & OPPs are below LORs and the adopted criteria.

The tabulated soil results with comparison against the adopted criteria can be seen in Attachment G.

Laboratory certificates and QA/QC reports can be seen in Attachment H.

DM McMahon Pty Ltd – October 2020 Page 19 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 10.0 Quality assurance/quality control data evaluation

Table 6: Sampling Data Quality Indicators

DM McMahon Pty Ltd – October 2020 Page 20 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 Table 7: Analysis Data Quality Indicators

Data quality objectives The following QA/QC samples were taken in accordance with the requirements of NEPM (2013), EPA (1995) & AS 4482.1-2005: • One soil duplicate sample was taken during the sampling (7363/1 & 7636/D). All duplicate parameters returned Relative Percentage Differences (RPD) below 30%, except for arsenic (67%), chromium (56%), lead (48%) and lead (61%). These RPD exceedances are not considered to significantly impact the reliability of the results due to the comparably low exceedance when compared to the adopted criteria and the low parameters concentrations. • One rinsate sample was collected (7363/R) with all parameters below the LOR.

DM McMahon Pty Ltd – October 2020 Page 21 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 11.0 Conclusions and recommendations This investigation met the objective of assessing whether contamination has the potential to exist on the site and whether further investigation is needed.

The results of the investigation returned no historical gross contaminating land use with soil contaminant levels below the adopted human health and environmental criteria for residential land use.

Based on the above, the risk to future residential site users and the environment is low. Accordingly, it is McMahon’s conclusion that the site is suitable for residential land use and that no further assessment is necessary.

DM McMahon Pty Ltd – October 2020 Page 22 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 12.0 Unexpected findings If any unconsolidated, odorous, stained or deleterious soils are encountered during any further excavation, suspected historical contaminating activities are encountered, or conditions that are not alike the above descriptions, the site supervisor should be informed, the work stopped, and this office be contacted immediately for further evaluation by an appropriately qualified environmental consultant. The unexpected findings may trigger the need for more investigation and assessment dependant on the scope and context of the unexpected finding.

DM McMahon Pty Ltd – October 2020 Page 23 of 24 Preliminary Site Investigation: Railway Parade Culcairn NSW 2660 Report 7363 15.0 References AS 1726, (2017). Geotechnical site investigations.

AS 4482.1, (2005). Guide to the investigation and sampling of sites with potentially contaminated soil Part 1: Non-volatile and semi-volatile compounds.

AS 4482.2, (1999). Guide to the sampling and investigation of potentially contaminated soil Part 2: Volatile substances.

BoM, (2020). Climate Data Online.

Doughty, D, (2003). Soil Landscapes of the Holbrook-Tallangatta 1:100,000 Sheets map and report, Department of Sustainable Natural Resources, Sydney.

National Environment Protection (Assessment of Site Contamination) Measure (NEPM), (2013).

NSW Department of Urban Affairs and Planning, (1998). Managing Land Contamination Planning Guidelines SEPP 55–Remediation of Land.

NSW EPA, (1995). Sampling Design Guidelines.

NSW EPA, (2020). Contaminated Land Guidelines, Consultants Reporting on Contaminated Land.

Water NSW, (2020). Water insights. Real-time data.

16.0 Attachments

Attachments Details A. Location map 1 page B. Aerial photographs 16 pages C. Site map 1 page D. Site photographs 2 pages E. Sample location map 1 page F. Field notes 1 page G. Tabulated results 1 page H. Laboratory reports 18 pages I. RPD calculation 1 page

DM McMahon Pty Ltd – October 2020 Page 24 of 24 REPORT 7363

DM McMahon Pty Ltd 6 Jones Street, (PO Box 6118) Wagga Wagga NSW 2650

t (02) 6931 0510 www.dmmcmahon.com.au Attachment A : Location map

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Railway Pde Culcairn NSW Legend Aerial photograph 2019. CU2 boundary Report No. 7363. ➤ ImageImage ©© 20202020 CNESCNES // AirbusAirbus © 2020 Google N Image © 2020 CNES / Airbus ImageImage ©© 20202020 MaxarMaxar TechnologiesTechnologies 1 km © 2020 Google Image © 2020 Maxar Technologies Attachment B : Aerial photographs

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Railway Pde Culcairn NSW Legend Aerial photograph 1959 CU2 boundary

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DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Site photographs Railway Parade Culcairn (CU2) Report No. 7363

Photograph 1: The two trees and farm dam.

Photograph 2: The forage brassica and grass vegetation.

October 2020 Page 1 of 2

Site photographs Railway Parade Culcairn (CU2) Report No. 7363

Photograph 3: The natural soil typical of the paddock surface.

Photograph 4: View of the property facing west from the north eastern corner.

October 2020 Page 2 of 2

Attachment E : Sample location map

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au

Attachment G : alated reslts

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Attachment G - Tabulated Results Zinc HCB DDT Lead Nickel Endrin Copper Arsenic Mercury Cadmium Chlordane Chromium Heptachlor Endosulfan Chlorpyrifos Methoxychlor Aldrin + + Dieldrin Aldrin DDT + DDE +DDT

Unit of Measure mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg mg/kg Limit of Reporting 5 1 2 5 5 2 5 0.1 0.05 0.05 0.1 0.05 0.05 0.2 0.05 0.05 0.05 0.05 HILs A 100 20 - 6000 300 400 7400 40 10 6 50 10 270 300 6 240 160 - ACLs - - 400 190 1100 170 400 ------EILs 100 ------180

Sample Point Sample ID Sample depth Point 1 7363/1 0.1-0.2m 10 <1 23 6 28 9 15 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 <0.2 <0.05 <0.05 <0.05 <0.2 Point 2 7363/2 0.1-0.2m <5 <1 9 5 13 5 11 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 <0.2 <0.05 <0.05 <0.05 <0.2 Point 3 7363/3 0.1-0.2m <5 <1 14 7 13 7 15 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 <0.2 <0.05 <0.05 <0.05 <0.2 Point 4 7363/4 0.1-0.2m <5 <1 12 <5 10 5 8 <0.1 <0.05 <0.05 <0.05 <0.05 <0.05 <0.2 <0.05 <0.05 <0.05 <0.2

HILs A - Table 1A(1) Residential A, NEPM (2013) <3M depth ACLs - Table 1B(1-5) Residential A, NEPM (2013) <2M depth , pH of 6.0, CEC of 10 EILs - Table 1B(5) Residential, NEPM (2013) <2M depth Attachment H : Laorator reports

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au 0 0.00 True

Environmental CERTIFICATE OF ANALYSIS Work Order : ES2037101 Page : 1 of 6 Client : DM MCMAHON PTY LTD Laboratory : Environmental Division Sydney Contact : ADMIN Contact : Grace White Address : 6 JONES ST Address : 277-289 Woodpark Road Smithfield NSW Australia 2164 Wagga Wagga NSW, AUSTRALIA 2650 Telephone : +61 02 6931 0510 Telephone : +61 2 8784 8555 Project : RAILWAY PDE CULCAIM Date Samples Received : 22-Oct-2020 11:40 Order number : 7363 Date Analysis Commenced : 23-Oct-2020 C-O-C number : ---- Issue Date : 28-Oct-2020 18:04 Sampler : DAVID MCMAHON Site : ---- Quote number : EN/222 No. of samples received : 6 No. of samples analysed : 6 This report supersedes any previous report(s) with this reference. Results apply to the sample(s) as submitted. This document shall not be reproduced, except in full. This Certificate of Analysis contains the following information: l General Comments l Analytical Results l Surrogate Control Limits Additional information pertinent to this report will be found in the following separate attachments: Quality Control Report, QA/QC Compliance Assessment to assist with Quality Review and Sample Receipt Notification. Signatories This document has been electronically signed by the authorized signatories below. Electronic signing is carried out in compliance with procedures specified in 21 CFR Part 11. Signatories Position Accreditation Category Edwandy Fadjar Organic Coordinator Sydney Inorganics, Smithfield, NSW Edwandy Fadjar Organic Coordinator Sydney Organics, Smithfield, NSW Ivan Taylor Analyst Sydney Inorganics, Smithfield, NSW

R I G H T S O L U T I O N S | R I G H T P A R T N E R Page : 2 of 6 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM General Comments

Where the LOR of a reported result differs from standard LOR, this may be due to high moisture content, insufficient sample (reduced weight employed) or matrix interference.

Key : CAS Number = CAS registry number from database maintained by Chemical Abstracts Services. The Chemical Abstracts Service is a division of the American Chemical Society. LOR = Limit of reporting ^ = This result is computed from individual analyte detections at or above the level of reporting ø = ALS is not NATA accredited for these tests. ~ = Indicates an estimated value. l EP068: Where reported, Total Chlordane (sum) is the sum of the reported concentrations of cis-Chlordane and trans-Chlordane at or above the LOR. l EP068: Where reported, Total OCP is the sum of the reported concentrations of all Organochlorine Pesticides at or above LOR. Page : 3 of 6 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM Analytical Results

Sub-Matrix: SOIL Client sample ID 7363/1 7363/2 7363/3 7363/4 7363/D (Matrix: SOIL) Client sampling date / time 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 Compound CAS Number LOR Unit ES2037101-001 ES2037101-002 ES2037101-003 ES2037101-004 ES2037101-005 Result Result Result Result Result EA055: Moisture Content (Dried @ 105-110°C) Moisture Content ---- 1.0 % 11.7 13.0 8.4 8.5 10.9 EG005(ED093)T: Total Metals by ICP-AES Arsenic 7440-38-2 5 mg/kg 10 <5 5 <5 <5 Cadmium 7440-43-9 1 mg/kg <1 <1 <1 <1 <1 Chromium 7440-47-3 2 mg/kg 23 9 14 12 13 Copper 7440-50-8 5 mg/kg 6 5 7 <5 6 Lead 7439-92-1 5 mg/kg 28 13 13 10 15 Nickel 7440-02-0 2 mg/kg 9 5 7 5 10 Zinc 7440-66-6 5 mg/kg 15 11 15 8 14 EG035T: Total Recoverable Mercury by FIMS Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 <0.1 <0.1 <0.1 EP068A: Organochlorine Pesticides (OC) alpha-BHC 319-84-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 beta-BHC 319-85-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 gamma-BHC 58-89-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 delta-BHC 319-86-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Heptachlor 76-44-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Aldrin 309-00-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 ^ Total Chlordane (sum) ---- 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Dieldrin 60-57-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Endrin 72-20-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 ^ Endosulfan (sum) 115-29-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 Endrin ketone 53494-70-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Page : 4 of 6 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM Analytical Results

Sub-Matrix: SOIL Client sample ID 7363/1 7363/2 7363/3 7363/4 7363/D (Matrix: SOIL) Client sampling date / time 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 Compound CAS Number LOR Unit ES2037101-001 ES2037101-002 ES2037101-003 ES2037101-004 ES2037101-005 Result Result Result Result Result EP068A: Organochlorine Pesticides (OC) - Continued Methoxychlor 72-43-5 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 ^ Sum of Aldrin + Dieldrin 309-00-2/60-57-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 ^ Sum of DDD + DDE + DDT 72-54-8/72-55-9/5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 0-2 EP068B: Organophosphorus Pesticides (OP) Dichlorvos 62-73-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Monocrotophos 6923-22-4 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 Dimethoate 60-51-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Diazinon 333-41-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Parathion-methyl 298-00-0 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 Malathion 121-75-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Fenthion 55-38-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Parathion 56-38-2 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 <0.2 Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Fenamiphos 22224-92-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Prothiofos 34643-46-4 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Ethion 563-12-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Carbophenothion 786-19-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 <0.05 EP068S: Organochlorine Pesticide Surrogate Dibromo-DDE 21655-73-2 0.05 % 84.9 93.4 96.4 82.8 90.8 EP068T: Organophosphorus Pesticide Surrogate DEF 78-48-8 0.05 % 57.4 68.6 76.7 73.0 87.6 Page : 5 of 6 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM Analytical Results

Sub-Matrix: WATER Client sample ID 7363/R ------(Matrix: WATER) Client sampling date / time 21-Oct-2020 00:00 ------Compound CAS Number LOR Unit ES2037101-006 ------Result ------EG020T: Total Metals by ICP-MS Arsenic 7440-38-2 0.001 mg/L <0.001 ------Cadmium 7440-43-9 0.0001 mg/L <0.0001 ------Chromium 7440-47-3 0.001 mg/L <0.001 ------Copper 7440-50-8 0.001 mg/L <0.001 ------Nickel 7440-02-0 0.001 mg/L <0.001 ------Lead 7439-92-1 0.001 mg/L <0.001 ------Zinc 7440-66-6 0.005 mg/L <0.005 ------EG035T: Total Recoverable Mercury by FIMS Mercury 7439-97-6 0.0001 mg/L <0.0001 ------Page : 6 of 6 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM Surrogate Control Limits

Work Order : ES2037101 Page : 1 of 7

Client : DM MCMAHON PTY LTD Laboratory : Environmental Division Sydney Contact : ADMIN Contact : Grace White Address : 6 JONES ST Address : 277-289 Woodpark Road Smithfield NSW Australia 2164 Wagga Wagga NSW, AUSTRALIA 2650 Telephone : +61 02 6931 0510 Telephone : +61 2 8784 8555 Project : RAILWAY PDE CULCAIM Date Samples Received : 22-Oct-2020 Order number : 7363 Date Analysis Commenced : 23-Oct-2020 C-O-C number : ---- Issue Date : 28-Oct-2020 Sampler : DAVID MCMAHON Site : ---- Quote number : EN/222 No. of samples received : 6 No. of samples analysed : 6 This report supersedes any previous report(s) with this reference. Results apply to the sample(s) as submitted. This document shall not be reproduced, except in full. This Quality Control Report contains the following information: l Laboratory Duplicate (DUP) Report; Relative Percentage Difference (RPD) and Acceptance Limits l Method Blank (MB) and Laboratory Control Spike (LCS) Report; Recovery and Acceptance Limits l Matrix Spike (MS) Report; Recovery and Acceptance Limits Signatories This document has been electronically signed by the authorized signatories below. Electronic signing is carried out in compliance with procedures specified in 21 CFR Part 11. Signatories Position Accreditation Category

Edwandy Fadjar Organic Coordinator Sydney Inorganics, Smithfield, NSW Edwandy Fadjar Organic Coordinator Sydney Organics, Smithfield, NSW Ivan Taylor Analyst Sydney Inorganics, Smithfield, NSW

R I G H T S O L U T I O N S | R I G H T P A R T N E R Page : 2 of 7 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM General Comments The analytical procedures used by ALS have been developed from established internationally recognised procedures such as those published by the USEPA, APHA, AS and NEPM. In house developed procedures are fully validated and are often at the client request. Where moisture determination has been performed, results are reported on a dry weight basis. Where a reported less than (<) result is higher than the LOR, this may be due to primary sample extract/digestate dilution and/or insufficient sample for analysis. Where the LOR of a reported result differs from standard LOR, this may be due to high moisture content, insufficient sample (reduced weight employed) or matrix interference.

Key : Anonymous = Refers to samples which are not specifically part of this work order but formed part of the QC process lot CAS Number = CAS registry number from database maintained by Chemical Abstracts Services. The Chemical Abstracts Service is a division of the American Chemical Society. LOR = Limit of reporting RPD = Relative Percentage Difference # = Indicates failed QC Laboratory Duplicate (DUP) Report The quality control term Laboratory Duplicate refers to a randomly selected intralaboratory split. Laboratory duplicates provide information regarding method precision and sample heterogeneity. The permitted ranges for the Relative Percent Deviation (RPD) of Laboratory Duplicates are specified in ALS Method QWI-EN/38 and are dependent on the magnitude of results in comparison to the level of reporting: Result < 10 times LOR: No Limit; Result between 10 and 20 times LOR: 0% - 50%; Result > 20 times LOR: 0% - 20%. Sub-Matrix: SOIL Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EG005(ED093)T: Total Metals by ICP-AES (QC Lot: 3326117) ES2037099-002 Anonymous EG005T: Arsenic 7440-38-2 5 mg/kg 1140 1110 2.80 0% - 20% ES2037099-002 Anonymous EG005T: Cadmium 7440-43-9 1 mg/kg <1 <1 0.00 No Limit EG005T: Chromium 7440-47-3 2 mg/kg 18 20 10.7 0% - 50% EG005T: Nickel 7440-02-0 2 mg/kg 14 12 8.89 No Limit EG005T: Copper 7440-50-8 5 mg/kg 11 11 0.00 No Limit EG005T: Lead 7439-92-1 5 mg/kg 20 20 0.00 No Limit EG005T: Zinc 7440-66-6 5 mg/kg 47 44 5.85 No Limit ES2037100-008 Anonymous EG005T: Cadmium 7440-43-9 1 mg/kg <1 <1 0.00 No Limit EG005T: Chromium 7440-47-3 2 mg/kg 22 21 4.97 0% - 50% EG005T: Nickel 7440-02-0 2 mg/kg 9 12 30.2 No Limit EG005T: Arsenic 7440-38-2 5 mg/kg 8 8 0.00 No Limit EG005T: Copper 7440-50-8 5 mg/kg 8 10 24.5 No Limit EG005T: Lead 7439-92-1 5 mg/kg 14 15 0.00 No Limit EG005T: Zinc 7440-66-6 5 mg/kg 10 15 38.6 No Limit EA055: Moisture Content (Dried @ 105-110°C) (QC Lot: 3326121) ES2037099-004 Anonymous EA055: Moisture Content ---- 0.1 % 9.6 9.2 4.42 No Limit ES2037101-002 7363/2 EA055: Moisture Content ---- 0.1 % 13.0 12.6 3.39 0% - 50% EG035T: Total Recoverable Mercury by FIMS (QC Lot: 3326118) ES2037099-002 Anonymous EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 0.00 No Limit ES2037100-008 Anonymous EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 0.00 No Limit EP068A: Organochlorine Pesticides (OC) (QC Lot: 3324937) ES2037099-001 Anonymous EP068: alpha-BHC 319-84-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: beta-BHC 319-85-7 0.05 mg/kg <0.05 <0.05 0.00 No Limit Page : 3 of 7 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM

Sub-Matrix: SOIL Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EP068A: Organochlorine Pesticides (OC) (QC Lot: 3324937) - continued ES2037099-001 Anonymous EP068: gamma-BHC 58-89-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: delta-BHC 319-86-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Heptachlor 76-44-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Aldrin 309-00-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Dieldrin 60-57-1 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endrin 72-20-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endrin ketone 53494-70-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068: Methoxychlor 72-43-5 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068B: Organophosphorus Pesticides (OP) (QC Lot: 3324937) ES2037099-001 Anonymous EP068: Dichlorvos 62-73-7 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Dimethoate 60-51-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Diazinon 333-41-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Malathion 121-75-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Fenthion 55-38-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Fenamiphos 22224-92-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Prothiofos 34643-46-4 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Ethion 563-12-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Carbophenothion 786-19-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Monocrotophos 6923-22-4 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068: Parathion-methyl 298-00-0 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068: Parathion 56-38-2 0.2 mg/kg <0.2 <0.2 0.00 No Limit

Sub-Matrix: WATER Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EG020T: Total Metals by ICP-MS (QC Lot: 3326173) ES2037145-004 Anonymous EG020A-T: Cadmium 7440-43-9 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit EG020A-T: Arsenic 7440-38-2 0.001 mg/L 8.69 8.62 0.787 0% - 20% EG020A-T: Chromium 7440-47-3 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Copper 7440-50-8 0.001 mg/L 0.162 0.162 0.00 0% - 20% EG020A-T: Lead 7439-92-1 0.001 mg/L 0.003 0.003 0.00 No Limit EG020A-T: Nickel 7440-02-0 0.001 mg/L 0.014 0.013 0.00 0% - 50% EG020A-T: Zinc 7440-66-6 0.005 mg/L 0.006 <0.005 19.3 No Limit ES2037065-001 Anonymous EG020A-T: Cadmium 7440-43-9 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit EG020A-T: Arsenic 7440-38-2 0.001 mg/L <0.001 0.001 0.00 No Limit EG020A-T: Chromium 7440-47-3 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Copper 7440-50-8 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Lead 7439-92-1 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Nickel 7440-02-0 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Zinc 7440-66-6 0.005 mg/L 0.006 0.005 0.00 No Limit EG035T: Total Recoverable Mercury by FIMS (QC Lot: 3326211) ES2036858-001 Anonymous EG035T: Mercury 7439-97-6 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit ES2037063-002 Anonymous EG035T: Mercury 7439-97-6 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit Page : 5 of 7 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM Method Blank (MB) and Laboratory Control Spike (LCS) Report The quality control term Method / Laboratory Blank refers to an analyte free matrix to which all reagents are added in the same volumes or proportions as used in standard sample preparation. The purpose of this QC parameter is to monitor potential laboratory contamination. The quality control term Laboratory Control Spike (LCS) refers to a certified reference material, or a known interference free matrix spiked with target analytes. The purpose of this QC parameter is to monitor method precision and accuracy independent of sample matrix. Dynamic Recovery Limits are based on statistical evaluation of processed LCS.

Sub-Matrix: SOIL Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EG005(ED093)T: Total Metals by ICP-AES (QCLot: 3326117) EG005T: Arsenic 7440-38-2 5 mg/kg <5 121.1 mg/kg 104 88.0 113 EG005T: Cadmium 7440-43-9 1 mg/kg <1 0.74 mg/kg 108 70.0 130 EG005T: Chromium 7440-47-3 2 mg/kg <2 20.2 mg/kg 92.0 68.0 132 EG005T: Copper 7440-50-8 5 mg/kg <5 52.9 mg/kg 109 89.0 111 EG005T: Lead 7439-92-1 5 mg/kg <5 62.1 mg/kg 96.3 82.0 119 EG005T: Nickel 7440-02-0 2 mg/kg <2 15.4 mg/kg 95.3 80.0 120 EG005T: Zinc 7440-66-6 5 mg/kg <5 162 mg/kg 81.8 66.0 133 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326118) EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 0.0847 mg/kg 73.4 70.0 105 EP068A: Organochlorine Pesticides (OC) (QCLot: 3324937) EP068: alpha-BHC 319-84-6 0.05 mg/kg <0.05 0.5 mg/kg 104 69.0 113 EP068: Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 0.5 mg/kg 106 65.0 117 EP068: beta-BHC 319-85-7 0.05 mg/kg <0.05 0.5 mg/kg 92.0 67.0 119 EP068: gamma-BHC 58-89-9 0.05 mg/kg <0.05 0.5 mg/kg 92.8 68.0 116 EP068: delta-BHC 319-86-8 0.05 mg/kg <0.05 0.5 mg/kg 92.0 65.0 117 EP068: Heptachlor 76-44-8 0.05 mg/kg <0.05 0.5 mg/kg 106 67.0 115 EP068: Aldrin 309-00-2 0.05 mg/kg <0.05 0.5 mg/kg 105 69.0 115 EP068: Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 0.5 mg/kg 103 62.0 118 EP068: trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 0.5 mg/kg 105 63.0 117 EP068: alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 0.5 mg/kg 94.9 66.0 116 EP068: cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 0.5 mg/kg 91.8 64.0 116 EP068: Dieldrin 60-57-1 0.05 mg/kg <0.05 0.5 mg/kg 95.5 66.0 116 EP068: 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 0.5 mg/kg 96.5 67.0 115 EP068: Endrin 72-20-8 0.05 mg/kg <0.05 0.5 mg/kg 108 67.0 123 EP068: beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 0.5 mg/kg 104 69.0 115 EP068: 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 0.5 mg/kg 100 69.0 121 EP068: Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 0.5 mg/kg 90.8 56.0 120 EP068: Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 0.5 mg/kg 87.9 62.0 124 EP068: 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 0.5 mg/kg 91.8 66.0 120 EP068: Endrin ketone 53494-70-5 0.05 mg/kg <0.05 0.5 mg/kg 94.1 64.0 122 EP068: Methoxychlor 72-43-5 0.2 mg/kg <0.2 0.5 mg/kg 91.2 54.0 130 EP068B: Organophosphorus Pesticides (OP) (QCLot: 3324937) EP068: Dichlorvos 62-73-7 0.05 mg/kg <0.05 0.5 mg/kg 76.8 59.0 119 EP068: Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 0.5 mg/kg 98.8 62.0 128 Page : 6 of 7 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM

Sub-Matrix: SOIL Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EP068B: Organophosphorus Pesticides (OP) (QCLot: 3324937) - continued EP068: Monocrotophos 6923-22-4 0.2 mg/kg <0.2 0.5 mg/kg 80.3 54.0 126 EP068: Dimethoate 60-51-5 0.05 mg/kg <0.05 0.5 mg/kg 100 67.0 119 EP068: Diazinon 333-41-5 0.05 mg/kg <0.05 0.5 mg/kg 94.9 70.0 120 EP068: Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 0.5 mg/kg 103 72.0 120 EP068: Parathion-methyl 298-00-0 0.2 mg/kg <0.2 0.5 mg/kg 108 68.0 120 EP068: Malathion 121-75-5 0.05 mg/kg <0.05 0.5 mg/kg 92.4 68.0 122 EP068: Fenthion 55-38-9 0.05 mg/kg <0.05 0.5 mg/kg 106 69.0 117 EP068: Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 0.5 mg/kg 108 76.0 118 EP068: Parathion 56-38-2 0.2 mg/kg <0.2 0.5 mg/kg 101 64.0 122 EP068: Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 0.5 mg/kg 97.5 70.0 116 EP068: Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 0.5 mg/kg 104 69.0 121 EP068: Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 0.5 mg/kg 106 66.0 118 EP068: Fenamiphos 22224-92-6 0.05 mg/kg <0.05 0.5 mg/kg 95.5 68.0 124 EP068: Prothiofos 34643-46-4 0.05 mg/kg <0.05 0.5 mg/kg 94.4 62.0 112 EP068: Ethion 563-12-2 0.05 mg/kg <0.05 0.5 mg/kg 104 68.0 120 EP068: Carbophenothion 786-19-6 0.05 mg/kg <0.05 0.5 mg/kg 94.8 65.0 127 EP068: Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 0.5 mg/kg 66.2 41.0 123

Sub-Matrix: WATER Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EG020T: Total Metals by ICP-MS (QCLot: 3326173) EG020A-T: Arsenic 7440-38-2 0.001 mg/L <0.001 0.1 mg/L 91.1 82.0 114 EG020A-T: Cadmium 7440-43-9 0.0001 mg/L <0.0001 0.1 mg/L 92.8 84.0 112 EG020A-T: Chromium 7440-47-3 0.001 mg/L <0.001 0.1 mg/L 93.6 86.0 116 EG020A-T: Copper 7440-50-8 0.001 mg/L <0.001 0.1 mg/L 88.9 83.0 118 EG020A-T: Lead 7439-92-1 0.001 mg/L <0.001 0.1 mg/L 89.7 85.0 115 EG020A-T: Nickel 7440-02-0 0.001 mg/L <0.001 0.1 mg/L 86.6 84.0 116 EG020A-T: Zinc 7440-66-6 0.005 mg/L <0.005 0.1 mg/L 90.9 79.0 117 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326211) EG035T: Mercury 7439-97-6 0.0001 mg/L <0.0001 0.01 mg/L 95.6 77.0 111

Laboratory sample ID Client sample ID Method: Compound CAS Number Concentration MS Low High Page : 7 of 7 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM

Sub-Matrix: SOIL Matrix Spike (MS) Report Spike SpikeRecovery(%) Recovery Limits (%)

Laboratory sample ID Client sample ID Method: Compound CAS Number Concentration MS Low High EG005(ED093)T: Total Metals by ICP-AES (QCLot: 3326117) ES2037099-002 Anonymous EG005T: Arsenic 7440-38-2 50 mg/kg # Not 70.0 130 Determined EG005T: Cadmium 7440-43-9 50 mg/kg 97.6 70.0 130 EG005T: Chromium 7440-47-3 50 mg/kg 89.1 68.0 132 EG005T: Copper 7440-50-8 250 mg/kg 96.6 70.0 130 EG005T: Lead 7439-92-1 250 mg/kg 97.8 70.0 130 EG005T: Nickel 7440-02-0 50 mg/kg 94.6 70.0 130 EG005T: Zinc 7440-66-6 250 mg/kg 97.1 66.0 133 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326118) ES2037099-002 Anonymous EG035T: Mercury 7439-97-6 5 mg/kg 86.6 70.0 130 EP068A: Organochlorine Pesticides (OC) (QCLot: 3324937) ES2037099-001 Anonymous EP068: gamma-BHC 58-89-9 0.5 mg/kg 116 70.0 130 EP068: Heptachlor 76-44-8 0.5 mg/kg 76.2 70.0 130 EP068: Aldrin 309-00-2 0.5 mg/kg 78.0 70.0 130 EP068: Dieldrin 60-57-1 0.5 mg/kg 84.9 70.0 130 EP068: Endrin 72-20-8 2 mg/kg 96.1 70.0 130 EP068: 4.4`-DDT 50-29-3 2 mg/kg 96.4 70.0 130 EP068B: Organophosphorus Pesticides (OP) (QCLot: 3324937) ES2037099-001 Anonymous EP068: Diazinon 333-41-5 0.5 mg/kg 85.8 70.0 130 EP068: Chlorpyrifos-methyl 5598-13-0 0.5 mg/kg 85.1 70.0 130 EP068: Pirimphos-ethyl 23505-41-1 0.5 mg/kg 83.6 70.0 130 EP068: Bromophos-ethyl 4824-78-6 0.5 mg/kg 82.1 70.0 130 EP068: Prothiofos 34643-46-4 0.5 mg/kg 83.9 70.0 130

Sub-Matrix: WATER Matrix Spike (MS) Report Spike SpikeRecovery(%) Recovery Limits (%)

Laboratory sample ID Client sample ID Method: Compound CAS Number Concentration MS Low High EG020T: Total Metals by ICP-MS (QCLot: 3326173) ES2037066-001 Anonymous EG020A-T: Arsenic 7440-38-2 1 mg/L 85.4 70.0 130 EG020A-T: Cadmium 7440-43-9 0.25 mg/L 89.0 70.0 130 EG020A-T: Chromium 7440-47-3 1 mg/L 89.4 70.0 130 EG020A-T: Copper 7440-50-8 1 mg/L 81.0 70.0 130 EG020A-T: Lead 7439-92-1 1 mg/L 82.5 70.0 130 EG020A-T: Nickel 7440-02-0 1 mg/L 83.2 70.0 130 EG020A-T: Zinc 7440-66-6 1 mg/L 83.7 70.0 130 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326211) ES2037065-001 Anonymous EG035T: Mercury 7439-97-6 0.01 mg/L 86.4 70.0 130 True

Environmental QA/QC Compliance Assessment to assist with Quality Review

Work Order : ES2037101 Page : 1 of 5

Client : DM MCMAHON PTY LTD Laboratory : Environmental Division Sydney Contact : ADMIN Telephone : +61 2 8784 8555 Project : RAILWAY PDE CULCAIM Date Samples Received : 22-Oct-2020 Site : ---- Issue Date : 28-Oct-2020 Sampler : DAVID MCMAHON No. of samples received : 6 Order number : 7363 No. of samples analysed : 6

Brief method summaries and references are also provided to assist in traceability.

Summary of Outliers Outliers : Quality Control Samples

Outliers : Analysis Holding Time Compliance l NO Analysis Holding Time Outliers exist.

Outliers : Frequency of Quality Control Samples l NO Quality Control Sample Frequency Outliers exist.

R I G H T S O L U T I O N S | R I G H T P A R T N E R Page : 2 of 5 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM Outliers : Quality Control Samples Duplicates, Method Blanks, Laboratory Control Samples and Matrix Spikes

EA055: Moisture Content (Dried @ 105-110°C) Soil Glass Jar - Unpreserved (EA055) 7363/1, 7363/2, 21-Oct-2020 ------23-Oct-2020 04-Nov-2020 ü 7363/3, 7363/4, 7363/D EG005(ED093)T: Total Metals by ICP-AES Soil Glass Jar - Unpreserved (EG005T) 7363/1, 7363/2, 21-Oct-2020 23-Oct-2020 19-Apr-2021 ü 26-Oct-2020 19-Apr-2021 ü 7363/3, 7363/4, 7363/D EG035T: Total Recoverable Mercury by FIMS Soil Glass Jar - Unpreserved (EG035T) 7363/1, 7363/2, 21-Oct-2020 23-Oct-2020 18-Nov-2020 ü 27-Oct-2020 18-Nov-2020 ü 7363/3, 7363/4, 7363/D EP068A: Organochlorine Pesticides (OC) Soil Glass Jar - Unpreserved (EP068) 7363/1, 7363/2, 21-Oct-2020 26-Oct-2020 04-Nov-2020 ü 27-Oct-2020 05-Dec-2020 ü 7363/3, 7363/4, 7363/D Page : 3 of 5 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM

EP068B: Organophosphorus Pesticides (OP) Soil Glass Jar - Unpreserved (EP068) 7363/1, 7363/2, 21-Oct-2020 26-Oct-2020 04-Nov-2020 ü 27-Oct-2020 05-Dec-2020 ü 7363/3, 7363/4, 7363/D

EG020T: Total Metals by ICP-MS Clear Plastic Bottle - Nitric Acid; Unfiltered (EG020A-T) 7363/R 21-Oct-2020 23-Oct-2020 19-Apr-2021 ü 23-Oct-2020 19-Apr-2021 ü EG035T: Total Recoverable Mercury by FIMS Clear Plastic Bottle - Nitric Acid; Unfiltered (EG035T) 7363/R 21-Oct-2020 ------27-Oct-2020 18-Nov-2020 ü Page : 4 of 5 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM

Matrix: SOIL Evaluation: û = Quality Control frequency not within specification ; ü = Quality Control frequency within specification. Quality Control Sample Type Count Rate (%) Quality Control Specification Analytical Methods Method QC Regular Actual Expected Evaluation Laboratory Duplicates (DUP) Moisture Content EA055 2 20 10.00 10.00 ü NEPM 2013 B3 & ALS QC Standard Pesticides by GCMS EP068 1 9 11.11 10.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 2 18 11.11 10.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 3 20 15.00 10.00 ü NEPM 2013 B3 & ALS QC Standard Laboratory Control Samples (LCS) Pesticides by GCMS EP068 1 9 11.11 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 1 18 5.56 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 1 20 5.00 5.00 ü NEPM 2013 B3 & ALS QC Standard Method Blanks (MB) Pesticides by GCMS EP068 1 9 11.11 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 1 18 5.56 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 1 20 5.00 5.00 ü NEPM 2013 B3 & ALS QC Standard Matrix Spikes (MS) Pesticides by GCMS EP068 1 9 11.11 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 1 18 5.56 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 1 20 5.00 5.00 ü NEPM 2013 B3 & ALS QC Standard Matrix: WATER Evaluation: û = Quality Control frequency not within specification ; ü = Quality Control frequency within specification. Quality Control Sample Type Count Rate (%) Quality Control Specification Analytical Methods Method QC Regular Actual Expected Evaluation Laboratory Duplicates (DUP) Total Mercury by FIMS EG035T 2 16 12.50 10.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 2 15 13.33 10.00 ü NEPM 2013 B3 & ALS QC Standard Laboratory Control Samples (LCS) Total Mercury by FIMS EG035T 1 16 6.25 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 1 15 6.67 5.00 ü NEPM 2013 B3 & ALS QC Standard Method Blanks (MB) Total Mercury by FIMS EG035T 1 16 6.25 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 1 15 6.67 5.00 ü NEPM 2013 B3 & ALS QC Standard Matrix Spikes (MS) Total Mercury by FIMS EG035T 1 16 6.25 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 1 15 6.67 5.00 ü NEPM 2013 B3 & ALS QC Standard Page : 5 of 5 Work Order : ES2037101 Client : DM MCMAHON PTY LTD Project : RAILWAY PDE CULCAIM Brief Method Summaries The analytical procedures used by the Environmental Division have been developed from established internationally recognized procedures such as those published by the US EPA, APHA, AS and NEPM. In house developed procedures are employed in the absence of documented standards or by client request. The following report provides brief descriptions of the analytical procedures employed for results reported in the Certificate of Analysis. Sources from which ALS methods have been developed are provided within the Method Descriptions. Analytical Methods Method Matrix Method Descriptions Moisture Content EA055 SOIL In house: A gravimetric procedure based on weight loss over a 12 hour drying period at 105-110 degrees C. This method is compliant with NEPM Schedule B(3). Total Metals by ICP-AES EG005T SOIL In house: Referenced to APHA 3120; USEPA SW 846 - 6010. Metals are determined following an appropriate acid digestion of the soil. The ICPAES technique ionises samples in a plasma, emitting a characteristic spectrum based on metals present. Intensities at selected wavelengths are compared against those of matrix matched standards. This method is compliant with NEPM Schedule B(3) Total Mercury by FIMS EG035T SOIL In house: Referenced to AS 3550, APHA 3112 Hg - B (Flow-injection (SnCl2) (Cold Vapour generation) AAS) FIM-AAS is an automated flameless atomic absorption technique. Mercury in solids are determined following an appropriate acid digestion. Ionic mercury is reduced online to atomic mercury vapour by SnCl2 which is then purged into a heated quartz cell. Quantification is by comparing absorbance against a calibration curve. This method is compliant with NEPM Schedule B(3) Pesticides by GCMS EP068 SOIL In house: Referenced to USEPA SW 846 - 8270 Extracts are analysed by Capillary GC/MS and quantification is by comparison against an established 5 point calibration curve. This technique is compliant with NEPM Schedule B(3). Total Metals by ICP-MS - Suite A EG020A-T WATER In house: Referenced to APHA 3125; USEPA SW846 - 6020, ALS QWI-EN/EG020. The ICPMS technique utilizes a highly efficient argon plasma to ionize selected elements. Ions are then passed into a high vacuum mass spectrometer, which separates the analytes based on their distinct mass to charge ratios prior to their measurement by a discrete dynode ion detector. Total Mercury by FIMS EG035T WATER In house: Referenced to AS 3550, APHA 3112 Hg - B (Flow-injection (SnCl2)(Cold Vapour generation) AAS) FIM-AAS is an automated flameless atomic absorption technique. A bromate/bromide reagent is used to oxidise any organic mercury compounds in the unfiltered sample. The ionic mercury is reduced online to atomic mercury vapour by SnCl2 which is then purged into a heated quartz cell. Quantification is by comparing absorbance against a calibration curve. This method is compliant with NEPM Schedule B(3).

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Duplicate Sample Sample Sample ID RPD Calculation (%) 7363/D 7363/1 Sample Point 1 Point Point 0.1-0.2m 0.1-0.2m Sample depth 67 10 <5 Arsenic <1 <1 0 Cadmium 13 23 56 Chromium Parameter 0 6 6 Copper 10 11 9 Nickel

61 15 28 Lead 14 15 7 Zinc <0.1 <0.1 0 Mercury

WALBUNDRIE ROAD CULCAIRN NSW

PRELIMINARY SITE INVESTIGATION

OCTOBER 2020

REFERENCE: 7364

DM McMahon Pty Ltd 6 Jones St (PO Box 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 www.dmmcmahon.com.au

Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 Report type Preliminary Site Investigation

Site address Walbundrie Road Culcairn NSW 2660

Report number 7364

Prepared for Colin Kane Director Environment & Planning Greater Hume Council 39 Young St (PO Box 99) Holbrook NSW 2644 Tel: 0260 448 928 Email: [email protected]

Prepared by DM McMahon Pty Ltd 6 Jones Street (PO Box 6118) Wagga Wagga NSW 2650 Tel: 0269 310 510 Email: [email protected]

Document control

Role Name Signed Date Revision Author Zach Bradley 30/10/2020 0 BEnvSc MALGA MEIANZ Certifier David McMahon CEnvP SC 30/10/2020 0 BAppSc SA GradDip WRM MEnvMgmt MALGA MEIANZ MSSA

DM McMahon Pty Ltd – October 2020 Page 2 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 Contents 1.0 Executive summary ...... 4 2.0 Objectives ...... 5 3.0 Scope of work ...... 6 4.0 Site identification ...... 7 5.0 Site history ...... 8 6.0 Site condition and surrounding environment ...... 10 7.0 Conceptual site model ...... 13 8.0 Sampling and analysis quality plan and sampling methodology ...... 15 9.0 Results ...... 19 10.0 Quality assurance/quality control data evaluation ...... 20 11.0 Conclusions and recommendations...... 22 12.0 Unexpected findings ...... 23 13.0 Limitations and disclaimer ...... 23 14.0 Notice of copyright ...... 23 15.0 References ...... 24 16.0 Attachments ...... 24

List of Tables Table 1: Site identification ...... 7 Table 2: Ownership ...... 8 Table 3: Sample media and analytes ...... 16 Table 4: Tier 1 analysis acceptance criteria ...... 16 Table 5: Sampling rationale ...... 18 Table 6: Sampling Data Quality Indicators ...... 20 Table 7: Analysis Data Quality Indicators ...... 21

DM McMahon Pty Ltd – October 2020 Page 3 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 1.0 Executive summary DM McMahon Pty Ltd (McMahon) conducted a Preliminary Site Investigation (PSI) at Walbundrie Road Culcairn NSW (the site). The 10ha (approx.) site identified by Council as CU3 is vacant land having a history of broad acre agriculture. The site is subject to a planning proposal for rezoning from RU1 primary production to RU5 village and reduction of the minimum lot size from 100ha to 600m2. Surrounding land uses are predominantly agricultural with some residential and commercial land. A map of the site location can be seen in Attachment A.

The objective of this investigation is to assess whether contamination has the potential to exist on the site and whether further investigation is needed.

Findings of the investigation include: • The site has history of agricultural land use as far as records can ascertain. • Areas of potential environmental concern include: o Pesticide and herbicide use on agricultural land. o Pesticide use in the previous ram yard in the southern end of the site. o Pesticide use and run off from the sheep spray dip located on adjacent land to the north of the site. • The chemicals of potential concern within the above areas are heavy metals and organochlorine and organophosphate residues which may still remain in the soil. • Sampling of the areas of potential environmental concern returned results below the adopted criteria for residential land use, except for one sample with a criteria exceedance for arsenic on the northern boundary located around 5m from the sheep spray dip on the adjacent land.

In summary McMahon assesses there is no gross contamination across the site, but further investigation is required around the land on the northern boundary where run off from the sheep spray dip is likely to have occurred as indicated by the high arsenic in soil result.

This executive summary and the findings of this PSI is subject to limitations as stated in Section 13.

DM McMahon Pty Ltd – October 2020 Page 4 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 2.0 Objectives The objective of this investigation is to: • Provide information regarding potential contamination on site. • Provide a factual record of the works completed and results. • Undertake a risk assessment for health risk to future site users and the environment. • Provide a statement of recommendations for further investigation, remediation, and/or ongoing site management or alternatively, suitability of the site for the proposed land use. • To prepare the PSI in general accordance with the relevant guidelines and legislation, namely: o NSW EPA Contaminated land guidelines for Consultants reporting on contaminated sites (2020). o State Environmental Planning Policy 55 – Remediation of Land (SEPP 55). o National Environment Protection (Assessment of Site Contamination) Measure (NEPM), (2013).

DM McMahon Pty Ltd – October 2020 Page 5 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 3.0 Scope of work The scope of work includes the following: • Review the available information regarding historical, current, and proposed land use of the site and surrounds. • Review the environmental setting of the site and surrounds. • Assess the potential contamination sources and Chemicals of Potential Concerns (CoPCs). • Assess the potential contamination source-pathway-receptor linkages from the CoPCs, environmental setting and land use. • Formulate a Sampling, Analysis & Quality Plan (SAQP) to investigate the potential contamination. • Conduct limited soil sampling across the site for the CoPCs to assess the requirement for further investigation. • Collect soil samples for laboratory analysis of the CoPCs. • Compare the laboratory results against the adopted criteria. • Evaluate Quality Assurance/Quality Control (QA/QC) data to assess the sampling and analysis procedure. • Refine a Conceptual Site Model (CSM) to assess potential contamination risk from the source-pathway-receptor linkages. • Provide a clear statement on site suitability for the proposed land use or the need for further investigation, remediation, and/or ongoing site management.

DM McMahon Pty Ltd – October 2020 Page 6 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 4.0 Site identification The site identification can be seen as follows, Table 1.

Table 1: Site identification Identifier Details Walbundrie Road (CU3) Property identification/address Culcairn NSW 2660 Lot 1 DP 311778 Real property description Part Lot 3 DP1105775 Centre co-ordinate 502820E 6053260N MGA GDA z55 Property size 10ha (approx.) Owner(s) Andrew Godde Local Government Area Greater Hume Council Present use Agricultural/residential Present zoning RU1 Primary Production Proposed zoning RU5 Village

DM McMahon Pty Ltd – October 2020 Page 7 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 5.0 Site history From research of land titles, Council records, EPA records, aerial photography, and information provided by the owner, the following site history is offered:

Ownership Council records and the land titles database were investigated for land use, ownership history, previous owner occupations and other notes of interest, Table 2.

Table 2: Ownership Year Owner/occupier Occupation/land-use Reference owned/occupied James Balfour - 1873 Tile search

Jack Thomas Hynes Farmer 1948 Tile search

Leo and Hazel Pumpa Farmer 1965 Tile search

Andrew Godde Farmer 2005 Tile search

Council records No Council records for development applications and building approvals were available at the time of reporting. The site is not on the Council contaminated land register.

Aerial photos McMahon observed the following from a review of the available aerial photography. 1959 – The site is broadacre agricultural land with scattered trees. A short (100m) north west trending tree line in visible in the south western corner. Agricultural land use surrounding. 1966 – No change. 1972 – No change. 1980 – The short tree line in the south west corner has been removed. 1990 – No change. 1991 – No change. 1996 – No change. 1998 – No change. 2007 – A tree line has been planted on the boundary between the two Lots in the southern end of the site. 2010 – No change. 2013 – No change.

DM McMahon Pty Ltd – October 2020 Page 8 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 2014 – No change. 2015 – The tree line on the boundary between the two lots has been removed. 2016 – No change. 2017 – No change. 2018 – No change. 2019 – No change.

The aerial photographs can be seen in Attachment B.

Interviews McMahon conducted an interview with Andrew Goode (current owner) and the following was forthcoming: • Andrew purchased in 2005 from Leo Pumpa. • Leo Pumpa owned the site for a long time before Andrew bought the site. • Leo Pumpa used the small paddock in the southern end of the site (Lot 1 DP 311778) visible in the 1980 aerial photograph as a ram yard. • About 50 or so years ago the small paddock in the southern end of the site (Lot 1 DP 311778) was a sheep yard.

McMahon assesses that the information supplied by Andrew Goode is reliable based on comparable findings from the site inspection, research, and multiple lines of evidence.

DM McMahon Pty Ltd – October 2020 Page 9 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 6.0 Site condition and surrounding environment McMahon notes the following observations of the site condition as part of this PSI:

Layout • The site consists of one paddock that is fenced along the western and southern boundary.

Buildings • None.

Septic systems • None.

Site surface • The surface is natural soil. • The site is planted to canola. • There was no surface chemical or hydrocarbons staining.

Other • There is a windmill, groundwater bore, and water trough located in the north western corner of the site. • There is a low-lying area in the northern portion of the site with some surface ponding observed. • Scattered yellow box and Kurrajong trees across the site. • The western and southern boundary are fenced with wire. • There is no visible evidence of any yards or infrastructure in the southern end of the site (Lot 1 DP 311778)

Surrounds • The site fronts Walbundrie Road. • The site is bound by the Walbundrie Road to the south and a road reserve to the north. • Residential land lies to the east. • Broad acre agricultural land lies to the wider north, south and west. • A shearing shed, sheep yards, a sheep spray dip, and silos lay to the north of the site on adjacent farm land. • A groundwater bore and concrete water tank lies on adjacent farm land to the north west of the site.

A map of the site features can be seen in Attachment C.

Site photographs can be seen in Attachment D.

DM McMahon Pty Ltd – October 2020 Page 10 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 A summary of the site environmental setting is as follows.

Vegetation Vegetation is a canola crop in healthy condition.

Hydrology The nearest named waterway is the Billabong Creek located around 400m to the south of the site. An unnamed drainage (a tributary of the Billabong Creek) lies around 300m to the north of the site with a very widely spaced stream channel occurrence. Flow direction is generally to the west with a convergent, integrated, and tributary channel patterns. Due to the relative incline of the site, rainfall will both infiltrate into the soil and run off the surface.

DM McMahon Pty Ltd – October 2020 Page 11 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 Hydrogeology The site lies within the Lower Billabong Hydrogeological Landscape (HGL). As described by Muller et. al. (2015), aquifers within the Lower Billabong HGL are unconfined to semi-confined, with groundwater flow occurring primarily through unconsolidated alluvial sediments. Hydraulic conductivity is high, and transmissivity is moderate to high. Groundwater recharge rates are estimated to be high.

Medium to long residence times are typical. These landscapes have a slow to medium response time to changes in land management.

From a search of the Water NSW database there are no registered groundwater bores located on site. There are four registered groundwater bores located within 500m of the site for general use, stock/domestic and public/municipal use. From the available information these bores are 27m to 65m deep and are constructed into the underlying alluvium and rock. From this McMahon assess that a groundwater resource on site is likely to be deep and in the underlying alluvium and rock (20m+).

There is one groundwater bore located on site, but the depth and construction of the bore is unknown.

DM McMahon Pty Ltd – October 2020 Page 12 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 7.0 Conceptual site model A Conceptual Site Model (CSM) is a representation of site-related information regarding contamination sources, receptors and exposure pathways between those sources and receptors and is presented and follows.

Herbicide and pesticide application to cropping land are diffuse in nature with small quantities applied and periodic use. Based on the above and the moderate persistence of the chemicals used in herbicides and pesticides, the potential for contamination from these is assessed as low.

Concentrated pesticide application to sheep such as by mobile jetting and the like is possible in the ram yard in the southern end of the site. Based on the periodic application of these products, no evidence of these activities from the site research and inspection, and the moderate persistence of the chemicals used in pesticides, the potential for contamination from these is assessed as low.

Sheep spray dips are periodically used and use small quantities of pesticides in a concentrated area. Based on the above and the moderate persistence of the chemicals used in pesticides, the potential for contamination from these is assessed as low distal to the sheep spray dip and medium to high proximal to it.

No available information on historical herbicides which are typically more persistent and toxic herbicides than modern herbicides. The organic component of these historical herbicides may have attenuated, however heavy metal residues may still remain.

List of contaminants of potential concern • Heavy metals- Arsenic (As), Cadmium (Cd), Chromium (Cr), Copper (Cu), Nickel (Ni), Lead (Pb), Zinc (Zn), Mercury (Hg). • Organochlorines (OCPs). • Organophosphates (OPPs).

Potential and known sources of contamination • Pesticide and herbicide use on agricultural land. • Pesticide use in the previous ram yard in the southern end of the site. • Sheep spray dip on adjacent land north of the site.

Mechanism of contamination The mechanism of contamination from the primary source is predominantly top down vertical migration into soil. There is the potential for contaminated water from the sheep spray dip to migrate onto the site through surface water run-off.

Potentially affected environmental media • Surface and near surface soil. • Groundwater through soil media from surface spills but unlikely owing to deep depths (>30m).

DM McMahon Pty Ltd – October 2020 Page 13 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 Actual or potential exposure pathways • Direct skin contact with soil. • Inhalation and/or ingestion of soil, vapour, and dust. • Direct groundwater contact but groundwater is deep (>20m) and unlikely to be contacted. • Groundwater ingestion but no known domestic groundwater bores currently exist on site.

Human and ecological receptors • Current and future on-site residents. • Future on-sites workers. • Domestic groundwater users but no domestic groundwater bores currently exist on site. • Down gradient ecological receptors such as the Billabong Creek. • Current and future landscaping and ecological receptors.

Source pathway receptor linkage assessment • Current and future residents are at risk from contact with contaminated soil. • Workers are at risk from contact with contaminated soil during shallow and intrusive works. • Groundwater contact or ingestion is unlikely owing to deep depths (>20m) and no know domestic bores on site. • On site ecological receptors.

DM McMahon Pty Ltd – October 2020 Page 14 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 8.0 Sampling and analysis quality plan and sampling methodology The Data Quality Objectives (DQOs) of the site assessment have been developed to define the type and quality of data to meet the project objectives. The DQOs have been developed generally in accordance with the seven-step process as outlined in AS 4482.1:2005 and the USA EPA: Guidance on Systematic Planning Using the Data Quality Objectives Process (2006a). These DQOs are as follows: 1. The problem 2. The goal of the study 3. Information inputs 4. Study boundaries 5. The analytical approach 6. Performance and acceptance criteria 7. Obtaining data

These objectives have been further outlined in the following sections.

DQO 1 - The problem There are potential sources of contamination from historical land uses which may pose risk to current and future users of the site. Insufficient data relating to these sources is currently available to determine residential land use suitability with the necessary level of confidence.

DQO 4 - Study boundaries • Intrusive soil investigations in the near surface soil will be conducted across the site. • Temporal boundaries are limited to the proposed fieldwork timeframes.

DQO 5 - The analytical approach Soil were tested against the following parameters as identified in the Conceptual Site Model (see Section 7.0), summarised in Table 3.

DM McMahon Pty Ltd – October 2020 Page 15 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 Table 3: Sample media and analytes Material Analytes ALS suite code Test method Heavy metals S-2 APHA 3120 Organochlorine & S-12 USEPA 3510/8270 Soil Organophosphate Pesticides (OCP/OPP)

To assess the validity of data for decision making, the data will be assessed against a set of data quality indicators, the following predetermined data quality indicators have been adopted.

-Residential A NEPM (2013) -Table 1B(1) Zinc

DM McMahon Pty Ltd – October 2020 Page 16 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 -Table 1B(2) Copper -Table 1B(3) Nickel -Table 1B(4) Lead -Soils within 2m of surface

-pH of 6.0 (CaCl2) assumed from Doughty (2003) -CEC of 10 assumed from Doughty (2003) Environmental Investigation Levels (EILs) -Residential A NEPM (2013) -Table 1B(5) Arsenic and DDT -Soils within 2m of surface

McMahon assesses that the sampling pattern is suitable to be used for decision making and site characterisation.

Key features of the sampling pattern include: • Three soil sampling points. • One near surface sample collected from each sample point. • One soil duplicate. • One rinsate sample.

By reference to the DQOs, a map of the sampling pattern can be seen in Attachment E.

The following table presents a summary of the sampling locations and rationale behind their selection, Table 5.

DM McMahon Pty Ltd – October 2020 Page 17 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 Table 5: Sampling rationale Sample locations Rationale Point 1 To assess the potential contamination of the natural soil across the agricultural area. Heavy metals and OCPs/OPPS, may be persistent in the soil if pesticide and herbicide application has occurred. This area was also used as a ram yard so pesticide application to sheep is possible. Point 2 To assess the potential contamination of the natural soil across the agricultural area. Heavy metals and OCPs/OPPS, may be persistent in the soil if pesticide and herbicide application has occurred. The sheep spray dip is adjacent to this sample point (around 5m away), so pesticide run off is possible. Point 3 To assess the potential contamination of the natural soil across the agricultural area. Heavy metals and OCPs/OPPS, may be persistent in the soil if pesticide and herbicide application has occurred. The sheep spray dip is near to this sample point (around 20m away), so pesticide run off is possible.

Soil sampling method The sampling officers wore unused disposable nitrile gloves to extract samples directly from test pits and placed into Teflon lined glass sample jars. Collected sample containers were placed into a chilled esky for preservation prior to analysis. All in-field observations and any relevant comments were detailed in the field sheets/bore logs and a Chain of Custody form was produced to accompany the samples to the laboratory.

DM McMahon Pty Ltd – October 2020 Page 18 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 9.0 Results Sampling was conducted over one day on Wednesday 21 October 2020. The weather was warm and dry with light winds. A summary of the field observations and sample analytical results are as follows.

Soil The surface and near surface natural soils on site are synonymous with the Quaternary alluvium of the Culcairn soil landscape. The soil profile presented below is a generalised model of the conditions encountered to the investigated depth of 0.3m. 1. 0.0-0.1m OL silt CLAY, brown, low plasticity, soft. Trace fine sand. Moist > PL, TOPSOIL, Culcairn soil landscape. 2. 0.1-0.3m CL sand CLAY, yellow-brown, low plasticity, firm. Moist > PL, Alluvial, Culcairn soil landscape.

Analytical results A summary of the soil analytical results are as follows: • Heavy metals are below the laboratory Limit of Reporting (LOR) and/or the adopted criteria, except for arsenic at sample point 2 with an above criteria result of 1,140mg/kg. • OCPs & OPPs are below LORs and the adopted criteria.

The tabulated soil results with comparison against the adopted criteria can be seen in Attachment G.

Laboratory certificates and QA/QC reports can be seen in Attachment H.

DM McMahon Pty Ltd – October 2020 Page 19 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 10.0 Quality assurance/quality control data evaluation

Table 6: Sampling Data Quality Indicators

DM McMahon Pty Ltd – October 2020 Page 20 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 Table 7: Analysis Data Quality Indicators

Data quality objectives The following QA/QC samples were taken in accordance with the requirements of NEPM (2013), EPA (1995) & AS 4482.1-2005: • One soil duplicate sample was taken during the sampling (7364/1 & 7364/D). All duplicate parameters returned Relative Percentage Differences (RPD) below 30%, except for arsenic (67%), chromium (67%), and nickel (40%). These RPD exceedances are not considered to significantly impact the reliability of the results due to the low parameters concentrations and comparably low exceedance when compared to the adopted criteria. • One rinsate sample was collected (7364/R) with all parameters below the LOR.

DM McMahon Pty Ltd – October 2020 Page 21 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 11.0 Conclusions and recommendations This investigation met the objective of assessing whether contamination has the potential to exist on the site and whether further investigation is needed.

The results of the investigation returned no historical gross contaminating land use and soil contaminant levels were below the adopted human health and environmental criteria for residential land use, with the exception of one sample on the northern boundary located around 5m from the sheep spray dip on the adjacent property with a criteria exceedance for arsenic.

Based on the above, there is a risk to future residential site users from land on the northern boundary where run off from the sheep spray dip is likely to have occurred as indicated by the high arsenic in soil result. Accordingly, it is McMahon’s conclusion that the further investigation and assessment is necessary on the northern boundary around the sheep spray dip run off area. Further investigation is recommended to include surface and subsurface soil sampling on the northern boundary around the sheep spray dip run off area, and groundwater sampling of the bore in the north west corner of the site.

DM McMahon Pty Ltd – October 2020 Page 22 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 12.0 Unexpected findings If any unconsolidated, odorous, stained or deleterious soils are encountered during any further excavation, suspected historical contaminating activities are encountered, or conditions that are not alike the above descriptions, the site supervisor should be informed, the work stopped, and this office be contacted immediately for further evaluation by an appropriately qualified environmental consultant. The unexpected findings may trigger the need for more investigation and assessment dependant on the scope and context of the unexpected finding.

DM McMahon Pty Ltd – October 2020 Page 23 of 24 Preliminary Site Investigation: Walbundrie Road Culcairn NSW 2660 Report 7364 15.0 References AS 1726, (2017). Geotechnical site investigations.

AS 4482.1, (2005). Guide to the investigation and sampling of sites with potentially contaminated soil Part 1: Non-volatile and semi-volatile compounds.

AS 4482.2, (1999). Guide to the sampling and investigation of potentially contaminated soil Part 2: Volatile substances.

BoM, (2020). Climate Data Online.

Doughty, D, (2003). Soil Landscapes of the Holbrook-Tallangatta 1:100,000 Sheets map and report, Department of Sustainable Natural Resources, Sydney.

National Environment Protection (Assessment of Site Contamination) Measure (NEPM), (2013).

NSW Department of Urban Affairs and Planning, (1998). Managing Land Contamination Planning Guidelines SEPP 55–Remediation of Land.

NSW EPA, (1995). Sampling Design Guidelines.

NSW EPA, (2020). Contaminated Land Guidelines, Consultants Reporting on Contaminated Land.

Water NSW, (2020). Water insights. Real-time data.

16.0 Attachments

Attachments Details A. Location map 1 page B. Aerial photographs 15 pages C. Site map 1 page D. Site photographs 3 pages E. Sample location map 1 page F. Field notes 1 page G. Tabulated results 1 page H. Laboratory reports 19 pages I. RPD calculation 1 page

DM McMahon Pty Ltd – October 2020 Page 24 of 24 REPORT 7364

DM McMahon Pty Ltd 6 Jones Street, (PO Box 6118) Wagga Wagga NSW 2650

t (02) 6931 0510 www.dmmcmahon.com.au Attachment A : Location map

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Walbundrie Rd Culcairn NSW Legend Aerial photograph 2019. CU3 boundary Reprot No. 7364.

➤ N

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Walbundrie Rd Culcairn NSW Legend Aerial photograph 1959 CU3 boundary Report No. 7364 ➤ N 500 m Walbundrie Rd Culcairn NSW Legend Aerial photograph 1966 CU3 boundary Report No. 7364 ➤ N 600 m Walbundrie Rd Culcairn NSW Legend Aerial photograph 1972 CU3 boundary Report No. 7364 ➤ N 600 m Walbundrie Rd Culcairn NSW Legend Aerial photograph 1980 CU3 boundary Report No. 7364 ➤ N 600 m Walbundrie Rd Culcairn NSW Legend Aerial photograph 1990 CU3 boundary Report No. 7364 ➤ N 600 m Walbundrie Rd Culcairn NSW Legend Aerial photograph 1996 CU3 boundary Report No. 7364 ➤ N 600 m Walbundrie Rd Culcairn NSW Legend Aerial photograph 1998 CU3 boundary Report No. 7364 ➤ N 600 m Walbundrie Rd Culcairn NSW Legend Aerial photograph 2007 CU3 boundary Report No. 7364 ➤ N

ImageImage ©© 20202020 CNESCNES // AirbusAirbus N 500 m Image © 2020 CNES / Airbus Walbundrie Rd Culcairn NSW Legend Aerial photograph 2015 CU3 boundary Report No. 7364 ➤ N 500 m Walbundrie Rd Culcairn NSW Legend Aerial photograph 2016 CU3 boundary Report No. 7364 ➤ N

Image © 2020 Maxar Technologies Walbundrie Rd Culcairn NSW Legend Aerial photograph 2017 CU3 boundary Report No. 7364 ➤ N 500 m Walbundrie Rd Culcairn NSW Legend Aerial photograph 2019 CU3 boundary Report No. 7364 ➤ N 500 m Attachment C : Site map

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Walbundrie Rd Culcairn NSW Legend Aerial photograph 2019. CU3 boundary Report No. 7364. Previous ram yard ➤ N

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Site photographs Walbundrie Rd Culcairn (CU3) Report No. 7364

Photograph 1: Facing south from the southern end of the site showing the canola crop to the east and the western fence line.

Photograph 1: Facing south from the northern end of the site showing the canola crop to the east and the western fence line.

October 2020 Page 1 of 3

Site photographs Walbundrie Rd Culcairn (CU3) Report No. 7364

Photograph 3: The low-lying area with surface ponding of water in the northern portion of the site. Photograph is taken facing east.

Photograph 4: The windmill, groundwater bore and water trough in the north west corner of the site. The concrete water tank on the adjacent farmland can be seen to the west. The sheep spray dip, yards and shearing shed on the adjacent land can be seen in the background. Photograph is taken facing north.

October 2020 Page 2 of 3

Site photographs Walbundrie Rd Culcairn (CU3) Report No. 7364

Photograph 5: The sheep spray dip on the adjacent land to the north of the site. This photograph is taken from the adjacent land facing east with the canola crop on the subject site to the south.

October 2020 Page 3 of 3

Attachment E : Sample location map

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au

Attachment G : alated reslts

- - DDT + DDE - - Cadmium +DDT mg/kg mg/kg <0.05 <0.05 <0.05 0.05 160 400 18 7 7 2 - - Chlorpyrifos - - Chromium mg/kg mg/kg 6000 0.05 600 190 11 <5 5 5 - - - - - Bifenthrin - Copper mg/kg mg/kg 1100 0.05 <0.2 <0.2 <0.2 180 300 13 20 12 5 - - DDT - Lead mg/kg 170 400 14 4 4 2 ------Nickel mg/kg 7400 400 26 47 19 5 ------Zinc mg/kg <0.1 <0.1 <0.1 0.1 40 ------Mercury mg/kg <0.05 <0.05 <0.05 0.05 10 ------HCB mg/kg <0.05 <0.05 <0.05 0.05 6 ------Heptachlor mg/kg <0.05 <0.05 <0.05 0.1 50 ------Chlordane mg/kg <0.05 <0.05 <0.05 0.05 10 ------Endrin mg/kg <0.05 <0.05 <0.05 0.05 270 ------Endosulfan mg/kg <0.2 <0.2 <0.2 300 0.2 ------Methoxychlor mg/kg 0.2 10 ------Mirex Attachment H : Laorator reports

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au 0 0.00 True

Environmental CERTIFICATE OF ANALYSIS Work Order : ES2037099 Page : 1 of 6 Client : DM MCMAHON PTY LTD Laboratory : Environmental Division Sydney Contact : MR DAVID MCMAHON Contact : Grace White Address : 6 JONES ST Address : 277-289 Woodpark Road Smithfield NSW Australia 2164 Wagga Wagga NSW, AUSTRALIA 2650 Telephone : 02 6931 0510 Telephone : +61 2 8784 8555 Project : WALBUNDRIE RD CULCAIM Date Samples Received : 22-Oct-2020 11:40 Order number : 7364 Date Analysis Commenced : 23-Oct-2020 C-O-C number : ---- Issue Date : 28-Oct-2020 18:04 Sampler : DAVID MCMAHON Site : ---- Quote number : EN/222 No. of samples received : 5 No. of samples analysed : 5 This report supersedes any previous report(s) with this reference. Results apply to the sample(s) as submitted. This document shall not be reproduced, except in full. This Certificate of Analysis contains the following information: l General Comments l Analytical Results l Surrogate Control Limits Additional information pertinent to this report will be found in the following separate attachments: Quality Control Report, QA/QC Compliance Assessment to assist with Quality Review and Sample Receipt Notification. Signatories This document has been electronically signed by the authorized signatories below. Electronic signing is carried out in compliance with procedures specified in 21 CFR Part 11. Signatories Position Accreditation Category Edwandy Fadjar Organic Coordinator Sydney Inorganics, Smithfield, NSW Edwandy Fadjar Organic Coordinator Sydney Organics, Smithfield, NSW Ivan Taylor Analyst Sydney Inorganics, Smithfield, NSW

R I G H T S O L U T I O N S | R I G H T P A R T N E R Page : 2 of 6 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM General Comments

Where the LOR of a reported result differs from standard LOR, this may be due to high moisture content, insufficient sample (reduced weight employed) or matrix interference.

Key : CAS Number = CAS registry number from database maintained by Chemical Abstracts Services. The Chemical Abstracts Service is a division of the American Chemical Society. LOR = Limit of reporting ^ = This result is computed from individual analyte detections at or above the level of reporting ø = ALS is not NATA accredited for these tests. ~ = Indicates an estimated value. l EP068: Where reported, Total Chlordane (sum) is the sum of the reported concentrations of cis-Chlordane and trans-Chlordane at or above the LOR. l EP068: Where reported, Total OCP is the sum of the reported concentrations of all Organochlorine Pesticides at or above LOR. Page : 3 of 6 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM Analytical Results

Sub-Matrix: SOIL Client sample ID 7364/1 7364/2 7364/3 7364/D ---- (Matrix: SOIL) Client sampling date / time 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 ---- Compound CAS Number LOR Unit ES2037099-001 ES2037099-002 ES2037099-003 ES2037099-004 ------Result Result Result Result ---- EA055: Moisture Content (Dried @ 105-110°C) Moisture Content ---- 1.0 % 9.7 11.8 11.2 9.6 ---- EG005(ED093)T: Total Metals by ICP-AES Arsenic 7440-38-2 5 mg/kg <5 1140 <5 10 ---- Cadmium 7440-43-9 1 mg/kg <1 <1 <1 <1 ---- Chromium 7440-47-3 2 mg/kg 7 18 7 14 ---- Copper 7440-50-8 5 mg/kg <5 11 5 5 ---- Lead 7439-92-1 5 mg/kg 12 20 13 12 ---- Nickel 7440-02-0 2 mg/kg 4 14 4 6 ---- Zinc 7440-66-6 5 mg/kg 19 47 26 15 ---- EG035T: Total Recoverable Mercury by FIMS Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 <0.1 <0.1 ---- EP068A: Organochlorine Pesticides (OC) alpha-BHC 319-84-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- beta-BHC 319-85-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- gamma-BHC 58-89-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- delta-BHC 319-86-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Heptachlor 76-44-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Aldrin 309-00-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- ^ Total Chlordane (sum) ---- 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Dieldrin 60-57-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Endrin 72-20-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- ^ Endosulfan (sum) 115-29-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- Endrin ketone 53494-70-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Page : 4 of 6 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM Analytical Results

Sub-Matrix: SOIL Client sample ID 7364/1 7364/2 7364/3 7364/D ---- (Matrix: SOIL) Client sampling date / time 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 21-Oct-2020 00:00 ---- Compound CAS Number LOR Unit ES2037099-001 ES2037099-002 ES2037099-003 ES2037099-004 ------Result Result Result Result ---- EP068A: Organochlorine Pesticides (OC) - Continued Methoxychlor 72-43-5 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- ^ Sum of Aldrin + Dieldrin 309-00-2/60-57-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- ^ Sum of DDD + DDE + DDT 72-54-8/72-55-9/5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- 0-2 EP068B: Organophosphorus Pesticides (OP) Dichlorvos 62-73-7 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Monocrotophos 6923-22-4 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- Dimethoate 60-51-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Diazinon 333-41-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Parathion-methyl 298-00-0 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- Malathion 121-75-5 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Fenthion 55-38-9 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Parathion 56-38-2 0.2 mg/kg <0.2 <0.2 <0.2 <0.2 ---- Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Fenamiphos 22224-92-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Prothiofos 34643-46-4 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Ethion 563-12-2 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Carbophenothion 786-19-6 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 <0.05 <0.05 <0.05 ---- EP068S: Organochlorine Pesticide Surrogate Dibromo-DDE 21655-73-2 0.05 % 90.9 104 102 95.7 ---- EP068T: Organophosphorus Pesticide Surrogate DEF 78-48-8 0.05 % 79.2 83.6 85.0 74.3 ---- Page : 5 of 6 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM Analytical Results

Sub-Matrix: WATER Client sample ID 7364/R ------(Matrix: WATER) Client sampling date / time 21-Oct-2020 00:00 ------Compound CAS Number LOR Unit ES2037099-005 ------Result ------EG020T: Total Metals by ICP-MS Arsenic 7440-38-2 0.001 mg/L <0.001 ------Cadmium 7440-43-9 0.0001 mg/L <0.0001 ------Chromium 7440-47-3 0.001 mg/L <0.001 ------Copper 7440-50-8 0.001 mg/L <0.001 ------Nickel 7440-02-0 0.001 mg/L <0.001 ------Lead 7439-92-1 0.001 mg/L <0.001 ------Zinc 7440-66-6 0.005 mg/L <0.005 ------EG035T: Total Recoverable Mercury by FIMS Mercury 7439-97-6 0.0001 mg/L <0.0001 ------Page : 6 of 6 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM Surrogate Control Limits

Work Order : ES2037099 Page : 1 of 8

Client : DM MCMAHON PTY LTD Laboratory : Environmental Division Sydney Contact : MR DAVID MCMAHON Contact : Grace White Address : 6 JONES ST Address : 277-289 Woodpark Road Smithfield NSW Australia 2164 Wagga Wagga NSW, AUSTRALIA 2650 Telephone : 02 6931 0510 Telephone : +61 2 8784 8555 Project : WALBUNDRIE RD CULCAIM Date Samples Received : 22-Oct-2020 Order number : 7364 Date Analysis Commenced : 23-Oct-2020 C-O-C number : ---- Issue Date : 28-Oct-2020 Sampler : DAVID MCMAHON Site : ---- Quote number : EN/222 No. of samples received : 5 No. of samples analysed : 5 This report supersedes any previous report(s) with this reference. Results apply to the sample(s) as submitted. This document shall not be reproduced, except in full. This Quality Control Report contains the following information: l Laboratory Duplicate (DUP) Report; Relative Percentage Difference (RPD) and Acceptance Limits l Method Blank (MB) and Laboratory Control Spike (LCS) Report; Recovery and Acceptance Limits l Matrix Spike (MS) Report; Recovery and Acceptance Limits Signatories This document has been electronically signed by the authorized signatories below. Electronic signing is carried out in compliance with procedures specified in 21 CFR Part 11. Signatories Position Accreditation Category

Edwandy Fadjar Organic Coordinator Sydney Inorganics, Smithfield, NSW Edwandy Fadjar Organic Coordinator Sydney Organics, Smithfield, NSW Ivan Taylor Analyst Sydney Inorganics, Smithfield, NSW

R I G H T S O L U T I O N S | R I G H T P A R T N E R Page : 2 of 8 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM General Comments The analytical procedures used by ALS have been developed from established internationally recognised procedures such as those published by the USEPA, APHA, AS and NEPM. In house developed procedures are fully validated and are often at the client request. Where moisture determination has been performed, results are reported on a dry weight basis. Where a reported less than (<) result is higher than the LOR, this may be due to primary sample extract/digestate dilution and/or insufficient sample for analysis. Where the LOR of a reported result differs from standard LOR, this may be due to high moisture content, insufficient sample (reduced weight employed) or matrix interference.

Key : Anonymous = Refers to samples which are not specifically part of this work order but formed part of the QC process lot CAS Number = CAS registry number from database maintained by Chemical Abstracts Services. The Chemical Abstracts Service is a division of the American Chemical Society. LOR = Limit of reporting RPD = Relative Percentage Difference # = Indicates failed QC Laboratory Duplicate (DUP) Report The quality control term Laboratory Duplicate refers to a randomly selected intralaboratory split. Laboratory duplicates provide information regarding method precision and sample heterogeneity. The permitted ranges for the Relative Percent Deviation (RPD) of Laboratory Duplicates are specified in ALS Method QWI-EN/38 and are dependent on the magnitude of results in comparison to the level of reporting: Result < 10 times LOR: No Limit; Result between 10 and 20 times LOR: 0% - 50%; Result > 20 times LOR: 0% - 20%. Sub-Matrix: SOIL Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EG005(ED093)T: Total Metals by ICP-AES (QC Lot: 3326115) ES2036962-001 Anonymous EG005T: Cadmium 7440-43-9 1 mg/kg <1 <1 0.00 No Limit EG005T: Chromium 7440-47-3 2 mg/kg 5 10 66.6 No Limit EG005T: Nickel 7440-02-0 2 mg/kg 5 10 68.4 No Limit EG005T: Arsenic 7440-38-2 5 mg/kg <5 7 28.7 No Limit EG005T: Copper 7440-50-8 5 mg/kg 22 30 29.6 No Limit EG005T: Lead 7439-92-1 5 mg/kg 17 22 23.6 No Limit EG005T: Zinc 7440-66-6 5 mg/kg 55 76 33.0 0% - 50% ES2036962-011 Anonymous EG005T: Cadmium 7440-43-9 1 mg/kg <1 <1 0.00 No Limit EG005T: Chromium 7440-47-3 2 mg/kg 3 4 0.00 No Limit EG005T: Nickel 7440-02-0 2 mg/kg 2 2 0.00 No Limit EG005T: Arsenic 7440-38-2 5 mg/kg <5 <5 0.00 No Limit EG005T: Copper 7440-50-8 5 mg/kg 11 11 0.00 No Limit EG005T: Lead 7439-92-1 5 mg/kg 14 16 17.1 No Limit EG005T: Zinc 7440-66-6 5 mg/kg 16 16 0.00 No Limit EG005(ED093)T: Total Metals by ICP-AES (QC Lot: 3326117) ES2037099-002 7364/2 EG005T: Arsenic 7440-38-2 5 mg/kg 1140 1110 2.80 0% - 20% ES2037099-002 7364/2 EG005T: Cadmium 7440-43-9 1 mg/kg <1 <1 0.00 No Limit EG005T: Chromium 7440-47-3 2 mg/kg 18 20 10.7 0% - 50% EG005T: Nickel 7440-02-0 2 mg/kg 14 12 8.89 No Limit EG005T: Copper 7440-50-8 5 mg/kg 11 11 0.00 No Limit EG005T: Lead 7439-92-1 5 mg/kg 20 20 0.00 No Limit EG005T: Zinc 7440-66-6 5 mg/kg 47 44 5.85 No Limit ES2037100-008 Anonymous EG005T: Cadmium 7440-43-9 1 mg/kg <1 <1 0.00 No Limit EG005T: Chromium 7440-47-3 2 mg/kg 22 21 4.97 0% - 50% EG005T: Nickel 7440-02-0 2 mg/kg 9 12 30.2 No Limit Page : 3 of 8 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM

Sub-Matrix: SOIL Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EG005(ED093)T: Total Metals by ICP-AES (QC Lot: 3326117) - continued ES2037100-008 Anonymous EG005T: Arsenic 7440-38-2 5 mg/kg 8 8 0.00 No Limit EG005T: Copper 7440-50-8 5 mg/kg 8 10 24.5 No Limit EG005T: Lead 7439-92-1 5 mg/kg 14 15 0.00 No Limit EG005T: Zinc 7440-66-6 5 mg/kg 10 15 38.6 No Limit EA055: Moisture Content (Dried @ 105-110°C) (QC Lot: 3326120) ES2036962-002 Anonymous EA055: Moisture Content ---- 0.1 % 5.4 6.1 12.2 No Limit ES2036962-014 Anonymous EA055: Moisture Content ---- 0.1 % 12.1 12.3 1.53 0% - 50% EA055: Moisture Content (Dried @ 105-110°C) (QC Lot: 3326121) ES2037099-004 7364/D EA055: Moisture Content ---- 0.1 % 9.6 9.2 4.42 No Limit ES2037101-002 Anonymous EA055: Moisture Content ---- 0.1 % 13.0 12.6 3.39 0% - 50% EG035T: Total Recoverable Mercury by FIMS (QC Lot: 3326116) ES2036962-001 Anonymous EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 0.00 No Limit ES2036962-011 Anonymous EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 0.00 No Limit EG035T: Total Recoverable Mercury by FIMS (QC Lot: 3326118) ES2037099-002 7364/2 EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 0.00 No Limit ES2037100-008 Anonymous EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 <0.1 0.00 No Limit EP068A: Organochlorine Pesticides (OC) (QC Lot: 3324937) ES2037099-001 7364/1 EP068: alpha-BHC 319-84-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: beta-BHC 319-85-7 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: gamma-BHC 58-89-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: delta-BHC 319-86-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Heptachlor 76-44-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Aldrin 309-00-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Dieldrin 60-57-1 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endrin 72-20-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Endrin ketone 53494-70-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068: Methoxychlor 72-43-5 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068B: Organophosphorus Pesticides (OP) (QC Lot: 3324937) Page : 4 of 8 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM

Sub-Matrix: SOIL Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EP068B: Organophosphorus Pesticides (OP) (QC Lot: 3324937) - continued ES2037099-001 7364/1 EP068: Dichlorvos 62-73-7 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Dimethoate 60-51-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Diazinon 333-41-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Malathion 121-75-5 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Fenthion 55-38-9 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Fenamiphos 22224-92-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Prothiofos 34643-46-4 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Ethion 563-12-2 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Carbophenothion 786-19-6 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 <0.05 0.00 No Limit EP068: Monocrotophos 6923-22-4 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068: Parathion-methyl 298-00-0 0.2 mg/kg <0.2 <0.2 0.00 No Limit EP068: Parathion 56-38-2 0.2 mg/kg <0.2 <0.2 0.00 No Limit

Sub-Matrix: WATER Laboratory Duplicate (DUP) Report Laboratory sample ID Client sample ID Method: Compound CAS Number LOR Unit Original Result Duplicate Result RPD (%) Recovery Limits (%) EG020T: Total Metals by ICP-MS (QC Lot: 3326173) ES2037145-004 Anonymous EG020A-T: Cadmium 7440-43-9 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit EG020A-T: Arsenic 7440-38-2 0.001 mg/L 8.69 8.62 0.787 0% - 20% EG020A-T: Chromium 7440-47-3 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Copper 7440-50-8 0.001 mg/L 0.162 0.162 0.00 0% - 20% EG020A-T: Lead 7439-92-1 0.001 mg/L 0.003 0.003 0.00 No Limit EG020A-T: Nickel 7440-02-0 0.001 mg/L 0.014 0.013 0.00 0% - 50% EG020A-T: Zinc 7440-66-6 0.005 mg/L 0.006 <0.005 19.3 No Limit ES2037065-001 Anonymous EG020A-T: Cadmium 7440-43-9 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit EG020A-T: Arsenic 7440-38-2 0.001 mg/L <0.001 0.001 0.00 No Limit EG020A-T: Chromium 7440-47-3 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Copper 7440-50-8 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Lead 7439-92-1 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Nickel 7440-02-0 0.001 mg/L <0.001 <0.001 0.00 No Limit EG020A-T: Zinc 7440-66-6 0.005 mg/L 0.006 0.005 0.00 No Limit EG035T: Total Recoverable Mercury by FIMS (QC Lot: 3326211) ES2036858-001 Anonymous EG035T: Mercury 7439-97-6 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit ES2037063-002 Anonymous EG035T: Mercury 7439-97-6 0.0001 mg/L <0.0001 <0.0001 0.00 No Limit Page : 5 of 8 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM Method Blank (MB) and Laboratory Control Spike (LCS) Report The quality control term Method / Laboratory Blank refers to an analyte free matrix to which all reagents are added in the same volumes or proportions as used in standard sample preparation. The purpose of this QC parameter is to monitor potential laboratory contamination. The quality control term Laboratory Control Spike (LCS) refers to a certified reference material, or a known interference free matrix spiked with target analytes. The purpose of this QC parameter is to monitor method precision and accuracy independent of sample matrix. Dynamic Recovery Limits are based on statistical evaluation of processed LCS.

Sub-Matrix: SOIL Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EG005(ED093)T: Total Metals by ICP-AES (QCLot: 3326115) EG005T: Arsenic 7440-38-2 5 mg/kg <5 121.1 mg/kg 106 88.0 113 EG005T: Cadmium 7440-43-9 1 mg/kg <1 0.74 mg/kg 116 70.0 130 EG005T: Chromium 7440-47-3 2 mg/kg <2 20.2 mg/kg 94.6 68.0 132 EG005T: Copper 7440-50-8 5 mg/kg <5 52.9 mg/kg 111 89.0 111 EG005T: Lead 7439-92-1 5 mg/kg <5 62.1 mg/kg 99.4 82.0 119 EG005T: Nickel 7440-02-0 2 mg/kg <2 15.4 mg/kg 100 80.0 120 EG005T: Zinc 7440-66-6 5 mg/kg <5 162 mg/kg 83.9 66.0 133 EG005(ED093)T: Total Metals by ICP-AES (QCLot: 3326117) EG005T: Arsenic 7440-38-2 5 mg/kg <5 121.1 mg/kg 104 88.0 113 EG005T: Cadmium 7440-43-9 1 mg/kg <1 0.74 mg/kg 108 70.0 130 EG005T: Chromium 7440-47-3 2 mg/kg <2 20.2 mg/kg 92.0 68.0 132 EG005T: Copper 7440-50-8 5 mg/kg <5 52.9 mg/kg 109 89.0 111 EG005T: Lead 7439-92-1 5 mg/kg <5 62.1 mg/kg 96.3 82.0 119 EG005T: Nickel 7440-02-0 2 mg/kg <2 15.4 mg/kg 95.3 80.0 120 EG005T: Zinc 7440-66-6 5 mg/kg <5 162 mg/kg 81.8 66.0 133 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326116) EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 0.0847 mg/kg 79.7 70.0 105 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326118) EG035T: Mercury 7439-97-6 0.1 mg/kg <0.1 0.0847 mg/kg 73.4 70.0 105 EP068A: Organochlorine Pesticides (OC) (QCLot: 3324937) EP068: alpha-BHC 319-84-6 0.05 mg/kg <0.05 0.5 mg/kg 104 69.0 113 EP068: Hexachlorobenzene (HCB) 118-74-1 0.05 mg/kg <0.05 0.5 mg/kg 106 65.0 117 EP068: beta-BHC 319-85-7 0.05 mg/kg <0.05 0.5 mg/kg 92.0 67.0 119 EP068: gamma-BHC 58-89-9 0.05 mg/kg <0.05 0.5 mg/kg 92.8 68.0 116 EP068: delta-BHC 319-86-8 0.05 mg/kg <0.05 0.5 mg/kg 92.0 65.0 117 EP068: Heptachlor 76-44-8 0.05 mg/kg <0.05 0.5 mg/kg 106 67.0 115 EP068: Aldrin 309-00-2 0.05 mg/kg <0.05 0.5 mg/kg 105 69.0 115 EP068: Heptachlor epoxide 1024-57-3 0.05 mg/kg <0.05 0.5 mg/kg 103 62.0 118 EP068: trans-Chlordane 5103-74-2 0.05 mg/kg <0.05 0.5 mg/kg 105 63.0 117 EP068: alpha-Endosulfan 959-98-8 0.05 mg/kg <0.05 0.5 mg/kg 94.9 66.0 116 EP068: cis-Chlordane 5103-71-9 0.05 mg/kg <0.05 0.5 mg/kg 91.8 64.0 116 EP068: Dieldrin 60-57-1 0.05 mg/kg <0.05 0.5 mg/kg 95.5 66.0 116 EP068: 4.4`-DDE 72-55-9 0.05 mg/kg <0.05 0.5 mg/kg 96.5 67.0 115 EP068: Endrin 72-20-8 0.05 mg/kg <0.05 0.5 mg/kg 108 67.0 123 Page : 6 of 8 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM

Sub-Matrix: SOIL Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EP068A: Organochlorine Pesticides (OC) (QCLot: 3324937) - continued EP068: beta-Endosulfan 33213-65-9 0.05 mg/kg <0.05 0.5 mg/kg 104 69.0 115 EP068: 4.4`-DDD 72-54-8 0.05 mg/kg <0.05 0.5 mg/kg 100 69.0 121 EP068: Endrin aldehyde 7421-93-4 0.05 mg/kg <0.05 0.5 mg/kg 90.8 56.0 120 EP068: Endosulfan sulfate 1031-07-8 0.05 mg/kg <0.05 0.5 mg/kg 87.9 62.0 124 EP068: 4.4`-DDT 50-29-3 0.2 mg/kg <0.2 0.5 mg/kg 91.8 66.0 120 EP068: Endrin ketone 53494-70-5 0.05 mg/kg <0.05 0.5 mg/kg 94.1 64.0 122 EP068: Methoxychlor 72-43-5 0.2 mg/kg <0.2 0.5 mg/kg 91.2 54.0 130 EP068B: Organophosphorus Pesticides (OP) (QCLot: 3324937) EP068: Dichlorvos 62-73-7 0.05 mg/kg <0.05 0.5 mg/kg 76.8 59.0 119 EP068: Demeton-S-methyl 919-86-8 0.05 mg/kg <0.05 0.5 mg/kg 98.8 62.0 128 EP068: Monocrotophos 6923-22-4 0.2 mg/kg <0.2 0.5 mg/kg 80.3 54.0 126 EP068: Dimethoate 60-51-5 0.05 mg/kg <0.05 0.5 mg/kg 100 67.0 119 EP068: Diazinon 333-41-5 0.05 mg/kg <0.05 0.5 mg/kg 94.9 70.0 120 EP068: Chlorpyrifos-methyl 5598-13-0 0.05 mg/kg <0.05 0.5 mg/kg 103 72.0 120 EP068: Parathion-methyl 298-00-0 0.2 mg/kg <0.2 0.5 mg/kg 108 68.0 120 EP068: Malathion 121-75-5 0.05 mg/kg <0.05 0.5 mg/kg 92.4 68.0 122 EP068: Fenthion 55-38-9 0.05 mg/kg <0.05 0.5 mg/kg 106 69.0 117 EP068: Chlorpyrifos 2921-88-2 0.05 mg/kg <0.05 0.5 mg/kg 108 76.0 118 EP068: Parathion 56-38-2 0.2 mg/kg <0.2 0.5 mg/kg 101 64.0 122 EP068: Pirimphos-ethyl 23505-41-1 0.05 mg/kg <0.05 0.5 mg/kg 97.5 70.0 116 EP068: Chlorfenvinphos 470-90-6 0.05 mg/kg <0.05 0.5 mg/kg 104 69.0 121 EP068: Bromophos-ethyl 4824-78-6 0.05 mg/kg <0.05 0.5 mg/kg 106 66.0 118 EP068: Fenamiphos 22224-92-6 0.05 mg/kg <0.05 0.5 mg/kg 95.5 68.0 124 EP068: Prothiofos 34643-46-4 0.05 mg/kg <0.05 0.5 mg/kg 94.4 62.0 112 EP068: Ethion 563-12-2 0.05 mg/kg <0.05 0.5 mg/kg 104 68.0 120 EP068: Carbophenothion 786-19-6 0.05 mg/kg <0.05 0.5 mg/kg 94.8 65.0 127 EP068: Azinphos Methyl 86-50-0 0.05 mg/kg <0.05 0.5 mg/kg 66.2 41.0 123

Sub-Matrix: WATER Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EG020T: Total Metals by ICP-MS (QCLot: 3326173) EG020A-T: Arsenic 7440-38-2 0.001 mg/L <0.001 0.1 mg/L 91.1 82.0 114 EG020A-T: Cadmium 7440-43-9 0.0001 mg/L <0.0001 0.1 mg/L 92.8 84.0 112 EG020A-T: Chromium 7440-47-3 0.001 mg/L <0.001 0.1 mg/L 93.6 86.0 116 EG020A-T: Copper 7440-50-8 0.001 mg/L <0.001 0.1 mg/L 88.9 83.0 118 EG020A-T: Lead 7439-92-1 0.001 mg/L <0.001 0.1 mg/L 89.7 85.0 115 EG020A-T: Nickel 7440-02-0 0.001 mg/L <0.001 0.1 mg/L 86.6 84.0 116 EG020A-T: Zinc 7440-66-6 0.005 mg/L <0.005 0.1 mg/L 90.9 79.0 117 Page : 7 of 8 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM

Sub-Matrix: WATER Method Blank (MB) Laboratory Control Spike (LCS) Report Report Spike Spike Recovery (%) Recovery Limits (%)

Method: Compound CAS Number LOR Unit Result Concentration LCS Low High EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326211) EG035T: Mercury 7439-97-6 0.0001 mg/L <0.0001 0.01 mg/L 95.6 77.0 111

Laboratory sample ID Client sample ID Method: Compound CAS Number Concentration MS Low High EG005(ED093)T: Total Metals by ICP-AES (QCLot: 3326115) ES2036962-001 Anonymous EG005T: Arsenic 7440-38-2 50 mg/kg 104 70.0 130 EG005T: Cadmium 7440-43-9 50 mg/kg 99.0 70.0 130 EG005T: Chromium 7440-47-3 50 mg/kg 95.1 68.0 132 EG005T: Copper 7440-50-8 250 mg/kg 100 70.0 130 EG005T: Lead 7439-92-1 250 mg/kg 99.3 70.0 130 EG005T: Nickel 7440-02-0 50 mg/kg 103 70.0 130 EG005T: Zinc 7440-66-6 250 mg/kg 103 66.0 133 EG005(ED093)T: Total Metals by ICP-AES (QCLot: 3326117) ES2037099-002 7364/2 EG005T: Arsenic 7440-38-2 50 mg/kg # Not 70.0 130 Determined EG005T: Cadmium 7440-43-9 50 mg/kg 97.6 70.0 130 EG005T: Chromium 7440-47-3 50 mg/kg 89.1 68.0 132 EG005T: Copper 7440-50-8 250 mg/kg 96.6 70.0 130 EG005T: Lead 7439-92-1 250 mg/kg 97.8 70.0 130 EG005T: Nickel 7440-02-0 50 mg/kg 94.6 70.0 130 EG005T: Zinc 7440-66-6 250 mg/kg 97.1 66.0 133 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326116) ES2036962-001 Anonymous EG035T: Mercury 7439-97-6 5 mg/kg 87.9 70.0 130 EG035T: Total Recoverable Mercury by FIMS (QCLot: 3326118) ES2037099-002 7364/2 EG035T: Mercury 7439-97-6 5 mg/kg 86.6 70.0 130 EP068A: Organochlorine Pesticides (OC) (QCLot: 3324937) ES2037099-001 7364/1 EP068: gamma-BHC 58-89-9 0.5 mg/kg 116 70.0 130 EP068: Heptachlor 76-44-8 0.5 mg/kg 76.2 70.0 130 EP068: Aldrin 309-00-2 0.5 mg/kg 78.0 70.0 130 EP068: Dieldrin 60-57-1 0.5 mg/kg 84.9 70.0 130 EP068: Endrin 72-20-8 2 mg/kg 96.1 70.0 130 EP068: 4.4`-DDT 50-29-3 2 mg/kg 96.4 70.0 130 Page : 8 of 8 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM

Sub-Matrix: SOIL Matrix Spike (MS) Report Spike SpikeRecovery(%) Recovery Limits (%)

Laboratory sample ID Client sample ID Method: Compound CAS Number Concentration MS Low High EP068B: Organophosphorus Pesticides (OP) (QCLot: 3324937) ES2037099-001 7364/1 EP068: Diazinon 333-41-5 0.5 mg/kg 85.8 70.0 130 EP068: Chlorpyrifos-methyl 5598-13-0 0.5 mg/kg 85.1 70.0 130 EP068: Pirimphos-ethyl 23505-41-1 0.5 mg/kg 83.6 70.0 130 EP068: Bromophos-ethyl 4824-78-6 0.5 mg/kg 82.1 70.0 130 EP068: Prothiofos 34643-46-4 0.5 mg/kg 83.9 70.0 130

Sub-Matrix: WATER Matrix Spike (MS) Report Spike SpikeRecovery(%) Recovery Limits (%)

Environmental QA/QC Compliance Assessment to assist with Quality Review

Work Order : ES2037099 Page : 1 of 5

Client : DM MCMAHON PTY LTD Laboratory : Environmental Division Sydney Contact : MR DAVID MCMAHON Telephone : +61 2 8784 8555 Project : WALBUNDRIE RD CULCAIM Date Samples Received : 22-Oct-2020 Site : ---- Issue Date : 28-Oct-2020 Sampler : DAVID MCMAHON No. of samples received : 5 Order number : 7364 No. of samples analysed : 5

Brief method summaries and references are also provided to assist in traceability.

Summary of Outliers Outliers : Quality Control Samples

Outliers : Analysis Holding Time Compliance l NO Analysis Holding Time Outliers exist.

Outliers : Frequency of Quality Control Samples l NO Quality Control Sample Frequency Outliers exist.

R I G H T S O L U T I O N S | R I G H T P A R T N E R Page : 2 of 5 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM Outliers : Quality Control Samples Duplicates, Method Blanks, Laboratory Control Samples and Matrix Spikes

Matrix: SOIL Compound Group Name Laboratory Sample ID Client Sample ID Analyte CAS Number Data Limits Comment Matrix Spike (MS) Recoveries EG005(ED093)T: Total Metals by ICP-AES ES2037099--002 7364/2 Arsenic 7440-38-2 Not ---- MS recovery not determined, Determined background level greater than or equal to 4x spike level.

EA055: Moisture Content (Dried @ 105-110°C) Soil Glass Jar - Unpreserved (EA055) 7364/1, 7364/2, 21-Oct-2020 ------23-Oct-2020 04-Nov-2020 ü 7364/3, 7364/D EG005(ED093)T: Total Metals by ICP-AES Soil Glass Jar - Unpreserved (EG005T) 7364/1, 7364/2, 21-Oct-2020 23-Oct-2020 19-Apr-2021 ü 26-Oct-2020 19-Apr-2021 ü 7364/3, 7364/D EG035T: Total Recoverable Mercury by FIMS Soil Glass Jar - Unpreserved (EG035T) 7364/1, 7364/2, 21-Oct-2020 23-Oct-2020 18-Nov-2020 ü 27-Oct-2020 18-Nov-2020 ü 7364/3, 7364/D EP068A: Organochlorine Pesticides (OC) Soil Glass Jar - Unpreserved (EP068) 7364/1, 7364/2, 21-Oct-2020 26-Oct-2020 04-Nov-2020 ü 27-Oct-2020 05-Dec-2020 ü 7364/3, 7364/D EP068B: Organophosphorus Pesticides (OP) Soil Glass Jar - Unpreserved (EP068) 7364/1, 7364/2, 21-Oct-2020 26-Oct-2020 04-Nov-2020 ü 27-Oct-2020 05-Dec-2020 ü 7364/3, 7364/D

EG020T: Total Metals by ICP-MS Clear Plastic Bottle - Nitric Acid; Unfiltered (EG020A-T) 7364/R 21-Oct-2020 23-Oct-2020 19-Apr-2021 ü 23-Oct-2020 19-Apr-2021 ü EG035T: Total Recoverable Mercury by FIMS Clear Plastic Bottle - Nitric Acid; Unfiltered (EG035T) 7364/R 21-Oct-2020 ------27-Oct-2020 18-Nov-2020 ü Page : 4 of 5 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM

Matrix: SOIL Evaluation: û = Quality Control frequency not within specification ; ü = Quality Control frequency within specification. Quality Control Sample Type Count Rate (%) Quality Control Specification Analytical Methods Method QC Regular Actual Expected Evaluation Laboratory Duplicates (DUP) Moisture Content EA055 4 40 10.00 10.00 ü NEPM 2013 B3 & ALS QC Standard Pesticides by GCMS EP068 1 9 11.11 10.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 4 38 10.53 10.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 5 40 12.50 10.00 ü NEPM 2013 B3 & ALS QC Standard Laboratory Control Samples (LCS) Pesticides by GCMS EP068 1 9 11.11 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 2 38 5.26 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 2 40 5.00 5.00 ü NEPM 2013 B3 & ALS QC Standard Method Blanks (MB) Pesticides by GCMS EP068 1 9 11.11 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 2 38 5.26 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 2 40 5.00 5.00 ü NEPM 2013 B3 & ALS QC Standard Matrix Spikes (MS) Pesticides by GCMS EP068 1 9 11.11 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Mercury by FIMS EG035T 2 38 5.26 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-AES EG005T 2 40 5.00 5.00 ü NEPM 2013 B3 & ALS QC Standard Matrix: WATER Evaluation: û = Quality Control frequency not within specification ; ü = Quality Control frequency within specification. Quality Control Sample Type Count Rate (%) Quality Control Specification Analytical Methods Method QC Regular Actual Expected Evaluation Laboratory Duplicates (DUP) Total Mercury by FIMS EG035T 2 16 12.50 10.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 2 15 13.33 10.00 ü NEPM 2013 B3 & ALS QC Standard Laboratory Control Samples (LCS) Total Mercury by FIMS EG035T 1 16 6.25 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 1 15 6.67 5.00 ü NEPM 2013 B3 & ALS QC Standard Method Blanks (MB) Total Mercury by FIMS EG035T 1 16 6.25 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 1 15 6.67 5.00 ü NEPM 2013 B3 & ALS QC Standard Matrix Spikes (MS) Total Mercury by FIMS EG035T 1 16 6.25 5.00 ü NEPM 2013 B3 & ALS QC Standard Total Metals by ICP-MS - Suite A EG020A-T 1 15 6.67 5.00 ü NEPM 2013 B3 & ALS QC Standard Page : 5 of 5 Work Order : ES2037099 Client : DM MCMAHON PTY LTD Project : WALBUNDRIE RD CULCAIM Brief Method Summaries The analytical procedures used by the Environmental Division have been developed from established internationally recognized procedures such as those published by the US EPA, APHA, AS and NEPM. In house developed procedures are employed in the absence of documented standards or by client request. The following report provides brief descriptions of the analytical procedures employed for results reported in the Certificate of Analysis. Sources from which ALS methods have been developed are provided within the Method Descriptions. Analytical Methods Method Matrix Method Descriptions Moisture Content EA055 SOIL In house: A gravimetric procedure based on weight loss over a 12 hour drying period at 105-110 degrees C. This method is compliant with NEPM Schedule B(3). Total Metals by ICP-AES EG005T SOIL In house: Referenced to APHA 3120; USEPA SW 846 - 6010. Metals are determined following an appropriate acid digestion of the soil. The ICPAES technique ionises samples in a plasma, emitting a characteristic spectrum based on metals present. Intensities at selected wavelengths are compared against those of matrix matched standards. This method is compliant with NEPM Schedule B(3) Total Mercury by FIMS EG035T SOIL In house: Referenced to AS 3550, APHA 3112 Hg - B (Flow-injection (SnCl2) (Cold Vapour generation) AAS) FIM-AAS is an automated flameless atomic absorption technique. Mercury in solids are determined following an appropriate acid digestion. Ionic mercury is reduced online to atomic mercury vapour by SnCl2 which is then purged into a heated quartz cell. Quantification is by comparing absorbance against a calibration curve. This method is compliant with NEPM Schedule B(3) Pesticides by GCMS EP068 SOIL In house: Referenced to USEPA SW 846 - 8270 Extracts are analysed by Capillary GC/MS and quantification is by comparison against an established 5 point calibration curve. This technique is compliant with NEPM Schedule B(3). Total Metals by ICP-MS - Suite A EG020A-T WATER In house: Referenced to APHA 3125; USEPA SW846 - 6020, ALS QWI-EN/EG020. The ICPMS technique utilizes a highly efficient argon plasma to ionize selected elements. Ions are then passed into a high vacuum mass spectrometer, which separates the analytes based on their distinct mass to charge ratios prior to their measurement by a discrete dynode ion detector. Total Mercury by FIMS EG035T WATER In house: Referenced to AS 3550, APHA 3112 Hg - B (Flow-injection (SnCl2)(Cold Vapour generation) AAS) FIM-AAS is an automated flameless atomic absorption technique. A bromate/bromide reagent is used to oxidise any organic mercury compounds in the unfiltered sample. The ionic mercury is reduced online to atomic mercury vapour by SnCl2 which is then purged into a heated quartz cell. Quantification is by comparing absorbance against a calibration curve. This method is compliant with NEPM Schedule B(3).

DM McMahon Pty Ltd 6 Jones Street (PO BOX 6118) Wagga Wagga NSW 2650 t (02) 6931 0510 w www.dmmcmahon.com.au Duplicate Sample Sample Sample ID RPD Calculation (%) 7365/D 7364/1 Sample Point 1 Point Point 0.1-0.2m 0.1-0.2m Sample depth 67 10 <5 Arsenic <1 <1 0 Cadmium 14 67 7 Chromium <5 Parameter 0 5 Copper 40 6 4 Nickel 12 12 0 Lead 15 19 24 Zinc <0.1 <0.1 0 Mercury

Attachment ‘G’ Additional information post-Gateway determination

Addendum to Planning Proposal Zoning and Minimum Lot Size Changes for Culcairn – May 2020

This document will address issues that have been raised by the Department of Planning, Industry and Environment (the Department) which have prevented the granting of a Gateway Determination for Councils Planning Proposal for zoning and minimum lot size changes for Culcairn (the planning proposal).

The following issues are to be addressed include flood planning, sewer implications including buffer around treatment works and capacity of the treatment works, demonstration for demand for the land, addressing Ministerial Directions, bushfire, discussing further any inconsistency with the Greater Hume Local Strategic Planning Statement and land contamination.

Flood Planning The planning proposal shows figures 8 and 9 which are both sourced from the Culcairn Floodplain Risk Management Study and Plan and indicate that all candidate sites are effected by the 1%AEP flooding to some degree. Council requests that the Department consider Figure 3 (attached) also from the Culcairn Floodplain Risk Management Study and Plan. Figure 3 shows key locations and flood hotspots and has been trimmed to remove all depths for the 1% AEP event that are less than 100 mm. When the candidate site are compared against this Figure it can be seen that all of these sites are only partially effected to flooding at the 1% AEP and only to a depth 0.1-0.5 metre. Figure 14 (attached) is the Flood Planning Area and Levels, perusal of this figures show that all of the candidate sites are partially within a Flood Planning Area which has either a free board of 150 mm to 300 mm. Given that the inundation by the 1% AEP is minor at 0.1 to 0.5 metres and there is a modest free board it is considered by Council that dwellings constructed on the candidate sites can quite easily achieve a floor height that is above the flood planning level.

It is advised that the Culcairn Floodplain Risk Management Study and Plan also test amelioration strategies for the management of risk and put forwards priorities and approximately costed recommendations in regards to flood risk management at Culcairn.

On page 63 of the Culcairn Floodplain Risk Management Study and Plan there is a discussion regarding combined option S2/A7/A8 – Stopping Billabong Creek Flood Affectation to prevent Culcairn flooding from Billabong Creek for events up to and including the 1% AEP event. The works would include S2 Blockage of the Billabong Creek anabranch in two locations to stop Creek breakouts and flow through town and A7 & A8 construction of a non-return valve on the Gordon Street and Gamble Street drains. The costs to undertake works to complete S2/A7/A8 are quite modest and Council is proceeding with obtaining detailed designs to undertake the work.

It is indicated that the combination of S2/A7/A8 results in the elimination of flood affectation in Culcairn from Billabong Creek flood events which is shown Figure H9 (attached). It is conceded that flooding from local overland flow in Culcairn will not be mitigated by this measure. Council has been advised from the Department that overland flows are treated differently to creek flooding and do not result in the generation of a Flood Planning Area. Consequently if the work S2/A7/A8 is completed by Council there will not be a Flood Planning Area for Culcairn.

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The areas of land to be rezoned affected by overland flow which will include CU1 and CU4 will have development which will have finished floor heights set above the known height of the overland flow which from figure 3 is only in the range of 0.1m to 0.5 metres.

Culcairn Sewerage Treatment Works Capacity to treat additional volumes as a result of increased development Council has been requested to clarify whether the Culcairn Sewerage Treatment Works has sufficient capacity to treat additional inflow that will arise should additional land be rezoned to residential purposes.

It is advised that NSW Public Works Advisory has recently produced the Greater Hume Council Integrated Water Cycle Management Strategy Issues Paper (IWCM Issues Paper) which is the first component in the production of Greater Hume Councils Integrated Water Cycle Management Strategy. This document is a Local Water Utility’s (LWU) 30 year strategy that it identifies:

• the water supply and sewerage needs of a LWU; • ‘Right sizes’ any infrastructure projects and determines their priority; • Identifies the lowest level of stable Typical Residential Bill (TRB) to meet the levels service; • Includes a 30-year Total Asset Management Plan and Financial Plan.

There are population and demographic projections that are contained within the IWCM Issues Paper and for Culcairn the modelling that has been performed is based on a growth rate of 1% per annum. The projected number of occupied dwellings within Culcairn is to rise from 439 in 2019 to 592 in 2049. With the population rising from 1050 in 2019 to 1415 in 2049. Based on these projection the IWCM Issues Paper provides the following commentary with respect to Culcairn STP Performance:

The hydraulic load on Culcairn STP is not expected to exceed the STP capacity of 288 kL/day in the next 30 years. However, the biological load on the STP is estimated to exceed the STP capacity of 84kg/day around 2040.

Council believes that the IWCM Issues Paper is a credible source and can be relied upon to demonstrate that there is sufficient capacity at the Culcairn Sewerage Treatment Works to support further development.

Sufficient buffer distance around the Culcairn Sewerage Treatment Works There is a concern that that there will be an insufficient buffer distance around the Culcairn Sewerage Treatment Works CU1 as a result of rezoning from RU1 Primary Production to RU4 Primary Production Small Lots.

It is advised that Councils engineering staff have considered the need for a buffer around the Culcairn Sewerage Treatment Works and they nominated a distance of 400 metres as being acceptable.

In candidate site CU1, Lot 5 DP 250901 is the allotment which is closest to the Culcairn Sewerage Treatment Works. This is a freehold allotment which is owned by Council. The width of the allotment relative to the sewerage treatment works is 530 metres. Subject to the rezoning of this land Council will undertake a subdivision to remove 70 metres of land from the allotment on the eastern side of the allotment. This land will be available for future expansion of the Culcairn Sewerage Treatment Works.

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The remaining portion of land will be available for subdivision consistent with candidate site CU1. Council will develop the subdivision to ensure that no residences will be developed within the 400 metre buffer distance from the Culcairn Sewerage Treatment Works, which could be achieved through the imposition of a restrictive covenants.

Demand for the Land proposed to be Rezoned –A situational Assessment There has not been a residential subdivision undertaken in Culcairn since 2004 where Council created a 20 lot subdivision. The lots were sold progressively between 2004 and 2007 with the last lot being sold in October 2007 which is an average of 5 to 6 lots per year. The lots in the above subdivision ranged from 993 sqm to 1,334 sqm.

In the past 10 years 20 (10 in the last 5 years) new homes have been constructed predominately on infill lots. This has resulted in most of the better infill lots being built upon.

A search of realestate.com.au on Thursday 2 July 2020 indicated that currently there wasn’t any residential allotments listed for sale in Culcairn.

It has been Councils experience from sale of residential land in Culcairn and the neighbouring Walla Walla that prospective new home builders are drawn to new estates in favour of infill development.

Council has revised Table 1 from the planning proposal to provide a reduced estimated lot yield for the candidate site.

Location Area Intended Estimated Qualification on yield Outcome Lot Yield calculation Baird Street 40 hectares RU4 Primary 11 Council has reduced the (CU1) Production area to be developed as Small Lots 4 RU4 within Lot 5 DP ha MLS 250901. Railway 15 hectares RU5 Village 70 Note a portion of this area Parade 600 m2 MLS is preferred in the SLUP (CU2) for industrial development.

The yield for the residential component is based on a typical density for a country town of 10 lots per hectare. Walbundrie 10 hectares RU5 Village 33 lots This candidate site is to be Road (CU3) 600 m2 MLS developed by Council in stages. Until the land is needed it will be used for agricultural.

Council will develop the land with a range of land sizes from 1000 m2 to 2000 m2 Balfour 5 hectares R2 Low 5 lots The land has native Street Density vegetation. The cost of (CU4) Residential removing the vegetation will likely restrict the lot yield in this candidate site.

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As mentioned candidate site CU2 is intended to be partially developed for industrial land where the lot size will be bigger than 600 m2. It is currently surrounded on three sides by development other than agriculture. The site will continue to be used for limited agricultural activity until needed for development.

Council considers that the amount of land requested to be rezoned is appropriate given the scarcity of land that is available for residential development in Culcairn. The candidate sites will provide a range of lot sizes which will appeal to potential purchasers of land.

Risk of Bushfire on Candidate Sites It is advised that Council has perused the bushfire planning map and it appears that none of the candidate sites are shown upon that map as being impacted upon by bushfire. Notwithstanding that the candidate sites are not mapped as being affected by bushfire they maybe subject to grassland fires and candidate site CU4 could be impacted upon by woodland fires.

Council has reviewed Planning for Bush Fire Protection 2019 and notes for strategic planning it is necessary to identify whether new development is appropriate subject to the identified bushfire risk on a landscape scale. It is noted that Planning for Bushfire Protection 2019 states:

The ability of proposed land uses and associated future developments to comply with PBP will be assessed at the strategic planning stage. The expectation will be that the development will be able to comply with PBP at the DA stage.

To comply with the abovementioned expectations Council has reviewed the bushfire risk of the candidate sites which is discussed for the respective candidate sites. This review has involved considering Appendix 1 Site Assessment Methodology of Planning for Bushfire Protection 2019 determining the vegetation formation in all directions around the candidate site over a distance of 140 metres and considering the slope of the land for a distance of 100 metres.

Bushfire assessment CU1 It is anticipated that CU1 could be exposed to grassland fire originating from the North and the East and the topography is flat land. The fire risk in the other directions has been discounted as it has not been possible to determine a predominate vegetation formation due to the landscape being dominated by urban infrastructure.

From the North and East the predominate vegetation formation maybe grassland which is defined by Planning for Bushfire Protection 2019 as follows:

Grassland Maratime Grasslands Temperate Montane Grasslands, Western Slopes Grasslands, Riverine Plain Grasslands and Semi-arid Floodplain Grasslands.

Dominated by perennial grasses and the presence of broad-leaved herbs on flat topography. Lack of woody plants.

Plants include grasses, daises, legumes, geraniums, saltbushes and copperburrs.

Section 7.9 of Planning for Bushfire Protection 2019 contains grassland deeming provisions which have been developed in recognition of the characteristics of grassland fire behavior. It indicates that where an APZ of 50 metre can be provided then no further Bushfire Protection Measures are required.

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Candidate site CU1 is seeking rezoning from RU1 primary production to RU4 Primary Production Small Lots where the minimum lot size for the erection of a dwelling will be 4 ha. There is no question that at this minimum lot size an APZ of 50 metres can be provided at development assessment stage.

Bushfire Assessment CU2 It is anticipated that candidate site CU2 is exposed to a grassland fire risk from the west and the north, the topography of the land is flat land. The candidate site is intended to be rezoned from RU1 primary production to RU5 village with a minimum lot size of 600 square metres.

At the minimum lot size it may not be possible to achieve an APZ of 50 metres which would negate the need for implementing other Bushfire Protection Measures. Council believes that it would be reasonable that future development on the Western side could be designed to comply with Table 7.9 Grassland Deeming Provision for situations where there is an APZ between 20 metres and 49 metres.

Such actions could include a future subdivision providing perimeter access roads on the western side of the candidate site so that the roadway and the building line setback provide a 20 metre APZ. Other provision of Table 7.9 such as access, water supply and landscaping are considered to be able to be implemented at development assessment stage for the subdivision. Construction and landscaping requirements maybe addressed at development assessment stage for future dwellings or other village development.

Bushfire Assessment CU3 It is anticipated that candidate site CU2 is exposed to a grassland fire risk from the west, south and north, the topography of the land is flat land. The candidate site is intended to be rezoned from RU1 primary production to RU5 village with a minimum lot size of 600 square metres.

At the minimum lot size it may not be possible to achieve an APZ of 50 metres which would negate the need for implementing other Bushfire Protection Measures. Council believes that it would be that future development on the Western side could be designed to comply with Table 7.9 Grassland Deeming Provision for situations where there is an APZ between 20 metres and 49 metres.

Such actions could include a future subdivision providing perimeter access roads on the western side of the candidate site so that the roadway and the building line setback provide a 20 metre APZ. Alternatively Council will provide and maintain an APZ on the Western and Northern boundary. Other provision of Table 7.9 such as access, water supply and landscaping are considered to be able to be implemented at development assessment stage for the subdivision. Construction and landscaping requirements maybe addressed at development assessment stage for future dwellings or other village development.

It should be noted that Council intends to develop the land that is within candidate site CU3 and will consider the requirements of Table 7.9 Grassland Deeming Provisions.

Bushfire Assessment CU4 Candidate site CU4 has a small remnant woodland (approximately 4hectares) on the western side. This woodland would meet the following definition:

Woodland Dominated by an open sparse layer of eucalyptus with the crowns rarely touching. Typically 15-35 metres high (may be shorter at sub-alpine altitudes). Diverse ground

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cover of grasses and herbs. Shrubs are sparsely distributed. Usually found on flat or undulating ground.

The Culcairn golf course is located on the southern and eastern side which can be excluded as a bushfire risk under Planning for Bushfire Protection 2019 as it is a grassland managed in a minimal fuel condition.

The candidate site is intended to be rezoned from RU1 primary production to R2 Low Density Residential with a minimum lot size of 4000 square metres.

The predominate bushfire risk is the woodland. The 4000 square metre minimum lot size is compatible with this risk as that lot size will allow a reasonable large APZ to be provided to lots adjacent to the woodland. In turn this will allow a lower bushfire attack level to be applied for future dwellings. The land will also have ready access to the Culcairn Holbrook Road and reticulated water.

Council is satisfied that future development on candidate site CU4 will readily comply with Planning for Bushfire Protection 2019.

Soil Contamination – Ministerial Direction 2.6 Remediation of Land Candidate site CU1, CU2 and CU3 have been used to differing degrees for agricultural use, an activity that may cause contamination, which is listed in Table 1 Managing Land Contamination – Planning Guidelines. Whilst candidate site CU4 does not appear to have been used for agricultural pursuits and is not listed on Councils register of potentially contaminated land.

Due to the use of the land for agricultural use it is required that Council consider Ministerial Direction 2.6 – Remediation of Land. With respect to CU1 and CU2 Council’s evaluation concludes that due to the previous land uses being grazing where chemicals may have been applied only for weed management or on a rare occasion for pasture improvement it is unlikely that the land has been contaminated. The land is not listed on Council’s potentially contaminated register nor is there any visible evidence of contamination on the land. With the information available, Council considers the risk of contamination low and that the planning proposal may proceed.

Candidate site CU3 has routinely been used for broad acre cropping which has resulted in regular application of chemicals. To comply with clause 5 of the Ministerial Direction 2.6 Council is prepared to undertake a preliminary investigation to confirm with respect to land contamination that land can be rezoned from RU1 primary production to RU5. The Preliminary Investigation will be conducted and the rezoning will only proceed to completion depending on the findings of that investigation.

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