AECOM 80239333 tel Level 8 80239399 fax 17 York St Sydney, NSW 2000 18 June 2010 Richard Giles Project Manager Thiess Services Pty Ltd Level 3, 88 Phillip Street Parramatta NSW 2150 PO Box 201, Parramatta CBD BC 2124 Dear Richard, Due Diligence Assessment of Proposed Remedial Action Plan at 2 Christina Road, Villawood, NSW 1.0 Introduction AECOM Australia Pty Ltd (AECOM) was commissioned by Thiess Services Pty Ltd to conduct an archaeological due diligence assessment as part of the preparation of a Remedial Action Plan (RAP) for the former chemical manufacturing facility located at 2 Christina Road, Villawood, NSW (‘the Project Area’ - Lot 1, Plan Number 634604). Remediation works, as part of an overarching Environmental Assessment (EA) process, require approval under Part 3A of the Environmental and Planning Assessment Act 1979. Following the initial Part 3A application by Thiess Services to the Department of Planning (MP 09_0147), the Director General Requirements (DGRs) issued on the 12 May 2010 provided the following statement in their evaluation of ‘Impacts on Aboriginal cultural heritage values’: “DECCW acknowledges that the site is high disturbed and therefore the presence of Aboriginal cultural heritage artefacts is unlikely. Nonetheless, the EA should if applicable: x Address and document the information requirements set out in the draft Guidelines for Aboriginal Cultural Heritage Impact Assessment and Community Consultation involving surveys and consultation with the Aboriginal community; x Identify the nature and extent of impacts on Aboriginal cultural heritage values across the project area; x Describe the actions that will be taken to avoid or mitigate impacts or compensate to prevent unavoidable impacts of the project on Aboriginal cultural heritage values. This should include an assessment of the effectiveness and reliability of the measures and any residual impacts after these measures are implemented; and x Demonstrate that effective community consultation with Aboriginal communities has been undertaken in determining and assessing impacts, developing options and making final recommendations.” (Orica Villawood Remediation Project (MP 09_0147): Director General Requirements, 6.0 Impacts on Aboriginal cultural heritage values, Issued 12 May 2010) The purpose of this due diligence was to determine for the purposes of an EA the applicability of the DGRs for ‘Impacts on Aboriginal cultural heritage values’. This would be addressed by identifying whether there were any existing Aboriginal objects/places previously recorded for the Project Area and also to establish whether there is a risk of impacting any potential Aboriginal objects/places through the course of these works. If the due diligence determined that there were existing or potential Aboriginal objects/places, then a full assessment as stipulated by the DGRs would be applicable and therefore required under Part 3A. The assessment involved a desktop review of existing AHIMS data and archaeological survey reports for the project area, a one-day field inspection and mapping. The contents of this short report have been compiled with reference to Department of Environment, Climate Change and Water’s (DECCW) draft Due Diligence Code of Practice for the Protection of Aboriginal Objects in ABN 20 093 846 925 Page 1 of 11 60155506_Villawood_Heritage_Due Diligence_17Jun10.docx AECOM NSW 2009. These guidelines have been developed to assist proponents in exercising due diligence when carrying out activities that may harm Aboriginal objects and to help determine whether consent in the form of an Aboriginal Heritage Impact Permit (AHIP) is required. 2.0 Project Area Description The Project Area is approximately 12.5 hectares in area and is located in the suburb of Villawood on the northern side of Christina Road, between Birmingham Avenue and Miller Road. The local government area is the Bankstown City Council. The Villawood Detention Centre (former Villawood Migrants Hostel) is located 200 metres to the north and the Leightonfields train station is location 100 metres to the southwest. The Project Area has been developed since the 1940s for a range of industrial purposes including the manufacture of munitions and later a variety of chemicals and pharmaceuticals until the site’s closure in 2000 and subsequent partial demolition. Although few structures remain visible within the Project Area, evidence of the previous activities on site remains as structural foundations, roads and other subsurface utilities (manhole covers, drains etc). In addition to this heavy industrialization, continual usage of the Project Area as a major chemical manufacturing centre over 60 years has resulted in significant ground contamination issues. 3.0 Proposed Activity In 2005, the NSW Environment Protection Authority (EPA) issued a Remediation Order (RO, No 23019, Area 3200) for the Project Area. This requires the land owner to implement a Remedial Action Plan (RAP) to conduct site remediation works which will involve the remediation of soils in parts of the Project Area. The materials to be excavated comprise fill materials (generally clay based fill), natural clays and weathered shales. Excavation operations will commence within any Remediation Area by the removal and stockpiling of the overlying materials. Once in a stockpile, this material will be classified to determine if it can be reused on-site, or whether treatment or off-site disposal will be required. If off-site disposal of materials is required, the material will be sampled and analysed to assess its suitability for disposal to landfill or to a recycling facility in accordance with the Waste Classification Guidelines (DECC 2008). The excavated material requiring treatment will be stockpiled within the Remediation Area compound before being fed to a coarse vibrating screen (Grizzly) by a front end loader to remove oversized materials (greater than 100 mm in size) if required. Any oversized material from the screening works will be sampled and analysed to assess its suitability for treatment, disposal to an appropriate waste facility in accordance with Waste Classification Guidelines (DECC 2008) or transfer to a recycling facility. The remaining material will be temporarily stockpiled within the Remediation Area compound pending sampling and analysis. Materials considered suitable for off-site disposal will be labelled and temporarily stockpiled within the Remediation Area compound for transport and disposal at an appropriately licensed waste or recycling facility. All contaminated soil must be treated as part of the Remedial Action Plan. As a result, the depth of excavations within each of the Remediation Areas cannot be known in advance as that will be determined through the available data obtained through soil analysis for contaminants. Excavation will continue until the base and walls of the excavation have been validated to comply with the Remediation Goals. The plant operating within the Remediation Area compound will include a tracked excavator, front end loader and, if required, a grizzly screen/industrial sieve. 4.0 Project Area History The Project Area was first developed in 1941 and was initially part of a much larger chemical complex owned and used by the Commonwealth of Australia for the manufacturing of munitions, including trinitrotoluene (TNT). The Project Area was subsequently purchased by Taubmans in 1946, who manufactured a range of chemicals including chlorobenzene and DDT until the southern portion of the facility (the Project Area) was purchased by ICIANZ Pty Limited (ICIANZ) in 1953. ICIANZ (and later Orica) continued to manufacture a wide range of agricultural and pharmaceutical chemicals until the site was closed in 2000 and partially demolished. During the period of operations, onsite storage of chemicals and a variety of waste disposal methodologies were employed. These activities resulted in widespread ground contamination of a number of potentially toxic chemicals which are still present on the site today. Page 2 60155506_Villawood_Heritage_Due Diligence_17Jun10.docx AECOM A list of some of the known and suspected chemical contaminants on site includes: x Total Petroleum Hydrocarbons (TPH); x Benzene; x DDT (and its degradation products DDD and DDE); x 1,2-dichloroethane (1,2-DCA); x Trichloroethene (TCE); x Chlorobenzene (MCB); x 1,4-dichlorobenzene (1,4-DCB) x Hexachlorobenzene (HCB); x Lindane (a-BHC); and x Polycyclic Aromatic Hydrocarbons (PAHs), including Benzo(a)pyrene (BaP). SHE Pacific Pty Limited (SHE Pacific) undertook a review of available site historical information in 2000 to assist in ‘the planning of an initial site assessment’ (SHE Pacific 2000). The review included interviews with staff from AstraZeneca, located on the part of the site referred to as the Pharmaceuticals Site, Crop Care Australasia as well as former employees of Orica/ICI Australia. The review included a summary of the various production processes undertaken at the site and the historic use of each of the site buildings, which is summarised in Appendix 13 of the SHE Pacific report. This report included the identification of Site areas where ‘past occurrences, practises or physical features, combined with the materials involved, suggest there may possibly be ground contamination’. 5.0 Project Area Conditions 5.1 Topography The Project Area lies within the geomorphic region of the Sydney basin known as the Cumberland Plain and is categorised as Blacktown landscape type (Bannerman & Hazelton, 1990), which is characterised