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August 2007
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1 of 60 DAMES & MOO
A DAMES & MOORE COMPANY
Melbourne City Link Western Link kea8: Elevated Roads Melbourne, Victoria
POP Banlderstone Hornibrook Engineering PI.,
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00 I:: : : 033298-8-A 0: 0 ::I 0 Ill 0 ::
Dames & Moore Level 10,616 St Kilda Road RcfNo. J:U0102\011ka 8\Arca8 Rep Rcv2.doc Melbourne VIC 3004 18 March 1999 Ph: (03) 95 10 5050 Fax: (03)-9510-5850 A.C.N. 003 293 696
2 of 60 DAMES& MOORE PTYLTD A DAMES &MOORE COMPANY Level 10,616 St Kilda Road . . Melbourne,VIC 3004 61-3-9510 5050 Tel 61-3-9510 5850 Fax [email protected] E-mail
18 March 1999 Ref: KM~S\u)M-MEGNTIUOBSUO102\011\Ana Rcp RCv2.d~
Baulderstone Hornibrook Engineering PL Victoria Dock, Dudley Street MELBOURNE VIC 3000
Attention: Mr Steve Whitter
Dear Steve
STATUTORYENVIRONMENTALAUDITOFWESTERNLINK,MELBOURNE CITY LINK, AREA 8: ELEVATED ROADS, MELBOURNE CITY,VICTORIA
We refer to the appointment of Dames & Moore by Mr Steve Whitter of Baulderstone Homibrook Engineering Pty Ltd @HE), in a contract dated 17 October 1997, to undertake an Environmental Audit of the Western Link Portion of Melbourne City Link between Bulla Road Moonee Valley City and Graham Street, City of Port Phillip, Victoria.
Please fmd attached the Audit report for Area 8 of the Elevated Roads part of the site, indicating that we consider this portion of the project site to be suitable for the proposed use under the conditions indicated in the report. This is consistent with the continuing use of the site for a public road and associated public access to some areas. A copy of this report will be submitted direct to the EPA.
We trust this report will meet with your requirements. However, should you require any clarification of the contents of the report, please contact me immediately on 03 95 10 5050.
Yours faithfully DAMES & MOORE n
EnvironmentalAuditor (Contaminated Land)
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TABLE OF CONTENTS Page N" 1. INTRODUCTION...... 1 2. INFORMATION SUPPLIED ...... 3 3. SITE FEATURES ...... 5 3.1 HISTORICAL USAGE ...... 5 3.2 TOPOGRAPHY. VEGETATION AND DRAINAGE ...... 6 3.3 SOIL PROFILE...... 6 3.4 CONTAMINATED FILLS ...... 7 3.5 HYDROGEOLOGY ...... 9 3.6 POTENTIAL,HAZARDS AND CONTAMINANTS...... 10 3.7 CONSTRUCTION WORK AND REMEDIATION ACTIVITIES ...... 13 3.8 POTENTIAL PATHWAYS FOR MIGRATION OF CONTAMINANTS...... 15 3.9 ACCEPTANCE CRITERIA ...... 16 3.10 VALIDATION PROGRAM ...... 17 4. HUMAN AND ENVIRONMENTAL RECEPTORS ...... 19 4.1 GENERAL ...... 19 4.2 HUMAN RECEPTORS ...... 21 4.3 ECOLOGICAL RECEPTORS ...... 21 5. EXPOSURE TO CONTAMINANTS ...... 23 5.1 EXPOSURE POINT CONCENTRATIONS...... 23 Summary of Area 8 Contamination...... 25 UCL 95% ValueS and Maximum Detects ...... 25 5.1. I Creek Area ...... 25 5.1.2 Filled Area North of Dudley Street ...... 26 5.1.3 FilledAreas to South of Dudley Street ...... 27 5.1.4 . Central Bridge Pier Area ...... 28 5.2 EXPOSURE DURATIONS AND DOSES ...... 28 6. RISK EVALUATION ...... 30 6.1 HUMAN HEALTH...... 30 6.2 ENVIRONMENTAL RISK ...... 31 7. MANAGEMENT & DISPOSAL OF CONTAMINATED MATERIAL ...... 34
8. QUALITY OF INFORMATION...... 37 9. STATEMENT OF ENVIRONMENTAL AUDIT ...... 40 10. LIMITATIONS ...... 44
STATEMENT OF ENVIRONMENTAL AUDIT
4 of 60 Environmental Audit Revision 2 Area 8, Elevated Roaak, Western Link, MCLA, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Ply Ltd Page ii
LIST OF APPENDICES
A Figures B Correspondence with BHE
ATTACwlENTS Baulderstone Hornibrook Report Reference: Audit Reports/PC5228fl, dated February 1999.
5 of 60 Environmental Audit Revision 2 Area 8, Elevated Rod, Western Link, MCLA, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 1
STATUTORY ENVIRONMENTAL AUDIT FOR WESTERN LINK PORTION OF MELBOURNE CITY LINK AREA 8: OF ELEVATED ROADS MELBOURNE CITY,VICTORIA
1. INTRODUCTION
This audit has been performed by Mr Ken Mival, Environmental Auditor (Contaminated Land) appointed by the Victorian EPA on 14 December 1993.
This audit has been prepared following a request by Mr Joe Dujmovic of Baulderstone Homibrook Engineering Pty Ltd (BHE), as confirmed by Mr Steve Whitter of BHE in a contract dated 17 October 1997, for Dames & Moore to complete an Environmental Audit of the Western Link portion of the Melbourne City Link Freeway. BHE has contracted to complete the Western Link section of the Melbourne City Link on behalf of the principal contractor, Transfield Obayashi Joint Venture (TOW.
The property audited includes those areas contained within the construction areas of the Western Link Freeway Portion of Melbourne City Link, and located between Bulla Road, Essendon North, in Moonee Valley City, and Graham Street, Port Melbourne, in the City of Port Phillip.
Mr Mival was engaged as Auditor during October 1997 after construction had started, following an initial period from July 1997 during which h4r MivaI was consulted on taking over the Audit after a previous Auditor, Mr Nick Withers of Hyder Consulting, was unable to continue with the project. Documentation relating to the earlier work by Mr Withers was reviewed and has been taken into account during this Audit.
The Auditor understands from BHE that the Audit has two contractual objectives: e To demonstrate that, in respect of Controlled Land directly affected by the final construction works, the Performance Specifications appropriate to the intended land uses are satisfied; and e To demonstrate that Controlled Land not directly affected by the final construction works, will be returned to TOJV in no worse condition, pollution wise, than when access to the land was provided to BHE.
The area covered by this Audit Report comprises Area 8 of the Elevated Roads part of the project, and is located on a portion of the Moonee Ponds Creek Reserve and adjacent lands, extending between the north bank of Moonee Ponds Creek to the south of Footscray Road, up to the North bank of the Yarra River at North Wharf Road, in Melbourne City, Victoria.
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6 of 60 I Environmental Audit Revision 2 Area 8. Elevated Roads, Western Link MCLA. Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 2
The site prior to the City Link Project was zoned PPI7 “Existing Public Purpose, Port of Melbourne Authority” under the Melbourne City Council Planning Scheme and IB8 “Docklands Business Park” and lMUl “Dockland’s Victoria Harbour Mixed Use Zone under Melbourne Planning Scheme Amendment L202. For the purposes of this Audit, it is assumed that areas not part of the final road reserve will revert to these zonings.
Given the nature of the project, no Certificates of Title have been provided to attempt to define the whole site. However, a number of drawings based on plans of sub-division have been provided to the Auditor that indicate the area reserved for the City Link Project in relation to the existing property subdivisions which assist in defining the boundaries of the areas included in the Audit.
The overall boundary of the land acquired for this segment of the Western Link indicated to the Auditor by BHE, is shown in bold on the sketch plans included in the figures provided with this Audit Report, Drawing No SK-WLG-CI-0133 “Melbourne City Link Project, Western Link, Site Establishment and Access Plans”, Sheets 2 & 3 of 19, dated 7 November 1996, Amendment C and showing Area 8 and a portion of the “Yarra Bridge” part of the site.
The northern boundary of the site that separates Area 8 from Area 7 to the North, was defined in the information supplied. For the purposes of this audit, it has been taken to be at the point at which the MCLA licence envelope (Licence No 4) crosses the western boundary of the Moonee Ponds Creek, and therefore there is some overlap with the Audit of Area 7. The northern limit for this part of the Western Link Audit is indicated in bold in BHEs untitled drawing indicating the licence boundaries included in Appendix A of this Audit Report for reference. The Audit of Area 8 includes the land southwards from the northern boundary indicated, to the north bank of the Yarra River. It includes the central supporting pier located adjacent to the former Osaka Gardens at the western extremity of North Wharf Road.
The boundaries of each parcel of land reserved for the City Link Project under the Melbourne City Link Act (MCLA) are also indicated for Area 8 in the drawing incorporated into Appendix A of this Audit Report. They are described in MCLA Licence No’s 4, 25 and 27 and the boundaries are defined in the attached drawing numbers 1887 107K (part); 1887 1075; Legl 96-219; Legl 96-236, included with the Licences incorporated into Appendix A of BHE’s land Status Report Ref Audit Reports/PC5228fl, dated February 1999.
As requested by BHE, this Audit includes those portions of the land defined in the MCLA licences including those areas indicated by BHE to have been either used for construction or to be occupied by the final freeway envelope. The different segments of the site audited have also been outlined in Figure 3 of the attached BHE report. This figure is also included in Appendix A of this Audit Report for reference. The portion of the site audited in Area 8 is approximately 4 hectares.
7 of 60 Environmental Audit Revision 2 Area 8, Elevated Roadr, Western Link, MCU, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 3
2. INFORMATION SUPPLIED
This environmental audit is based on review of the following information:
0 The Environmental Closure Report titled “Western Link, Land Status Report, Area 8” prepared by Baulderstone Hornibrook Engineering Pty Ltd, Reference Audit ReportsPC5228fl and dated February, 1999.
0 The “Phase 1 Environmental Assessment of Zone W8 of the Western Link” prepared by Golder Associates, Reference 966135 1 1/13 dated March 1996. [The relevant sections of this report are included as excerpts in Appendix B in the above BHE Land Status Report for Area 81.
Phase 2 Environmental Assessment of the Western Section of the Western Link” prepared by Golder Associates, Reference 96613538/209, Volumes 1, 2 and 3, dated May 1996. The borehole logs and lab certificates from the phase 2 report are in Appendix C of the BHE Land Status Report for Area 8. [A copy of the full Golder Report was also supplied to the EPA with the Land Status Report for Area 21.
The Environmental Closure Report titled “Western Link, Land Status Report, Area 2” prepared by Baulderstone Hornibrook Engineering Pty Ltd, Reference EN04DPC4633B and dated October 1998 which contains relevant information on imported fill materials used on all sections of the Elevated Road.
Information included within the Land Status Report for Area 8 from the factual report produced by Golder Associates and Woodward-Clyde titled “Assessment of Land Contamination at Business Park Precinct, Melbourne Docklands” Reference 97613718/57, dated November, 1997, Volumes 1,2,3 and 4.
Various Design Drawings as provided by BHE for this Audit as indicated in the references in Section 7 of the BHE Land Status Report attached.
Various Documents, Method Statements and Work Instructions relating to construction methodology as indicated in the references in Section 7 of the BHE Land Status Report attached.
“Guidelines for Contamination Management of Controlled Land - Western Link” prepared by Hyder Consulting dated December 1996.
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8 of 60 Environmental Audit Revision 2 . Area 8, Elevated Roah, Western Link, MCLA, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering P@ Ltd Page 4
0 A Material Tracking System - as documented in BHE Work Instruction “Material Tracking - Document 8MP603ER004 (rev 2)” dated 14 April 1997 and included in Appendix K of the BHE Land Status Report.
Video tapes of the site conditionat the start of the project before any earthworks had been conducted.
0 Site inspections by Mr Mival on 24 occasions at intervals during the performance of the development works.
The site inspections were carried out to allow observation of the management of earthworks in progress and BHE’s management of soil stockpiles, audit of the tracking system, and to review the final site condition following completion of excavations and landscaping.
Site inspections on the Western Link Project were carried out by this Auditor on the following dates:
16797; 17797; 13 1097;21 1097;25 1197;7198;9198;2298;9298;23298; 17398;253 98; 3 4 98; 29 4 98; 11 5 98; 13 5 98; 2 6 98; 17 6 98; 2 7 98; 19 8 98; 30 9 98; 29 10 98,9 12 98 and 12 2 99.
The soil tracking systems were audited on: 27 January 1998; 17 March 1998; and 29 April 1998.
The Environmental Land Status Report titled “Western Link, Land Status Report, Area 8” prepared by Baulderstone Hornibrook Engineering Pty Ltd, Reference Audit ReportsPC5228fl and dated February 1999, Volumes I, II and III, contains all relevant information pertaining to the environmental quality of the site as at February 1999, and is attached to this document.
A copy of the Phase 2 Environmental Assessment of the Western Section of the Western Link” prepared by Golder Associates, Reference 966913538/209, Volumes 1, 2 & 3, dated May 1996 has been provided with the Area 2 Land Status Report by BHE for reference. The supporting information contained in the BHE and Golder Reports, is an integral part of this Audit report.
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9 of 60 Environmental Audit Revision 2 Area 8, Elevated Road, Western Link McLA. Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 5
3. SITE FEATURES
3.1 HISTORICAL USAGE
Golder Associates were commissioned by BHE to carry out an historical review for the site as part of the Phase I assessment. The Golder report and further investigations by BHE have identified a number of previous features and uses of various parts of the site as follows:
0 A low lying flood plain in the Moonee Ponds Creek Reserve area;
0 Milling of the site as part of a land reclamation process to prevent flooding and for dockside development;
Development of Dockyard facilities on all parts of the audited area;
A former cool store alongside Dudley Street (in the area now occupied by the BHE Site Offices);
Outside storage and cargo stacking area, including the northern parts of the site adjacent to Moonee Ponds Creek, and south of Pitt Street adjacent to Victoria Harbour;
The former T.J. Prest building (formerly used for PMA Maintenance Services;
Port of Melbourne Authority (PMA) Maintenance Services Building, the southern half also occupied by Amalgamated Marine Engineers;
A railway alignment along the northern side of Pitt Street which has been present since 1945; t
The Police Building;
A waste oil drum storage area to the north of the Police Building and adjacent to the east bank of Moonee Ponds Creek;
A Citipower substation located on Dudley Street to the North of the audited area;
An SEC transmission tower; and
The former Osaka Oriental Gardens in the North Wharf area. (The adjacent Shipping Control Tower in not included in the audited area).
10 of 60 Environmental Audit Revision 2 Area 8, Elevated Roads, Western Link, MCLA, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering PvLtd Page 6
The main remaining visible features of those listed above are indicated in Figures 4A and 4B of BHE’s Report.
The Moonee Ponds Creek itself has been re-aligned historically and widened up to Footscray Road to form the Royal Coal Canal. The course of the Yarra River was also diverted into the Coode Canal, and Victoria Harbour was dredged between 1885 and 1921. The works at Victoria Harbour also included dredging of the Royal Coal Canal.
3.2 TOPOGRAPHY, VEGETATION AND DRAINAGE
Area 8 of the Elevated Roads section of Western Link covers an approximate area of 4 hectares including 0.4 hectares of reclaimed land forming the Yarra Bridge Central Island.
There are essentially three main areas, the western extremity of North Wharf (of Victoria Harbour), the area west of Appleton Dock, now the western boundary of the “Business Park” Precinct of the Docklands Development, and the Moonee Ponds Creek. Two topographical units occur within the area; the Moonee Ponds Creek and Yarra River floodplain, and the areas of raised fill including the reclaimed land constructed by BHE to form the Yarra Bridge Central Island.
The fill areas include the former docklands around Dudley Street, and the areas of fill south of Dudley Street to the former wharves on the Yarra River. The filled area is raised several metres above the adjacent floodplain and slopes gently north westwards to the bank of the Moonee Ponds Creek. The creek floodplain itself falls gently to the west, broadening towards the confluence with the Yarra River to the west of the site.
This portion of the MCLA site is covered with fill material or areas of parking or hard standing and therefore is only sparsely covered with grasses at a few points, which include some rushes and tall grasses along the Moonee Ponds Creek bank. The majority of the site is unvegetated and contains no shrubs or trees except immediately surrounding the electricity pylon base.
Drainage of the whole area, and of the completed elevated road, is conducted through underground drains, swales and pipes, and the construction of a pond (Pond Q) to accept run-off from the bridge. Drainage is directed to the Moonee Ponds Creek. Drainage by surface run off towards the Yarra River is limited due to the slope of the land towards Moonee Ponds Creek and the landscaping and construction for the area.
33 SOIL PROFILE
The understanding of the soil profile is based on the information from the Golder Phase 1 and 2 reports supplied, and from BHE’s logs and logs from the geotechnical investigation for the structures.
11 of 60 Environmental Audit Revision 2 Area 8, Elevated Roads, Western Link MCLA. Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 7
The northern land segment of Area 8 appears to be underlain by up to 6m of fill material relating to the infilling for development of the dockyard facilities located along the eastern bank of Moonee Ponds Creek. The fill overlies Quaternary age silty clays and silts with occasional sandy lenses comprising generally alluvial soils of the Moonee Ponds Creek floodplain. The shallow clayey alluvial soils merge with deposits of shelly silt, silty clay and some thin lenses of sand, gravel and clay of the Quaternary Coode Island Silt formation. At depth this appears to be underlain by similar clayey silts of the Fishermens Bend formation.
Some sandy and gravelly horizons have been reported by Golder at about 18 metres depth in some of the geotechnical boreholes as likely to belong to the Moray Street Gravel formation or underlying Tertiary sandy formations. The Silurian age Melbourne Formation siltstones or sandstones comprise the basement rocks in the area at around 40 to 50 metres depth as indicated by Golder. Geological maps of the area also indicate the presence of basalt at depth in the area to the east of the site, and have been encountered in some of the deeper boreholes in Area 9 to the south of Area 8.’ According to Neilson in the “Geology of Melbourne, in the Yarra estuary, this is most likely to belong to the Tertiary age Older Volcanics formation.
From the borehole logs and information reviewed, the fill appears to have been historically imported over a long period of time to build up the ground to above flood level on the east side of the creek and to provide level land adjacent to the diverted course of the Yarra River. The imported material includes a heterogeneous mixture of clay and sand that is likely to comprise reworked natural soils and dredged materials, together with an admixture of brick concrete and boulder rubble, and some pockets of charcoal, glass, ash, coke, wood slag and other wastes. A layer of bluestone was observed at 0.4m depth adjacent to Dudley Street. Fill encountered in the North Wharf boreholes in the Osaka Gardens, included gravel and sand with brick, sandstone blocks and cinders.
Fill in the creek floodplain comprised silty gravel and layers of imported siltstone, silty gravel and admixtures of ash and crushed rock. The shallow soil horizons in the creek floodplain comprise mainly alluvial silty clay as identified in boreholes and test pits along the edge of the creek.
Groundwater seepage was also encountered in some of the boreholes and test pits drilled in the creek flood plain area. Most test pits encountered either water or wet materials at shallow depth, and seepage was recorded in most pits at between 0.8 and 1.0 metres depth. Groundwater was encountered at a depth of 2.5m in the North Wharf fill material and at 1.5m in the fill north of Dudley Street in the information supplied from groundwater monitoring boreholes installed for the Docklands investigations.
3.4 CONTAMINATED FILLS
Fill occurs in the Moonee Ponds Creek embankment, the area north of Dudley Street, the land between Dudley Street and the Yarra River and North Wharf. The fill in the area of Moonee Ponds
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Creek is found to a depths of up to of about 0.5 to 1.0m and directly overlies silty to sandy alluvial clay horizons.
North of Dudley Street
A number of Golder and CMPS & F boreholes for the Docklands development were undertaken in the filled area between Dudley Street and the Moonee Ponds Creek. The boreholes ranged in depth from 3m to 10m with depth of fill ranging from 2.3 m to 7.lm. The fill materials are underlain by mainly silty clay with shell fragments representing the Yarra and Moonee Ponds Creek estuary natural alluvial soils, mostly comprising the typical Coode Island Silt. There is some potential for these silty clays to have acid sulphate generating properties.
The fill material consisted of sand, silt, clay and gravel mixtures with admixture of coke, slag, basaltic gravel, crushed rock and concrete and brick fragments and traces of broken glass. The fill is heterogeneous and the source for the fill has not clearly been identified by the site history. The fill has probably resulted from importing of material to for the docklands by Melbourne Port Authority since the late 1800s and may also include some dumping of refuse and waste material.
The fill material was sampled and analysed by Golder Associates/Woodward Clyde (WWC) and found to have concentrations of PAHs, metals (As, Cu, Cr, Pb, Hg, Zn), sulphates and hydrocarbons.
South of Dudley Street
The fill material between Dudley Street and the Yarra River comprises mainly sand with coke and slag. It is noted that it is suggested in Golder boreholes that the sand deposits potentially include foundry sand. No information provided regarding the site history indicates that foundry sand was likely to have been deposited in the area, and it is possible this is a natural sand or dredged material. The Port Melbourne Sand formation is known to overlie the Coode Island Silt in the estuary area south of the river, and the sands may also have been derived from local deposits of that formation.
The fill was also covered with a layer of bitumen and crushed rock with cement stabilisation. The fill ranges in depth from 1.7m to 3.5m and is underlain by natural silty clays of the Yarra River estuary. The fill material was also found to contain some basaltic gravel. Concentrations of potential contaminants identified in the fill material include PAHs, sulphates, metals (As, Ni, Zn) and TPHs.
North Wharf
The fill material in the North Wharf segment ranges in depth from 0.5 to 1.8m and consists of mixtures of gravel, sand and clay with admixtures of brick, sandstone blocks, cinders and slag. From testing of soil samples taken from these boreholes the main contaminants include PAHs and the metals arsenic, copper, nickel and zinc.
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Underlying Natural Silty Clays
From the results of the Golder and BHE assessments, the underlying natural clay below the fills in Area 8, except for some isolated point concentrations of metals, TPH or PAHs, appear to be generally uncontaminated. This tends to indicate that the contaminants in the overlying fills are also not particularly leachable as they do not appear to have migrated significantly into the natural soils.
3.5 HYDROGEOLOGY
The site lies in an area consisting of tidal flats and coastal estuarine sediments and is characterised by low relief and moderately poor drainage with a gentle gradient to the Moonee Ponds Creek. The Creek flows along the northern boundary of the area and into the Yarra River to the west of the site.
Rainfall is in the range 500 to 600 millimetres per year falling all year round.
Generally shallow groundwater levels related to the tidal Moonee Ponds Creek and sea level, were encountered north of Dudley Street as recorded in Golder’s and Woodward-Clyde boreholes and test pits. Groundwater was encountered within or at the base of the fill. It may also be anticipated that localised perched water tables may develop within the fill during periods of heavy rainfall.
In the area of the North Wharf groundwater was encountered in Connolly boreholes at a depth of 2.4m. The near surface lithology of Quaternary aged alluvium, comprises mostly silt, silty clay and sandy clay soils which would be anticipated to be of generally low permeability. Except for localised groundwater seepage in the overlying fills or in backfilled former channels of the Moonee Ponds Creek, the potential for groundwater aquifers with sufficient yield and quality of groundwater suitable for beneficial use, is considered to be limited.
The proximity of the Yarra estuary and the estuarine nature of the Moonee Ponds Creek in the area indicates that groundwater salinity will be such that potential beneficial uses are very limited. The Moray Street Gravels and underlying Tertiary sandy sediments, may contain some sand and gravel lenses that may have the potential for an acceptable yield, but are likely to be highly saline. If the Older Volcanics formation is present, there is also some potential for limited yield of poor quality. Both the Quaternary sediments and the Tertiary aquifers, would be at a minimum of 18 to 20 metres below the site and would be overlain by the Coode Island and Fishermens Bend Silts of low vertical permeability. The Siltstone basement would also not be anticipated to provide a significant aquifer.
From the information provided by BHE and Golder, and from the Golder/WWC information included in the BHE report, groundwater quality is anticipated to be generally saline in the Quaternary alluvial and estuarine sediments in the range 4,000 to 40,000rnglL TDS. The clayey layers would be anticipated to restrict flows and yields would generally be low. The quality of groundwater in the Coode Island Silt and underlying formations is also anticipated to be at the upper end of the range of salinity and also have a very low yield. Although there is potential for
14 of 60 Environmental Audit Revision 2 Area 8, Elevated Road, Western Link, MCLA, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Puge IO
significant yields in the underlying Moray Street Gravels and underlying Tertiary sediments and Volcanics if present, from elsewhere on the Docklands development, the groundwater in these deeper formations has also been found to be strongly saline with TDS’s approaching that of sea water.
From the information supplied, the direction of flow of the groundwater is likely to be generally westwards in the direction of flow of the Yarra River and locally north westwards to the Moonee Ponds Creek on the north side of Dudley Street, and south westwards on the south side of Dudley Street.
If shallow perched water tables occur in the deeper fills above the clays, some recharge with rainwater of low salinity may occur which would account for some of the lower salinities found in the Docklands analyses. However this is highly unlikely to be relevant as a potential source of groundwater supply. The main consideration is the potential for lateral migration of contaminants through the fill into the Moonee Ponds Creek from the various fills that remain on the site.
3.6 POTENTIAL HAZARDS AND CONTAMINANTS
From the history of the site, there is a range of potential contaminants that could be associated with the heterogeneous fill material present across the site and associated with the former PMA and Amalgamated Marine Engineers (AME) operations, the USTs and waste oil drum store area.
Solvents were anticipated associated with the workshops and paint shop in the PMA Maintenance Services, and Amalgamated Marine Engineering (AME)ship repairs building. Some 200 waste oil storage drums located adjacent to the AME building were removed from the site. Two grease traps were also present, forming part of the wash down area for the AME building.
Potential contaminants indicated in Area 8 from the site history could include:
0 TPH;
8 PAHs;
0 Chlorinated Solvents;
8 PCBs;
0 Metals, a wide range and in particular copper, arsenic, mercury, chromium, tin, lead and zinc; and
0 OC pesticides.
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Other contaminants linked to the industrial use of the site could include cyanides if used for metal treatment or from the fills, strong alkalies and acids from de-rusting, and a range of possible contaminants in the imported fill materials, possibly partly derived from gasworks wastes. Acid sulphate soils are also a potential hazard with the presence of the Coode Island Silt beneath the site.
The initial 1996 CMPS&F study included analysis.of samples for a limited general screen of metals (As, Cr, Cu, Hg, Ni, Pb, Sn, Zn), PAHs including benzo-a-pyrene and TPHs. Levels of contaminants from the results of the CMPS&F testing were either below the relevant ANZECC B guideline levels or less than three (3) times the B level.
From the Docklands Business Park investigation in 1997, a number of samples were analysed for a wide screen of potential contaminants including for the EPA priority list of chemicals for which tabulated test results were provided by the laboratories undertaking the analyses included in Volume 3 Appendix E of the BHE report. Non detects are not reported in the tables. The results relevant to this audit where chemicals were detected, are summarised in Table 3 of the BHE Land Status Report and include the chemicals detected.
Chemical screens were undertaken by GolderNWC for the 16 metals As, Ba, Be, Cd, Cr, Co, Cu, Hg, Mn, Mo, Ni, Pb, Sb, Se, Sn, Zn; for ammonia, fluoride, sulphate, PAHs, PCBs, total cyanide, total phenols, TPHs, BTEX and a limited screen of VOCs and chlorinated volatile compounds. Analysis was by two NATA accredited laboratories, AMDEL and NAL. A similar wide screen was undertaken on groundwater samples from the main part of the site. They also undertook TDS analyses to establish the salinity of the groundwater.
Golder Associates were also independently commissioned to carry out a Phase 1 and Phase 2 assessments for the proposed Freeway in 1996. The preliminary assessments by Golder were focussed on the potential location of contamination based on the site history together with a broad spectrum review of other possible contaminants by undertaking partial EPA screens on a few selected samples.
The Golder investigation included analysis of selected samples from the areas of fill north of Dudley Street (BH21 at 2-2.45m) for an EPA screen. The screen included 17 priority heavy metals (As,Ba, Be, Bo Cd, Cr, Co, Cu, Hg, Mn, Mo, Ni, Pb, Sb, Se, Sn & Zn), TPH, MAHs (BTEX),PCBs and PAHs, and a range of OC pesticides, chlorinated hydrocarbons, volatile halogenated organics, cyanide and sulphate. The remaining samples were analysed for a reduced screen of heavy metals, PAHs and for TPHs where indicated by screening of samples Analysis was by WSL, a NATA accredited laboratory.
Except for a few isolated point concentrations of metals and sulphate, no significant concentrations of contamination were detected in the soivfill material on the site during the Golder assessment in Area 8.
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Chemicals detected by Golder WWC in 1997 at significant concentrations in the fill materials included the metals Cr, Cu, Hg, Pb, Sn and Zn, sulphates, PAHs, & TPHs. The main organic contaminants found were PAHs, with concentrations for benzo-a-pyrene (BaP) up to 120mgkg in Golder/Woodward-Clyde borehole 244 and TPHs up to 12,900 mgkg from the same location. Some volatile and chlorinated volatile compounds were detected generally associated with high TPHs, but not at significant concentrations. The underlying natural soils are generally uncontaminated.
The pH was measured in the range 5.7 to 9.6 for the areas containing fill, and 4.1 to 8.0 for the creek sediments. The bulk of the soils and fills are within the range of probable background pH for the local soils analysed. The pH in the fill is within a moderate range indicating that significant sources of alkaline or acid material are relatively unlikely. The occasional low pHs of 4.1 to around 7 are linked to the saturated natural soils underlying the fills and appear to be of natural origin, possibly due to anaerobic conditions in the former swamp.
No significant contamination was found in the creek floodplain samples except for some isolated PAH, zinc and lead concentrations close to the boundary between the fill and the underlying natural material.
The BHE validation sampling from the pile cap excavations in both the fill and the creek areas, and for the North Wharf focussed on the range of metals and organic compounds found to be significant on the site from the original GolderWoodward-Clyde investigations. However, given the industrial nature of the fill material, some analysis was also included of selected samples for PCBs, and OC pesticides. Analysis was again by two NATA accredited laboratories, in this case AEL and NAL. The validation sampling generally confirmed the results of the initial assessment with a similar pattern of contamination of the fill materials.
TCLP analyses conducted by BHE on the more contaminated materials to assess their suitability for disposal off-site are also relevant to the material remaining in the areas of fill on the site. The TCLP concentrations from these samples were generally low or below detection limits. This indicates that leaching of metals from the soils at the concentrations present is not likely to be significant. However, some concentrations of metals were detected in the various groundwater analyses including detection of arsenic, chromium, copper, lead, mercury, nickel and zinc, as well as flourides, cyanides, PCBs PAHs and TPHs.
BHE also examined the acid sulphate potential of the excavated clay soils. The soil that was investigated and found to have some acid generation potential, was excavated and disposed as a Prescribed Waste.
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3.7 CONSTRUCTION WORK AND REMEDIATION ACTIVITIES
Construction activities in Area 8 have included:
0 Piling and excavation for construction of pile caps and piers to support the elevated road superstructure.
0 Construction of the Central Island with crushed rock for protection of the Central Yarra Bridge piers.
0 Temporary works for access by plant and equipment along the Moonee Ponds Creek.
Demolition of the former Police Building and some small sheds.
0 Minor earthworks and construction of the Electric Tolling and Ticketing Machine (ETTM) shelter.
0 Construction of three temporary jetties extending out from the east and west banks of the creek to allow access for piling and construction equipment.
0 establishment and removal of drying beds along the south side of Moonee Ponds Creek to receive saturated sediments excavated from the pile caps in the creek bed.
0 Landscaping including excavation and lining with clay, soil and jute matt of Pond Q.
0 Construction of the stormwater infrastructure.
Other activities have included the removal off-site of contaminated soils excavated from pile caps and from the lower soil layers at Osaka Gardens (North Wharf); and the removal of soils from the landscaped areas (where the excavated soils were identified as surplus to requirements). Remediation activities on the site have therefore included:
0 Excavation, segregation, temporary stockpiling and appropriate disposal off-site to
Brooklyn Landfill of 153 m’ of soil classified as “ Low Level Contaminated” from the site due to limited stockpile space.
Removal of contaminated soils (approximately 640 m’) as “Prescribed Waste” from pile caps K1, S83, N84 and JO to Cleanaway Landfill.
0 Removal of sediment from the drying bed as “Low Level” or “Prescribed Waste” material.
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0 Disposal of potentially acid sulphate soils as “Prescribed Waste”.
0 Draining of the underground storage tanks, excavation and backfilling of associated packing sand from 4 locations.
Excavation of further contaminated soils by BHE in relation to removal of the USTs, (1 from Osaka Gardens, and 3 from adjacent to Pile cap N88).
Removal of 188 waste oil drums from the rear of the AME building adjacent to Moonee Ponds Creek.
0 Removal of TPH and PAH contaminated soil from the Pond Q excavation as “Prescribed Waste”.
Other activities included:
0 Stockpiling, sampling and classification of excavated soils;
0 Disposal off-site of surplus soils from the creek floodplain, where classified as “fill material”, for use on other parts of the Western Link Project; and
0 Removal and disposal of “fill material” classified soils unsuitable for use on the site.
As the interceptor traps for grease related to continuing activities in the industrial buildings remaining adjacent to the site were not directly affecting the construction works they were not decommissioned.
As indicated by the Audit of the transport tracking system and by the documentation included in Appendix K of the attached BHE report, excavated material stockpiled and classified as “Prescribed Wastes” andor “Low Level contaminated materials” was disposed off-site in accordance with EPA Bulletin 448 to appropriate licensed facilities. Audit of the tracking system confmed that use of soils as fill on-site included some material that could be classified as Low Level Contaminated in some of the pile cap excavations as indicated in the BHE report. However, general fill in the top 300mm or so, was also confmed to soils classified as “fill material”. A full description of the audit of the tracking system is described in Appendix K and the Audit is discussed in this report below.
Construction materials classified for structural use were also imported to the site for the construction of rock batters and mattresses and the Yarra Bridge Central Island, as well as for topsoiling on the exposed fill batters. This has also had the beneficial effect of reducing the potential for exposure of contaminated fill at the creek banks.
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3.8 POTENTIAL PATHWAYS FOR MIGRATION OF CONTAMINANTS
The pathways for migration of any potentially mobile contaminants in clay soil materials to groundwater is considered to be largely constrained by:
0 The low permeability of the natural silty clay sub-soil horizons in the creek floodplain and beneath the fills.
0 The low mobility of the main contaminants anticipated for the metals, and the PAHs, and as indicated by the elutriation tests carried out on metals from the fills.
Restricted infiltration from rainfall because of high annual evapotranspiration potential, some partial coverage of the eastern part of the area by roads, car parking and concrete slabs; coverage by the freeway superstructure, and the improvement of surface drainage included in the landscaping for the freeway.
0 The length of the flow path to groundwater aquifers.
0 The tendency of the natural clays to encourage absorption of mobile chemicals.
There remains some potential for lateral migration of petroleum hydrocarbon, in particular from the areas off site including the AME building or fill adjacent to the site, through the fill material in the direction of the Moonee Ponds Creek and the Yarra River. Some migration of hydrocarbons from the site itself is possible.
Groundwater information from monitoring boreholes placed during the Golder/Woodward-Clyde investigation indicates that PAH and metal contamination exceeding the SEPP for the Yarra Segment, and exceeding ANZECC ecosystem protection guidelines exists in the groundwater adjacent to Moonee Ponds Creek. Petroleum hydrocarbon concentrations also are at levels slightly above Dutch Intervention guidelines.
There therefore remains some potential for hydrocarbon contamination in the groundwater beneath the site to migrate into Moonee Ponds Creek. However, this potential is mitigated by:
0 The covering of much of the site area by asphalt and hard standing areas with surface drainage facilities;
0 Reduced infiltration due to cover by the elevated road structure;
0 Removal of significant potential sources of contamination including the waste oil drums and USTs; and
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0 Removal of a significant proportion of the contaminated soils.
This must also be reviewed in the context of the quality of the Moonee Ponds Creek. No visible evidence of oil sheens was noted on the surface of the creek adjacent to the site, other than flowing from upstream of the site, indicating that significant hydrocarbon contamination migration is unlikely to be occurring. Groundwater data for the Moonee Ponds Creek from samples taken from the Jetties located in Area 7 also indicated petroleum hydrocarbons present in the Creek. This is reviewed and reported in the Audit report for Area 7 in progress.
The significance of the groundwater contamination detected is discussed further below in the section on Ecological Risks.
Available results of groundwater monitoring are summarised by BHE in Table 7 of the Land Status Report.
3.9 ACCEPTANCE CRITERIA
The primary foci of the remediation program with regard to the contamination detected on the site were the identification of suitable management options for the excavated materials and the reduction of opportunities for exposure to contaminated material by replacement with more suitable soils. This was achieved by:
0 Excavation of the contaminated fills where required for development purposes, including for the pile caps, Pond Q, the UST removal, and the removal of the soils excavated for landscaping purposes or to install pile caps.
0 Segregation and removal of the contaminated material and replacement with more suitable imported or recycled material.
The formulation of target criteria and assessment of performance was by liaison between BHE and the Auditor throughout the environmental management process, with reference to performance criteria guidelines established by the previous Auditor, and by inspection of the site and review of the validation test results as work proceeded.
Some management of contaminated soils was undertaken during the construction of the elevated road on the site, in the areas north and south of Dudley Street, and in the Moonee Ponds Creek floodplain. The management objective was to leave the completed site within the audited area in a condition “no worse” than when the contract started, and to demonstrate that the performance criteria appropriate to the intended land uses are satisfied.
In this case, the performance criteria would be linked to the final end use of this part of the project site which would be for the MCLA Licence Freeway Reserve and for the existing Public Purpose,
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Port of Melbourne Authority, which encompasses the existing industrial activities that continue on and adjacent to the site in the Port Facilities buildings. There is no proposal to make the area Public Open Space and therefore this has not been considered in this audit. The general public may in future have limited access to the fringes of the area in relation to the development of Precincts of the Docklands Authority area for Mixed Use (which could include residential). This has not been considered as part of this audit. Currently the only fence in place to restrict access to the site is along the boundary with Dudley Street.
The performance criteria proposed by the previous Auditor were indicated to be threshold criteria as a guide to management of soils on the site. Where appropriate, these threshold criteria have been supplemented with reference to human health risk based criteria, as proposed by the National Environmental Health Forum, which are considered to be relevant to the final end uses of the audited site, provided that environmental risks are also acceptable.
3.10 VALIDATION PROGRAM
BHE has undertaken an extensive performance validation program throughout the development period, covering all excavated, stockpiled and re-used soils at sufficient frequency to provide confidence that all soil units remaining on the site, and exported from the site, have been adequately characterised.
In this case, the validation testing is largely based on the in-situ testing carried out on the soils prior to excavation for the pile caps and for the ramps, and from the sampling in the creek flood plain and on the investigations undertaken in parts of the area for the future Docklands developments.
The regular spacing of the pile caps and other samples provides a good overall coverage along the freeway envelope and therefore much of the material that remains in place between the pile caps is considered to be also adequately represented by these analyses. Where necessary, additional sampling was carried out to validate areas of excavation during the redevelopment period, both by BHE for management purposes and at the request of the Auditor. Validation sampling was also undertaken on the UST excavations.
Laboratory analysis indicated that the stockpiled soil from the UST excavations did not exceed EPA “Fill Material” criteria apart from an isolated result for lead. The soil around the tank removed from Osaka Gardens at North Wharf, appears to have been uncontaminated as the tank was intact and concrete casing was in place around the tank. The UST excavations were backfilled with crushed rock imported from commercial quarries.
All of the material on the site collected during excavation was extensively investigated by BHE in depth before stockpiling to identify and allow segregation of the heavily contaminated material when excavated and reviewed for either disposal off-site or appropriate management. Stockpiles were also sampled to confirm classifications before removal from the site. The validation program was
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generally limited by BHE to those analytes that were considered the key marker contaminants and of main concern on the site as indicated in the phase 1 and 2 investigations by Golder, and by reference to the CMPS&F, Golder and Woodward-Clyde Docklands assessments.
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4. HUMAN AND ENVIRONMENTAL RECEPTORS
4.1 GENERAL
The Western Link Project site has been sub-divided into a number of similar units bounded by roads and further sub-divided as characterised by its history or geographic position. Area 8 is characterised as generally industrial land used by the Port of Melbourne Authority, and no residential, Open Space, or other sensitive uses are relevant to this part of the site.
The creek reserve portion of the site is also currently zoned under the Port of Melbourne for Port Purposes and parts are now licensed for occupation for the Freeway Reserve by MCLA. From the maps and plans provided, it appears that there is no intention for the property to be re-zoned to more sensitive uses whilst remaining a part of the MCLA reserve. No consideration has been made of possible re-zoning of land surplus to the freeway envelope, however it is possible that some of the land on the eastern side of the creek, temporarily occupied for the project, may become in the future re zoned for industriaVcommercia1use and possibly also be incorporated into the adjacent Docklands Precincts as "Mixed Use".
Contamination of soil and groundwater can present a number of potential hazards both on-site and off-site. The approach used to assess these hazards is the "source-pathway-receptor" model. That is, the hazard presented by a source of contamination can impact on a receptor (people, animals, plants, etc.) via one or more pathways. The commonest receptors are:
0 Humans living, working, or recreating on or near a contaminated site (or remotely in the case of indirect exposure to contaminants);
0 Plants grown on the site or in the wider ecosystem; and
0 Animals (pets, other domestic species, or animals in the food chain of an affected ecosystem.
Another potential impact of contamination which is not a hazard, but which can be just as critical in restricting land use is aesthetic impairment (smell, sight etc). The Auditor also takes into account the potential for impacts on engineered structures (particularly building foundations) from chemicals that may remain in the soil.
An assessment of the contamination hazards and risks at this site could involve an assessment of all of the above factors. In assessing the level of risk that is incurred from the presence of any remaining contaminants in the soil of this site, human health risks are of significance given the location of the site in and area occupied in part for Port industrial purposes, and now licensed for the Freeway. However, potential ecological risks with regard to migration of contaminants have also been considered as a significant risk.
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In assessing potential exposure routes, it has been considered that a substantial part of the site occupied for the roadway is now covered by the pile caps, piers and associated structures themselves, or by landscaped areas and in the former industrial areas, associated floor slabs, car parking and asphalting. Therefore, the available area for potential exposure to underlying soils is reduced.
Similarly, the added contribution to surface and groundwater contamination of the region from this site is considered likely to have been substantially reduced by the earthworks undertaken, the presence of the freeway structure reducing infiltration, and the completed landscaping and improvement of stormwater management which will also reduce infiltration and potential mobilisation of chemicals that have been detected.
Potential pathways for hazards to human receptors from contaminated sites include:
e Ingestion of contaminated soil by adults;
e Ingestion of contaminated groundwater;
Inhalation of vapours from the site;
e Inhalation of contaminated dusts; and
e Dermal contact with contaminated soil, surface water or groundwater.
The source of the contamination, in this case the metals, TPH, and PAH contaminants remaining in fill soils at shallow depth within the freeway envelope, and adjacent Port of Melboume Authority land, should also be assessed in terms of its toxicity to the potential receptors in terms of a toxic dose or a tolerable daily intake (TDI).
The data provided by BHE and confiied by review of available sources, indicates that these contaminants are likely to be in forms with moderate toxicity and low mobility and are not likely to be exposed during use of the Creek reserve and adjacent industrial areas. The TPHs are also longer chain hydrocarbons with low volatility and relatively low mobility. The main hazard is likely to be encountered if the contaminated fills in the areas north and south of Dudley Street are re-exposed during any future maintenance or development works and exposure would then be due to ingestion, inhalation, and skin contact. Soils encapsulated under the Freeway pile caps and ElTM machine are not considered likely to be re-exposed.
In review of the quantity of information available for this part of the site, it is considered there is sufficient validation data available for the key contaminants for statistical treatment of the results for the areas of fill materials. Therefore, the 95% Upper Confidence Level (UCL) of the average concentration has been used to assess the significance of the remaining concentrations of contaminants in the soils.
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The 95% UCL is generally a more useful figure in this context for the assessment of environmental risks than either point concentrations or a straight arithmetic average. It is considered that the 95% UCL tends to give a figure that is more representative of the site as a whole, without giving too much or too little weight to random isolated point concentrations. The Auditor has also reviewed the calculations of the 95% UCL indicated in the BHE report and found them to be reasonable for the areas of the site indicated.
The North Wharf segment has not been treated statistically by the Auditor as the natural soils have been covered extensively by crushed rock classifiable as “Fill Material” placed during the construction program and therefore re-exposure to underlying soils is unlikely.
4.2 HUMAN RECEPTORS
BHE has requested the performance of a Statutory Environmental Audit in terms of the completed development for beneficial uses appropriate to the site. In this case, a limited use is proposed for the Creek Reserve that does not include the presence of the general public, and the categories of people who may therefore be exposed to the soils at the site would include: e Adult landscape, utility or construction workers involved in excavations of soils for landscaping or maintenance works during operation of the freeway.
Adult workers on land occupied for the project and potentially to continue for industrial use.
As this audit is undertaken at the end of a project where the health & safety of employees has been closely controlled, the potential for exposure of workers on the project has already been reviewed in the management plans and is not considered further here.
No exposure in a residential or public open space scenario has been considered as it is not relevant to the zoning. If more sensitive uses are planned for parts of the site in the future, such that it is rezoned wholly or in part to residential, the environmental quality of the re-zoned segment must be considered at that time and in that context and cannot be anticipated by this audit. The potential for exposure of industrial workers on some parts of the site occupied for the project, is considered in the same context as being no greater risk than for landscape or port workers on the adjacent segments of the MCLA licensed Road Reserve.
43 ECOLOGICAL RECEPTORS
The primary ecological receptors of interest at this site are anticipated to be plants that have their roots in or uptake nutrients from the soils and are established in the Creek Reserve for landscaping. Other potential receptors may include the fauna and flora of the Moonee Ponds Creek that passes
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through the site and the estuary of the Yarra River. This however, must also be judged in the context of the overall quality of the Moonee Ponds Creek and Yarra Estuary ecosystem.
The potential for off-site exposure of ecological receptors due to run-off fiom the site or groundwater contamination is generally considered to be somewhat limited for the reasons listed in Section 3 above. Temporary measures were also undertaken during the performance of the contract in accordance with the EPA Publication 480 “Environmental Guidelines for Major Construction Sites” December 1995, to limit the potential for contamination to reach the creek. This included installation of silt fences and frequent monitoring of water quality by BHE, and visual inspection by the Auditor.
The overall level of soil contamination has also been substantially reduced by the works performed. Sources of contamination including USTs and other storage areas were removed and potentially contaminated soils adjacent to the creek were removed during site works as indicated in the information included in Section 4 and Appendix G of the BHE report.
There may remain some potential for the remaining industrial properties that are outside the area covered by this Audit, hydrogeologically upgradient and outside of the control of BHE, to be a source of some contaminants that would be migrating westwards into the site. This may need to be considered by the owners of these properties. However, in terms of the relevant SEPPs and Auditor guidelines, this is considered not likely to be an issue for the audited part of the site as the monitoring and validation results indicated a low risk of significant contamination reaching the creek sediments sourced from within the audited areas.
There remains a potential for contaminated groundwater to migrate through the site to the Moonee Ponds Creek.
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5. EXPOSURE TO CONTAMINANTS
5.1 EXPOSURE POINT CONCENTRATIONS
The data in the BHE and Golder reports has been segregated into a number of separate segments. Review of the data groups indicates that significant contamination remains on the site in the segments north of Dudley Street and south of Dudley Street and in the creek floodplain sediments, whilst the North Wharf area is, on balance, relatively uncontaminated. The Auditor has independently reviewed the data available that is relevant to each of these segments separately in order to make an assessment of the risks posed by any remaining contamination.
In the filled portions of the site, the concentrations for those analytes tested generally exceed ANZECC threshold investigation criteria. However, if removed from the site and disposed to landfill, these materials would also in most cases be classified as a Low Level Contaminated Soil in terms of the Victorian EPA contaminated soil criteria set out in Information Bulletin 448.
Where statistical treatment of the results provided by BHE is valid for the key contaminants on the site, the 95% UCL of the average values for those contaminants are generally within criteria that would also define the material as “low level contaminated” and with reference to the risk based National Environmental Health Forum (NEHF) proposed health investigation levels (HILs), would also generally be acceptable for a public open space use or industrial uses. As public access to the area is not available from the elevated roads (there is no shared pathway present in this area), the relevant continuing beneficial use would be industrial.
In a number of cases, samples analysed during validation testing of soil materials that remain on the audited part of the site at the end of the development process, exceed NEHF threshold health investigation criteria for open space and in some cases industrial use. However, they are mostly either encapsulated by the construction of pond areas, the asphalt and concrete surfaces on parts of the site and for roads, partly by the pile caps or beneath gravel hard stand areas. Some contamination may also remain at depth within the fill or beneath slabs of the industrial buildings, where it is unlikely to become re-exposed accidentally.
Contaminant concentrations as indicated by the test results representing final condition of the site and reported by BHE are reviewed separately below for each portion of the site.
Table 2a in the BHE report summarises the available test results on samples taken by BHE from the creek floodplain crossing, for the Freeway envelope and for the pile caps, and for the adjacent areas of fill within the former industrial areas to the north and south of Dudley Street. This is supported by the initial testing by CMPS&F, Golder and Woodward-Clyde, for which the results are also reported in Tables 3, and 4 of the BHE Land Status Report. These results are therefore also representative of the unexcavated fill and natural materials that remain on the site following the excavation and are thus relevant to the final condition of the site.
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The figures reported in the tables were satisfactorily correlated by the Auditor with the test certificates supplied. Correspondence and updated information relating to the review of the supplied information is contained in Appendix B of this Audit Report.
BHE’s Table 6 presents a statistical summary of all relevant analyses for the filled industrial areas within the Moonee Ponds Creek reserve, to the North of Dudley Street and to the South of Dudley Street as delineated in Figure 3 of the Land Status Report. Therefore, because of the replacement of a proportion of these soils with the imported road fill and pile cap backfill, and by crushed rock for scour protection in some areas, these results must be considered a conservative upper limit for assessing the final condition of the site.
The Auditor has also extensively reviewed the segregation of the test results in Table 6 into the three segments, and has completed an independent statistical analysis for each of the segments represented by each group of results. The Audit has examined the peak concentrations recorded in the certificates supplied, and also the 95% UCL reported by BHE for the key contaminants and has found that the figures reported are generally representative of each segment of the site as delineated by BHE. The statistical analyses reported in these tables did not include results fiom the materials excavated fiom the North Wharf as this area has been covered with imported fill or contaminant concentrations fiom this area were below ANZECC investigation thresholds. In this case the peak concentrations relevant to that area have been reviewed.
The results of analyses on backfill materials imported to the site to refill around pile cap bases and to provide general backfill for other parts of the site, were characterised in general and presented in Appendix E of BHE’s Area 2 land status report. This has been previously reviewed for the Western Link audit and was discussed in the Area 2 Audit Report. The imported material was also physically identifiable on site during inspections as a light coloured weathered siltstone material, quite different in appearance to the pre-existing fill.
The tests on excavated packing materials and the remaining adjacent soils in the UST excavations, are summarised in Appendix G of the BHE report.
Table 1 summarises the statistical review by the Auditor undertaken for the most significant contaminants remaining on the site in the Creek Sediments and in the industrial areas north and south of Dudley Street, as indicated with regard to peak concentrations.
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Table 1 Summary of Area 8 Contamination UCL 95% Values and Maximum Detects
Fill South of Dudley
Maximum detect location: Maximum detects:
Fill North of Dudley
maximum detect location: 244 I Maximum detects: 71 1300 5200 5100 13600 120 1772
Moonee Ponds Creek
Maximum detect location: Maximum detects:
= indicates calculation not valid due to insufficient data
5.1.1 Creek Area
Thirty three (33) samples, were referenced to define the contaminant concentrations of the Moonee , Ponds Creek Sediments encountered in the pile excavations. Table 1 indicates peak and average concentrations for the Creek floodplain sediments. The concentrations of most of the metals detected appear to represent background levels. Similarly the concentrations of cyanides and phenols are not significant indicating that gross contamination by Gasworks wastes is also unlikely.
Zinc, lead and copper are also present in the sediments, but at relatively modest concentrations. The 95% UCLs calculated for the metal contaminants that exceed ANZECC threshold environmental investigation criteria, are also generally well within NEHF public open space criteria and therefore are not a health issue on this part of the site where opportunities for exposure are limited.
The peak concentration of benzo-a-pyrene (BaP) in the sediments of 35mgikg is more 7 times the NEW industrial threshold, whilst the UCL 95% for BaP is about 3 tipes the industrial threshold. However, this generally relates to sediments that remain submerged in the creek, which are not readily accessible in this part of the site and not part of the Land.
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The other significant contaminants detected in the creek segment are the petroleum hydrocarbons with a peak concentration of TPH in the C10 to C36 range up to 6,800mgkg. The UCL 95% for the longer chain hydrocarbons is however, less than three times the threshold value for “Fill Material” and they would be classified as Low Level Contaminated on that basis.
Due to the significant levels of PAHs and in particular, benzo-a-pyrene in the creek sediments, the creek segment is considered to be unacceptable for public open space or recreational use and are also unacceptable if the sediments are exposed during any industrial use. However, in their current location this is unlikely to be a health risk for ongoing use of the site for industrial purposes.
Great care was taken not to allow sediments to be disturbed during the development by use of caissons within which pile caps were constructed, and by the management of the wet sediments on land after excavation, before appropriate disposal. This will also have to be taken into account by any future developers of the site. As there is currently no public access to the creek from the elevated road or from a path, the Auditor does not consider this a health issue in terms of the use by the Western Link road reserve.
The overall condition of the creek sediments in Area 8 is significantly worse than for the creek reserve in areas upstream from Arden Street. This may be due to the use of the areas immediately north of Area 8 for industrial purposes and as landfills, and may be partly due to deposition of sediments and associated contaminants as the creek widens and interacts with the saline waters of the Yarra Estuary causing flocculation of the clays in suspension.
Significant sulphate levels and lower pHs, appear to correlate with the increasing presence of Coode Island Silt formation which is potentially a source of oxidisable sulphur, but also could be related to material leached or washed off landfills upstream.
5.1.2 Filled Area North of Dudley Street
The filled areas north of Dudley Street presently have limited access by Port Authority workers and the employees at AME. Up to one hundred and sixty samples (160) are available to characterise the material underlying these filled areas at shallow depth from a variety of sources. Significant peak concentrations have been detected for the same range of contaminants as discussed above and summarised in Table 1.
Although some peak concentrations exceed the guideline, the 95% UCL values for the metals mostly fall within ANZECC B investigation thresholds and all 95% UCL values for metals fall within the NEHF guideline values for public open space and industrial. Similarly The 95% UCL value for cyanide is above ANZECC B but well within NEHF open space guidelines.
The value for sulphate is above ANZECC background levels but is likely to be related to the natural oxidisable sulphur levels in the Coode Island Silt that underlies much of the fill. The 95% UCL for
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As with the creek segment, peak concentrations of PAHs, and in particular benzo-a-pyrene ‘exceed criteria at some locations with concentrations of BaP up to 120mgkg at A9C in Pond Q where it is associated with a concentration of TPH of 7,600mgkg. The UCL 95% values for BaP are also above NEHF guidelines for open space and industrial use. TPHs detected are again in the > C9 range with a peak concentration exceeding Low Level contamination. But the UCL 95% value is calculated as 2222mgkg, which is well within low level criteria and therefore the contamination represents only isolated pockets remaining in the fills. Sulphate concentrations of up to 9,000mgkg were also detected in the fill material, indicating that some precaution regarding concrete protection from acidic ground conditions may be relevant.
The 95% UCL for benzo-a-pyrene of about 15 mgkg, and for total PAHs of about 186 mgkg, exceed health investigation criteria, although total PAHs remain within the “Low Level Contaminated Soil” (LLCS) maximum of 200mgkg. As the BaP concentration exceeds the risk based HILs for industrial and public open space it is therefore examined in more detail below in assessing the health risks on the site.
Some peak values also substantially exceed the criteria by more than 10 times in some cases. For example, the single point concentration of 120mgkg of BaP from borehole 244. This seems to reflect the heterogenous nature of the fill material.
The underlying clayey sediments appear largely uncontaminated.
5.13 Filled Areas to South of Dudley Street.
The filled areas to the south of Dudley Street could be considered to have limited potential general public access, but would not be defined as public open space. The wharf areas are mainly of industrial use.
The 95% UCL values for most of the metals are below ANZECC B investigation thresholds, but only arsenic (58mgkg) and tin (64mgkg) exceed EPA fill material criteria. The 95% UCL for total TPHs >C9 (approx 629mgkg) falls within EPA fill material criteria. Apart from sulphate and PAHs, the 95% UCLs for this segment remain within relevant EPA LLCS criteria and NEW thresholds for public open space, and are therefore considered to be acceptable for industrial land use on this basis.
The 95% UCL for benzo-a-pyrene of about 13 mgkg, and for total PAHs of about 277 mgkg, exceed threshold investigation criteria, and the PAH value exceeds the LLCS maximum of 200mgkg. The BaP concentration exceeds the risk based HILs for public open space and the HIL value for industrial land use of 5mgkg and is therefore also considered to be an issue on this segment.
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It is considered that the replacement of a proportion of the contaminated fill soils with imported “fill material” for pile caps and for some limited landscaping and drainage works, would have slightly reduced the overall level of contamination. The peak concentrations reported for the areas north and south of Dudley Street therefore represent a conservative upper limit when assessing potential exposure risks.
There are therefore some fill soil materials that remain on the audited part of the site at the end of the development process, that exceed health investigation criteria for industrial or open space use. They are currently either encapsulated beneath existing hard standing areas, floor slabs and asphalt and located within the Port of Melbourne land, where there is little risk of access by the public, or they remain at depth beneath the filled areas where they are unlikely to become re-exposed accidentally and are considered in that context.
5.1.4 Central Bridge Pier Area.
Very little information has been provided for the Central Bridge pier area, or adjacent Osaka GardendNorth Wharf area, except for some limited analyses for a few metals, and the validation sampling for the removal of the UST, summarised in the Connolly Environmental report dated July 1996, included in Appendix G of the BHE report. Maximum concentration of TPH X9was in the recycled sand at 205mg/kg, well within Fill Material Criteria. BTEX and lead concentrations were considered to be negligible.
Copper, lead and zinc were at background levels and arsenic was found to have a peak concentration of 1 1 5mgkg from 18 analyses.
The UST in the Osaka Gardens areas had been contained within a concrete tank and was in good condition and does not appear to have caused any significant contamination. As the major work on the site, as confiied by inspection by the Auditor, was also to import and place a large volume of crushed rock to create an artificial island to protect the bridge piers, it was therefore considered that there was not likely to be any outstanding issues of concern to the Auditor. Accordingly no further analyses have been requested.
5.2 EXPOSURE DURATIONS AND DOSES
The exposure duration for all categories of human receptors in a public open space or industrial setting will be much less than for a low density residential setting. The total duration of exposure to surface soils in a residential setting with garden area can be assessed at potentially 84,000 hours (ie 8 hours per day, 7 days per week, 50 weeks per year for 70 years), although Langley has indicated that 30 years is a more likely time period based on actual population studies.
The opportunities for exposure of the public that may visit the site would be substantially reduced due to the reduced hours of potential exposure, being only one or two days per week and for a few
33 of 60 EnvironmentaI Audit Revision 2 Area 8, EIevated Roadr. Western Link MCLA, Victoria I8 March I999 for Baulderstone Hornibrook Engineering Pty Ltd Page 29 hours only at most. It will also be reduced due to the proportion of the site that is covered by soils of acceptable quality and also the coverage of parts of the site by pile caps, imported soils, by existing hard stand areas, roads, and the imported crushed rock for scour and collision protection, thus giving few opportunities for direct exposure to contaminated soils. Access to the more contaminated industrial areas on the north side of Dudley Street is not likely to be an issue for the general public unless access conditions are changed in the future by the Dockland Development.
This can be assessed as substantially eliminating opportunities for exposure to children in sensitive age groups (1-5 years) and reducing exposure to older children and adult visitors or workers on the site.
Where contaminants are present in the fills soils and sediments, the activities which might generate exposure would, where necessary, involve precautions which would limit:
0 Ingestion of soil to very small amounts by utility maintenance staff and landscape workers (by performance of adequate personal hygiene); and
0 Absorption of chemicals to limited areas of the body, say hands, forearms, neck and face by utility workers and landscape staff (by use of protective clothing if exposure is feasible).
In continuing post construction activities, there is therefore potential for exposure to the remaining contaminated fill soils located in the Freeway envelope, such as in future landscaping, minor construction activities or maintenance work including installation or repair of services, or where land continues to be used by personnel of the local industries for parking or other activities.
With any such activities, workers on the site may face exposure to the soils for a limited average number of days of, say, at most one day per week over a few months or a number of consecutive days over a shorter period when the soils are exposed
Inhalation has not been considered in this context as all of the contaminants detected have low volatility and no substantial pockets or areas of volatile organic compounds were detected.
The worst case exposure is therefore likely to be during any future maintenance work as soils may be exposed for construction of services and utilities over limited periods of up to say 2 months, which could be assessed at potentially 360 hours (8 hours per day, 5 days per week for 9 weeks). This is more than 2 orders of magnitude less than for a residential setting.
Potential exposure of workers may therefore be an issue in the Dudley Street port areas. However this should be seen in the context of the industrial operations in the remaining buildings on the site and the affected portion is also currently partly covered with asphalt, roads, floor slabs, gravel hard stands etc, thus partly isolating the workers from possible exposure.
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6. RISK EVALUATION
6.1 HUMANHEALTH
It is considered that a formal health risk assessmentfor a normal residential setting would generate acceptable concentrations of potential contaminants that are similar to or greater than the limiting values for health investigation criteria indicated in the ANZECC guidelines of January 1992, or, where appropriate, the limiting values for "Fill Material" as defined in the EPA Bulletin Publication No 448 on "Classification of Wastes" dated September 1995.
For a Public Open Space or Industrial Use setting, if a formal health risk assessment were to be conducted for the site, the exposure potential for maintenance workers or utility workers on the site in the future after completion of the main development is likely to be more than two orders of magnitude less than for the residential case. Therefore, satisfaction of criteria similar to EPA low level contaminated soil criteria as target criteria for the site for 95% UCL concentrations is considered to be conservative.
This argument is supported by risk based investigation levels that have been developed by the National Environmental Health Forum (NEHF) E & F levels for a typical public open space and industrial scenarios, which are based on a much reduced exposure potential for adults and children as compared to a residential case, and in the industrial case, the elimination of opportunities for exposure of young children.
The available data reviewed in the BHE report and previous CMPS & F, Golder and Woodward- Clyde reports, although limited to some extent, suggests that the bulk of the fill soils remaining on the site would be classified as Low Level Contaminated and therefore would generally fall within target criteria considered acceptable for public open space or industrial use. Some exposure point concentrations for this site do exceed the above mentioned criteria in a few cases for the individual chemicals tested. Whilst some point concentrations exceed the criteria by more than ten times, validation testing has however indicated that the 95% UCLs of the relevant average values are generally well within the target criteria for public open space, or industrial use.
Where there remain exceedences in relation to the target criteria, for example the occurrences of BaP in the fills and heavy end petroleum hydrocarbons remaining on the site, the resulting opportunities for exposure of local residents, workers or visitors to the site has been considerably reduced by physical barriers, such as the asphalt surfaces, the imported siltstone fills, imported crushed rock, hard standing areas, the pile caps and by some associated landscaping, and jute matting and topsoiling of the stormwater pond.
A concern remaining on the site is the presence in the underlying heterogenous fill of some significant concentrations of metals, TPHs and PAHs. The potential for future contact with these fill soils needs to be recognised in any future development on the site with appropriate Occupational
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Health and Safety precautions implemented in accordance with relevant EPA and OH&S regulations and standards. In particular, the presence of significant levels of PAH and TPH contamination on the filled areas north and south of Dudley Street should be identified on drawings and brought to the attention of relevant authorities, the EPA and the Melbourne City Council. This area forms the bulk of the site and cannot practically be separated from the remainder of Area 8. It must also be noted that industrial activities are continuing in the adjacent buildings indicated in this report, and may be contributing to contamination that may be migrating onto the site.
Provided that the physical barriers and precautions described above remain in place and are taken into account during any maintenance work, and where necessary re-instated after maintenance work, it is considered that the risks to human health from the chemicals remaining on the main part of the site are acceptable.
With regard to the filled areas north and south of Dudley Street, the health risks are also considered to be currently acceptable, provided that the existing surface coverings remains intact and the soiVfill material is not disturbed, and provided that it is not rezoned for a more sensitive use, such as Public Open Space, without undergoing further assessment and/or remediation appropriate to the proposed end use. It is unlikely to be suitable for the mixed use proposed for the Docklands Business Park Precinct without remediation.
6.2 ENVJRONMENTALRISK
On the basis of the extensive pre-excavation testing, as supported by visual identification and segregation of potentially contaminated material during the excavation works, a proportion of the contaminated material exposed in the works has been removed from the site. The validation testing indicates with a high degree of confidence, that the concentrations of chemicals remaining in the shallow fill soils that remain accessible on the site are within the range such that they would be generally classified as “low level contaminated soil”.
It is feasible that the remaining chemicals in the soil could also be harmful to plants that would be largely rooted in shallow soils, however, the use of imported topsoils in the landscaped areas should alleviate this possibility.
As indicated above, the reduced area of the site open to rainfall infiltration by coverage with the Freeway, has also reduced the potential for mobilisation of the remaining contamination. TCLP analyses on a number of samples from the site, summarised in Table 5 of the BHE report, have generally indicated that the main metal contaminants detected in the fill soils on the site are not particularly leachable, with only one sample of lead slightly exceeding the low level soil disposal TCLP criteria. Whilst these analyses were not all conducted on the samples with the peak concentrations of the metals analysed, the concentrations of the metals in the soils analysed do substantially exceed the 95% UCL average values calculated for those metals on the site, and are therefore considered to represent a more conservative consideration.
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The TCLP analyses have therefore indicated that most of the metal contamination is not anticipated to be significantly mobile. This was largely confirmed as very little evidence of past leaching and migration of metals was detected in the groundwater monitoring. Zinc was detected at a concentration of 90 ug/L exceeding the ANZECC guideline for Protection of Aquatic Ecosystems of SOU@ in one bore adjacent to the Creek. A lead concentration of 150 ug/L found in BHE’s water sample from pile cap N88 exceeded the ANZECC guideline value of 5 ug/L indicating some local sources of groundwater contamination in the central part of the area, but no lead was detected in groundwater entering the creek, and therefore does not appear to be impacting on an existing beneficial use.
TPHs were detected in the groundwater boreholes undertaken for Business Park at 750ug/L, which exceeds the Dutch Intervention level of 600 ug/L for mineral oil. However, a full screen of VOCs on sample MW208 did not detect any VOCs or halogenated VOCs. Also the TPH detected at 250ug/L (less than the Intervention level) at pile cap N88, was located adjacent to the former USTs. The sources of significant oily contamination in the soils at the site were detected and removed. Monitoring of the area in subsequent inspections has also not shown any emergence of oily seepage within the Moonee Ponds Creek.
The peak concentration of total PAHs in the deeper groundwater bores was recorded at 240ug/L in the deeper borehole adjacent to the creek. This also substantially exceeds the ANZECC ecosystem guideline of 3 ug/L for total PAHs. The detection limits on the BHE analyses for PAHs were set too high to provide hrther information on PAHs.
Up to 2.7mgL of fluoride was detected in the groundwater compared to the NH&MRC drinking water guideline of 1.5mg/L. This is not considered likely to be significant for ecosystems.
The remaining contaminated fills are also underlain by generally clayey soils reducing the potential for mobilisation and vertical migration of contaminants. The potential for some lateral migration remains feasible from the remainder of the industrial fills inside and outside of the audited site.
From the available groundwater analyses, it is apparent that there is present significant groundwater contamination that may be entering the Moonee Ponds Creek at concentrations that substantially exceed ANZECC ecosystem protection guidelines. Although it is likely that, due to the low potential seepage rates in the soilsj dilution of the contaminated groundwater in the creek would mitigate the situation such that the added contribution to surface and groundwater Contamination of the region from this site is likely to be relatively insignificant, dilution from an area source is not accepted by the EPA as a valid argument.
However, the contamination must be seen in the context of the overall quality of the portion of the Port of Melbourne, both within the Freeway envelope and in the adjacent land not part of this audit, and also in the context that the potential for further such migration of contamination has been
37 of 60 Environmental Audit Revision 2 Area 8, Elevated Roads, Western Link, MCLA. Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pry Ltd Page 33 substantially reduced by the work undertaken in the context of the original condition of the Port of Melbourne Authority portions of the site.
Based on the above considerations, and as the groundwater contamination potentially impacting on the existing beneficial uses of the Moonee Ponds Creek is from an off-site source, the environmental risks are judged to be acceptable in the context of the current land use for a Freeway. It is therefore considered that the proposed use for a Freeway is acceptable as that will have no significant adverse impact on the situation.
However, continued use of the site for industrial purposes should be restricted and further monitoring and potentially clean up of groundwater may need to be undertaken by the Precinct Developers and Port of Melbourne, coupled with assessment of the need for long term management of groundwater.
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7. MANAGEMENT & DISPOSAL OF CONTAMINATED MATERIAL
A significant risk on a major project of this type with regard to final condition of the site, arises fiom the excavation, handling and disposal of large quantities of potentially contaminated soils and the potential for contamination of remediated or uncontaminated areas. A vital aspect of the project management was therefore to put in place at the outset a soil management system in relation to all soils on the site. A basic requirement of such a system is to allow every soil load to be uniquely identified as to its origin, quality and final destination and to be managed appropriately.
As indicated in Appendix K of the Land Status Report, BHE put in place a comprehensive soil management program. Components of the system were audited on three separate occasions. Soil movements were included on a database and were scrutinised by the Auditor with some selected for detailed review. Some records were retrieved from archives to confirm a match with the system database. The results of the Audit review of the tracking system are also included in Appendix K of the BHE report.
In conducting the Audit of the tracking system, the field records for the movement of soils on randomly selected days were scrutinised in detail and the entries in the system checked for accuracy. These soil or material loads, including those imported to, or exported from, the site and those moved within site boundaries, were tracked through the system to establish whether their fate could be traced with a reasonable degree of confidence.
Records on the fate of materials identified as “Low Level Contaminated Soil” or “Prescribed Waste” excavated from pile caps in a particular area, were examined in order to establish whether they had been managed in accordance with EPA waste disposal policy, including proof of their disposal to premises licensed to receive them in the form of matching weighbridge receipts. This was also cross referenced where possible with site observations made by the Auditor during inspections of the site.
The Tracking System
The tracking system depended on the basic input from Load Sheets provided by the Truck Drivers which recorded their daily activities listing all loads including destinations. The driver did not get paid for the work without submission of the load sheet which ensured that every load was recorded in the basic information supplied to system. The loads were entered on the database indicating date, material type, origin and destination, together with the quantity estimated from the type of truck used and volume. Spot checks by the Auditor generally agreed in regard to the volume of soil recorded on the system compared to the number of truckloads indicated on the driver record sheets.
Materials in the loads were also identified, for example as concrete for recycling, or imported fill for road base or as structural fill. Where loads comprised soil sourced on site, they were classified as to structural quality and were cross matched with the test records for the samples fiom that location, or stockpile, to define the quality of the load. A Type A material was a sound structural fill and usually
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39 of 60 Environmental Audit Revision 2 Area 8, Elevated Roah, Western Link, MCLA, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 35 sourced from off-site. A Type B material was classified as possible structural fill, and Type C was of poor structural quality. The soil loads were also classified on the tracking system as to “Fill Material” or as “Low Level Contaminated Soil” or “Prescribed Waste” in accordance with EPA Bulletin 448.
The spreadsheet based system allowed the information to be sorted by any of the parameters. It was therefore possible to sort by origin, or by the date of the soil movements, or by type of soil, or any combination to highlight a target area. A general review of the system was performed by selecting random days, or random sources of material, or by sorting on the basis of soil classes to check on their allocation in accordance with the available test results. This allowed follow up on groups of load movements and the original paperwork to check that the system had been applied as indicated and correctly entered.
Results of System Audit
Movements of soil on site were examined for specific dates in 1997 and 1998. It was found that loads, as detailed on the original load sheets on these dates were generally correctly identified in the system with very infrequent errors. This included movement of concrete, of imported crushed rock and the stockpiling of soil classified as ‘fill material’ and structural fill for re-use at Graham Street (Area 9). Most of the loads investigated were tracked successfully completely through the system from excavation to final destination and were found to be appropriate for that destination.
Some minor errors were noted in respect of loads of “fill material”. For example some load sheets were incorrectly entered for the wrong date but total volumes tallied. Occasionally the number of loads entered was incorrect due to a miscount from the load sheets.
Some volume-discrepancies were noted with regard to “fill material” that was imported and stockpiled for use on parts of the site. The volumes imported indicated by the system did not match with the relevant original load sheets. In one case this could not be reconciled during the system audit but was followed up by BHE and corrected. The Auditor considered that it was important that all material movements could be identified with confidence as to source as this had to be linked to test results to indicate the quality of the imported material used in the destination area. There were sometimes found to be insufficient laboratory data to adequately characterise the imported “fill material”. This was also addressed by BHE and corrected by increasing the level of analysis for imported materials.
The information for the contaminated material excavated fiom pile caps was also tracked through the system and compared with the borehole logs, sample descriptions and relevant test results. Material containing very high concentrations of PAHs and TPH was scrutinised. The tracking load sheets and the transport certificates indicated use of EPA licensed transport to remove the material to the Tullamarine Landfill as Prescribed Waste. This was also physically observed on site during several site inspections. A large number of loads with EPA Transport Certificates were then examined and
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40 of 60 Environmental Audit Revision 2 Area 8, Elevated Roadr, Western Link MCLA. Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 36 matched with tip dockets indicating receipt of the same material. The likely volume excavated, as based on the size of the pile caps, was checked and found to tally closely with the volume of excavated material removed from site, allowing for some bulking.
The system was also searched for significant concentrations of material classified as Low Level Contaminated Soil. Test results were examined and matched with written requests to EPA and approvals for disposal. Truck records and tip dockets examined for those pile cap excavations indicated that the material was transported to a licensed landfill over time. In one case, it was found that approval had not been given for removal off-site of the material from one group of pile caps. This was followed up in detail. The truck movement records checked indicated that it had stayed within the designated Area and remained located in a stockpile awaiting a decision on its fate. This was confirmed by the Auditor during subsequent site visits.
No inconsistencies were therefore found in the records relating to Low Level Contaminated Soils and Prescribed Wastes.
Assessment of Tracking System
It was concluded that the system worked well and a high degree of reliance can be placed on the records where contaminated soils were identified and managed. A lower degree of confidence was applicable to the movement of material classified as “Fill Material” and this was promptly followed up by BHE and corrected.
Fill or soil material identified by the original assessment and by validation testing in the pile cap excavations and UST excavations as contaminated, was excavated and segregated into stockpiles during the course of the development of the site. From the information audited, and from the observations at inspections during the course of the development, it appears that surplus contaminated materials have been appropriately removed from Area 8 during the course of construction and disposed of in an acceptable manner.
As indicated by the documentation audited in the transport system, including for Area 8, the relevant EPA Transport Certificates have been completed for materials disposed to an appropriate facility for acceptance of Prescribed Wastes, and disposal of Low Level Contaminated Soils has been authorised where necessary by the EPA.
Some contaminated fill remains within the audited area. Therefore, if any future development undertaken in Area 8, or construction of services, results in the exposure of potentially contaminated soils, these must also be classified for appropriate management in accordance with current EPA policies and guidelines.
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8. QUALITY OF INFORMATION
The information in the BHE Land Status report and in the referenced Golder Phase I and II assessment reports concerning:
0 Site history;
0 Hydrogeological context;
0 Soil contamination investigation methods and data; and
0 Validation sampling and laboratory analysis. is considered to be of adequate quality and sufficiency for the purposes of this report and was supported by the Auditor's own observations during the 24 site inspections during the course of the project up to the completion of Area 8.
The potential contaminants, as indicated by the known history of the site and observations, are considered to have been identified and assessed either in the original assessment reports or in the earthworks management and validation sampling, by use of field observations, by laboratory analysis and from visual inspection.
Furthermore, this Auditor has also been involved in the pre-audit review of the investigations for the Business Park and Victoria Harbour Precincts of the Docklands Authority land. Although not discussed in detail in this report, the investigations for these areas were comprehensive and Quality Assurance procedures closely followed those suggested in AS 4482.1 - 1997.
The laboratory methodologies and detection limits used by the three laboratories employed in the original assessment by Golder (WSL & Analabs), and in the validation testing by BHE (AEL [formerly Analabs] & NAL) have been reviewed. This included review of the reported in-house laboratory methodologies and the detection limits used. The NAL and Amdel methods and detection limits were also thoroughly reviewed by this Auditor on behalf of Docklands and found to be acceptable. This can be documented further if required.
The laboratory testing database employed on site by BHE was also reviewed on many occasions during site inspections in relation to the test certificates provided. The resultant tables of data presented in the BHE report as representing the fmal condition of Area 8, have also been compared by the Auditor for accuracy with the original test certificates supplied in the BHE and Golder, and Golder/WWC reports and found to be representative of the reported concentrations. A few minor labeling discrepancies or issues identified in the Audit have been corrected or explained by BHE.
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The quality of the laboratory analyses has been assessed in the BHE and Golder reports by means of interlaboratory duplicate analysis, blind duplicate analyses, internal laboratory duplicate analyses, and by analysis of laboratory matrix spikes and blanks.
The numbers of laboratory tests reported for the whole project (including those for Area 8) both by Golder and BHE, have been reviewed separately by the Auditor. This has been compared with the project Quality Control analyses indicated in Tables El to E3 in Appendix J of the BHE report and Appendix F of the Golder Phase II report Volume 3. In some instances a higher frequency of duplicate samples has been employed than the overall 10% recommended by Australian Standard AS4482.1, and in some cases a lower frequency has been employed.
This is counterbalanced by extensive in-house quality control programs undertaken by the laboratories utilised, including numerous duplicates and matrix spikes, and has therefore been considered in proportion to the very large numbers of samples analysed and large volume of QA analyses produced. The use of fewer duplicate analyses does slightly reduce the level of confidence in the results, particularly with some QA analyses undertaken by BHE for phenols, PCBs and OC pesticides where the frequency of duplicates was 2% or less. However, in these cases the concentrations are also very low and unlikely to have influenced the outcome for the management of the site.
For the above reasons and based on our review, it is considered that the amount of Quality Assurance data collected is adequate to provide suffrcient confidence in the results from the primary analyses and to allow statistical analysis of the contaminant concentrations where feasible.
Except for some occasional significant differentials as reported by both BHE and Golder in some of the analyses, the bulk of the QA analyses indicate an adequate degree of consistency in the results. In the Land Status Report, BHE provided averaged Relative Percent Differences (RF’Ds) calculated for the results compared from each laboratory for the whole project. As this does not provide sufficiently focussed information to assess the reliability of individual batches of test results, the Auditor also checked individual duplicate samples by re-calculation of individual RPDs from the information provided by BHE. This allowed review of any significant discrepancies.
A large number of RPDs could not be calculated as either one or both of the results compared were below detection limits and concentrations very low. Some other analytical results were above detection limits and the discrepancies in the two results compared were outside a generally acceptable range of up to 50%. These were mostly for analytes that were also at relatively low concentrations. These discrepancies can therefore be attributed mostly to sample inhomogeneity related to the heterogenous fill that makes up a large proportion of the material tested, as is suggested by BHE in their report.
In a few cases, there remained significantly large variations in the duplicate analyses with RPDs in excess of 100% between the two laboratories and at relatively higher concentrations. From
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43 of 60 Environmental Audit Revision 2 Area 8, Elevated Roads. Western Link, MCLA, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 39 individual review of these few remaining cases, it appears that the variations in concentrations indicated by the duplicate samples are generally random in comparison to the primary samples, with no significant bias as to which laboratory undertook the analysis. Therefore, the Auditor believes that these remaining discrepancies do not indicate systematic errors that would need further investigation or adjustment in the statistical analysis of the test results. These remaining few variations are not considered to be of concern in considering the overall quality of the results in defining the environmental quality of the site.
Similar review of the Golder/WWC information by this Auditor on behalf of the Docklands Authority in 1997, indicated adequate correlation between the two laboratories utilised.
Based on the quality assurance procedures applied, as observed during site inspections and from review of the analysis of the results documented in the BHE and Golder reports, it is considered that the chemical analysis results provided are sufficient to form conclusions as to the current environmental status of the site with an acceptable level of confidence. On this basis, it was considered that there is no requirement for further verification of the environmental status of Area 8 of the project site by additional independent sampling and laboratory testing other than that already undertaken by BHE and Golder.
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44 of 60 Environmental Audit Revision 2 Area 8, Elevated Roads, Western Link MCLA, Victoria I8 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 40
9. STATEMENT OF ENVIRONMENTAL AUDIT
The property audited includes a number of separate areas contained within the construction area of the Western Link Freeway Portion of the Melbourne City Link development project, located between Bulla Road, Essendon North, in Moonee Valley City, and Graham Street, Port Melbourne, in the City of Port Phillip.
In order to assess whether a Certificate or Statement of Audit may be issued, this Audit has considered the environmental quality of the property located in Area 8 of the land licensed to Melbourne City Link Authority as indicated in Figure 2 of the attached Land Status Report prepared by Baulderstone Hornibrook Engineering Reference Audit ReportsPC5228fl and dated February 1998. Area 8 includes portions of the Moonee Ponds Creek Reserve from the point at which the MCLA licence envelope (Licence No 4) crosses the western boundary of the Moonee Ponds Creek, and portions of the Port of Melbourne Authority land located between Moonee Ponds Creek and the Yarra River, including the central pier of the Yarra Bridge and adjacent section of North Wharf, Victoria Harbour, Melbourne City, as outlined in bold on Figure 2 of the BHE Report.
This audit does not cover those parts of the Moonee Ponds Creek reserve or Port of Melbourne property that are outside the MCLA Licence boundary.
In reviewing the assessment of the site, the Auditor had regard for the proposed beneficial uses and the relevant State Environment Protection Policies (SEPPs) and Industrial Waste Management Policies (IWMPs), and a range of other standards and guidelines including: e EPA Information Bulletin “Guidelinesfor Environmental Auditors, Contaminated Land Issue of Certifcates of Environmental Audit” WM9 1/14 May 1992. e EPA Explanatory Notes “Environmental Audit System, Contaminated Land’,WM90104, May 1992.
EPA Information Bulletin 448 “Classifcation of Wastes” Sept 1995.
EPA Publication 480 “Environmental Guidelines for Major Construction Sites” December 1995.
0 Victorian SEPP “Groundwaters of Victoria” December 1997. e Victorian SEPP “Waters of Victoria” 1988.
0 Environment Protection (Prescribed Waste) Regulations 1987.
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45 of 60 Environmental Audit Revision 2 Area 8, Elevated Roads, Western Link MCLA. Victoria 18 March 1999 for Boulderstone Hornibrook Engineering Ply Ltd Page 41
e Environment Protection (Transport) Regulations 1987. e “Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites” prepared by the Australian and New Zealand Environment and Conservation Council (ANZECC) and National Health and Medical Research Council (NH&MRC), January 1992. e “Guidelinesfor the Laboratory Analysis of Contaminated Soils” prepared by ANZECC, August 1996. e National Environmental Health Forum (NEW) Proposed Health Investigation Levels (HILs) published by the SAHC in the Proceedings of the Third National Workshop on the Health Risk Assessment and Management of Contaminated Sites, 1996. e National Environmental Health Forum (NEHF)Proposed Health Investigation Levels for Petroleum Hydrocarbons published by the SAHC in the Proceedings of the Fourth National Workshop on the Health Risk Assessment and Management of Contaminated Sites, 1998. e Australian Water Quality Guidelines for Fresh and Marine Waters published by ANZECC November 1992. e Australian Drinking Water Guidelines published by the NH&MRC and Agricultural and Resource Management Council of Australia and New Zealand 1996. e Australian Standard AS 4482.1-1997 “Guide to the Sampling and Investigation of Potentially Contaminated SoiT‘ Part 1 Non-volatile and semi-volatile compounds, September 1997.
Assessment of the potential risks to human health and to ecosystems is based on the available data presented in the BHE Land Status Report, reference Audit ReportsPC5228fl and dated February 1999, and relevant sections of the Golder Associates reports titled “Phase 1 Environmental Assessment of Zone W8 of the Western Link” Reference 9661351 1/13 dated March “1996, and “Phase 2 Environmental Assessment of the Western Section of the Western Link” Reference 96613538/209, Volumes 1,2 and 3, dated May 1996.
From the results of the above assessment, it is considered that the site assessed in this Audit is unsuitable for issue of a Certificate of Audit due to the presence of heavy metals, and concentrations of polycyclic aromatic hydrocarbons and petroleum hydrocarbons.
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46 of 60 Environmental Audit Revision 2 Area 8, Elevated Roads, Western Link MCLA, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page 42
However, as based on the results of the above assessments, supported by the Auditor‘s inspections of the site and in consideration of the limited proposed occupation of the area for the Elevated Freeway under the MCLA Licence, and for parts of the area for industrial purposes as “Existing Public Purpose, Port of Melbourne Authority” under the Melbourne City Council Planning Scheme, it is considered that there is negligible risk to human health from the concentrations of chemicals that may remain in the soils on the part of the property described above in its final condition. The site is unsuitable for sensitive or other public beneficial uses such as public open space.
’ From the information made available, contaminated groundwater may also be entering the Moonee Ponds Creek at concentrations that exceed ANZECC guidelines for Ecosystem Protection. The source of the contaminated groundwater appears to be from the industrial areas to the east of the site forming part of the Port of Melbourne land. Other potential sources of groundwater contamination located within the Freeway envelope have been removed, and the site has been cleaned up to the extent considered practicable. Therefore it is considered that this should be considered in the context of the quality of the Moonee Ponds Creek ecosystem and should not affect issue of a Statement of Audit allowing occupation of the land for the freeway structure.
Accordingly, a Statement of Environmental Audit has been prepared for Area 8 of the Western Link site and is attached to this report. It is considered that, in some circumstances there remain some potential health and environmental risks related to the areas between Moonee Ponds Creek and the Yarra estuary, therefore restrictions on the use and management of the site are included with this audit.
It is considered that there are no particular requirements or limitations that would apply with regard to continued use of the site for the Elevated Road section of Freeway as constructed in its current condition. However, the presence of concentrations of contaminated soils and groundwater on parts of the site requires continuing attention to limit the potential for incidental exposure of the environment or the public, landscaping contractors and maintenance or industrial workers, to the contaminants that may remain. This is particularly important on the land located between the east bank of the Moonee Ponds Creek to the wharf area South of Dudley Street indicated in Figure 3 of the Land Status report, that remains contaminated with significant concentrations of metals, TPHs and PAHs.
In order to achieve these objectives it is necessary that the Operations and Maintenance Manual to be prepared by BEfor the completed Freeway as required by the Project Scope and Technical Requirements for Area 8 include and highlight the following provisions:
Plans clearly indicating the location of the areas of significant contamination that remain within the fill material in the segment from the east bank of the Moonee Ponds Creek to the wharf South of Dudley Street areas.
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47 of 60 Environmental Audit Revision 2 Area 8, Elevated Roo&, Western Link MCLA. Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Pane 43
0 Implementation of appropriate occupational health and safety precautions to protect workers potentially exposed to contaminated or hazardous soils should any future work be undertaken on the site that involves excavation or exposure of these soils.
All soil material excavated or exposed on the site must be appropriately managed in accordance with current EPA policy, regulations and guidelines and any surplus soils assessed for management or, where required, disposal to an appropriate facility licensed by the EPA to receive them.
Excavation in potentially contaminated areas must be adequately protected to limit access by the general public and minimise the potential for exposure.
0 Any physical barriers such as rock mattresses, sealed pavements or slabs, or topsoil, removed to allow excavation or other works, must be replaced on completion of the work.
A recommendation that any drawings prepared in relation to future proposed site works be reviewed by the Auditor prior to undertaking the work to ensure that they take into account and follow the intent of the Auditor’s recommendations.
And provided that the following limitations are also implemented:
0 No groundwater bores are to be constructed for any water supply purposes on this portion of the site.
0 All existing physical barriers, such as the fence on Dudley Street, floor slabs, paved roads and ballast materials, be maintained on the site.
0 If returned to commercial or industrial occupation, these areas must be reassessed and audited as to their suitability for the proposed use.
The Melbourne City Link Authority and relevant land owners and occupiers, are to be provided with information on the status of contamination of the segment from the east bank of the Moonee Ponds Creek to the wharf South of Dudley Street with recommendations that appropriate health and safety precautions be implemented to protect workers potentially exposed to contaminated or hazardous soils or groundwater should any future work be undertaken on the site that involves excavation or exposure of these soils or groundwater.
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48 of 60 Environmental Audit Revision 2 Area 8, Elevated Roads. Western Link, MCU, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering PW Ltd Page 44
10. LIMITATIONS
The Audit review was, and this report is, limited by and relies on this review's scope, the information made available to us by Baulderstone Hornibrook Engineering Pty Ltd, by the laboratory information and through the documents provided to us, and also on our observations of the site made during more than 20 inspections during the period May 1997 to February 1999. .
Dames & Moore has used reasonable care to avoid reliance upon data and information that may be inaccurate. Our conclusions presented in this report are therefore based on the information made available to us and on our own observations during our investigation. These conclusions could be different if the information upon which they are based is determined to be false, inaccurate or incomplete.
This report is intended exclusively for the use of the EPA and BHE and their consulting advisers. The scope of the work performed in connection with the audit review may not be appropriate to satisfy the needs of any other person, and any other person's use of this document or the findings, conclusions, recommendations or any other material presented in it is at that person's sole risk.
Whilst to the best of our knowledge information contained in this report is accurate at the date of issue, sub-surface conditions, including groundwater levels and contaminant concentrations, can change in a limited time. This should be borne in mind if the report is used after a protracted delay. There are always some variations in sub-surface conditions across a site which cannot be fully defined by investigation. Hence it is possible that the measurements and values obtained from the sampling and testing presented do not represent the extremes of conditions which exist within the site.
The opinions and other material presented in this report apply to circumstances at the site existing at the time of the final site inspection in February 1999 and do not apply to changes in those circumstances of which we are not aware or which we have not had the opportunity to evaluate. It is recommended that, any plans and specifications prepared by others and relating to the content of this report, be reviewed by Dames & Moore to verify that the intent of any recommendations is properly reflected in any future design.
DAMES & MOORE
KenMival Environmental Auditor (Contaminated Land)
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49 of 60 STATEMENT OF AUDIT
50 of 60 Environmental Audit Revision 2 Area 8, Elevated Road, Western Link MCU, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page I
ENVIRONMENT PROTECTION ACT 1970 SECTION 57AA STATEMENT OF ENVIRONMENTAL AUDIT I, K N Mival of Dames & Moore Pty Ltd, a person appointed by the Environment Protection Authority (“the Authority”) under the Environment Protection Act 1970 (“the Act”) as an environmental auditor for the purposes of the Act, having: 1. been requested by Mr Joe Dujmovic (and as confirmed by Mr Steve Whitter) of Baulakrstone Hornibrook Engineering of Dudley St Victoria Dock, Melbourne, Victoria, to issue a certificate of environmental audit in relation to the site located at Melbourne City, Victoria and described as Melbourne City Link Reserve Area 8 between the west bank of the Moonee Ponds Creek and the north bank of the Yarra River and including the central pier of the Yarra Bridge a4acent to North Wharj being the property described as Area 8 on Figure 2 of BHE report reference Audit Reports/PCS228fl dated February 1999, as defined in the relevant parts of MCLA Licence No’s 4, 25 and 272,as indicated in &awing numbers 1887 107K hart); 1887 1075; Leg1 96-219; Leg1 96-236, (“the site’? occupied by Baulderstone Hornibrook Engineering Pty Ltd for road constructionpurposes.
2. had regard to, amongst other things: (9 guidelines issued by the Authority for the purposes of Section 57AA of the Act; (ii) the beneficial uses that may be made of the site; and (iii) relevant State environment protection policieshdustrial waste management policies, namely;
a EPA Information Bulletin “Guidelines for Environmental Auditors, Contaminated Land, Issue of Certifcates of Environmental Audit” WM91/14 May 1992 0 EPA Explanatory Notes “Environmental Audit System, Contaminated Land”, WM90/04, May 1992 a ANZECC “Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites” Jan 1992 a ANZECC “Guidelines for the Laboratory Analysis of Contaminated Soils“ August 1996 0 EPA Information Bulletin 448 “Classification of Wastes” Sept 1995 0 Victorian SEPP “Groundwaters of Victoria” December 1997 a Victorian SEPP “Waters of Victoria” 1988 0 EPA Publication 480 “Environmental Guidelines for Major Construction Sites” December 1995 a Environment Protection (Prescnied Waste) Regulations 1987 0 Environment Protection (Transport) Regulations 1987 0 National Environmental Health Forum (NEHF) Proposed Health Investigation Levels (HILs) published by the SAHC in the Proceedings of the Third & Fourth National Workshops on the Health Risk Assessment and Management of Contaminated Sites, 1996/98 0 Australian Water Quality Guidelines for Fresh and Marine Waters published by ANZECC November 1992 0 Australian Drinking Water Guidelines published by the NH&MRC and Agricultural and Resource Management Council of Australia and New Zealand 1996 a Australian Standard AS 4482.1-1997 “Guide to the sampling and investigation of potentially contaminated soil” Part 1 Non-volatile and semi-volatile compounds, September 1997.
in making a total assessment of the nature zhd extent of any harm or detriment caused to, or the risk of any possible harm or detriment which may be caused to, any beneficial use made of the site by any industrial processes or activity, waste or substance (including any chemical substance); and
3. completed an environmental audit report in accordance with Section 57AA(2) of the Act, a copy of which has been sent to the Authority.
51 of 60 Environmental Audit Revision 2 Area 8,Elevated Roads, Western Link, MCLA, Victoria 18 March 1999 for Baulderstone Hornibrook Engineering Pty Ltd Page II
HEREBY STATE that I am of the opinion that:
1 The site is suitable for the following beneficial uses subject to the conditions attached thereto:
Road Reserve and Industrial use, provided that: An Operations and Maintenance Manual be prepared by BHE for the completed Freeway (as required by the Project Scope and Technical Requirements) which includes and highlights the following provisions commensurate with future land management and operations in the Freeway Road Reserve; all existing barriers are maintained such that areas of contaminated soils remain covered such as with landscaping topsoil, or other physical barriers that have been placed including for structures ,the boundary fence on Dudley Street, floor slabs, road works, stormwater control and flood protection The area is clearly identiled on plans included in the document as contaminated and appropriate occupational health and sdety precautions be implemented to protect workrs potentially exposed to contaminated or hazardous soils should any future work be undertakn on the site that involves excavation or exposure of these soils; AN soil material excavated or exposed on the site be appropriately managed in accordance with current EPA policy, regulations and guidelines and any surplus soils assessed for management or, where required disposal to an appropriatefacility licensed by the EPA to receive them
And provided that 0 no water supply boreholes are constructed within the site for any purpose; All existing physical barriers be maintained so that those areas of contaminated soils remain covered by such barriers, including the boundary fence on Dudley Street, areas covered by concrete, landscaping topsoil, or by structures, road pavements, stormwater control or flood protection works; and 0 The Melbourne City Link Authority and relevant land owners and occupiers, are provided with information on the status of contamination of the land with recommendations that appropriate health and safety precautions be implemented to protect workers potentially exposed to contaminated or hazardous soils or groundwater should any future work be undertaken on the site that involves excavation or exposure of these soils or groundwater.
2 The condition of the site is detrimental or potentially detrimental to any (one or more) beneficial uses of the land at the site. Accordingly I have not issued a Certificate of Environmental Audit for the site in its current condition, reasons for which are presented in the environmental audit report and are summarised as follows: the presence of soils and groundwater contaminated with heavy metals, with polyqclic aromatic hydrocarbons, and petroleum hydrocarbons. The presence of groundwater potentially contaminated with petroleum hydrocarbons, metals and PAHs, andpotentially migrating beneath the site to the Moonee Ponds Creek
This Statement forms part of environmental audit report prepared by Dames & Moore, titled “Melbourne City Link, Western Link, Area 8: Elevated Roads Melbourne, Victoria” Report reference J\20102\01 lkeaShea8 Rep .doc dated March 1999
K N Mival of Dames & Moore Pty Ltd Environmental Auditor - Contaminated Land
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52 of 60 D
53 of 60 APPENDIX A
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