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INFORMATION REGARDING ENVIRONMENTAL AUDIT REPORTS
August 2007
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Viva Energy Refining Pty Ltd Geelong Refinery 53V Environmental Audit Report
30 September 2014
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Executive Summary
Table 1 Summary of audit information
Summary information required
EPA file reference no. 54790-9 service order number 8003988
Auditor Dr Peter Nadebaum
Auditor term of appointment 16 May 1990 to 29 September 2015
Name of person requesting audit David Braiden of Viva Energy Refining Pty Ltd (Viva Energy)
Relationship to premises / Viva Energy Environmental Advisor – Soil and Groundwater location
Date of request Ongoing audit with biennial Audit Report. Approval for 2013-2014 Audit received on 25/3/2013
Date EPA notified of audit 27 March 2013
Completion date of the audit 30 September 2014
Reason for audit Requirement of Clean Up Notice dated 30 November 2011 issued pursuant to Section 62A of the Environment Protection Act 1970.
Description of activity The progress/implementation of clean up at the premises in accordance with the 2010 CUP (ERM 2010), the 2012 Audit report recommendations (GHD 2012b), and the updated CUP implementation schedule provided to EPA on 19 November 2013. The implementation of the clean-up plan will assess clean up against core remediation objectives including boundary containment of light non-aqueous phase liquid (LNAPL) and reduction of the risk of any possible harm or detriment to the groundwater or land environment caused by past and current industrial processes and activities, waste or substance at the premises. The adequacy of management plans, action plans and clean up activities will be assessed as part of the audit.
EPA region South West Region
Dominant – Lot on plan Refinery • 7200/845 - Land parcel (comprising CA 200-214 and 217 - 219)
• 7262/383 - Access roads (CA210A) • 75201/040 - Small triangular land parcel • 7715/083 - Large land parcel north of the Refinery Road extension • 8113/158 - Access roads (continuation of Refinery Road) • 8201/597 - Small land parcel adjacent to railway (CA215) • 8821/663 - Road adjacent to railway (continuation of Lowe Street) • 8094/861 – Small land parcel south of Wharf Road
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Summary information required
Additional – Lot on plan Western Buffer Zone • 6303/431 - Land Parcel • 7314/691 - Land Parcel • 8141/916 - Land Parcel • 8738/154 - Land Parcel • 8866/943 - Land Parcel • Lot A of PS 612326Gon 11153/110 • Lot 1 on PS 612326G on 11153/109 Northern Buffer Zone
• 6310/885 (comprising CA 24 and 25) • 3770/999 (comprising CA 12 and 13) Nerita Gardens
• Part of 7715/083 and 7715/035
Site/premises name Geelong Refinery
Building/complex sub-unit No.
Street/Lot – Lower No.
Street/Lot – Upper No.
Street Name Refinery
Street type (road, court, etc.) Road
Street suffix (North, South etc.)
Suburb Corio
Postcode 3214
GIS Coordinate of Site centroid 80.123611
• Longitude / Northing 58.379167 (GDA94) • Latitude / Easting (GDA94)
Members and categories of Peter Egberts (hydrogeology and remediation) support team utilised Eric Friebel (containment transport and assessment of exposure pathways and risk) Barry Mann (hydrogeology)
Outcome of the audit The majority of the proposed actions are progressing satisfactorily. The actions implemented are improving the effectiveness of boundary containment, and are reducing the risk associated with soil and groundwater contamination at the Refinery. The progress of implementation of the remainder of the actions and the recommendations from this audit will be considered in the next audit.
Further works or requirements Continue to implement actions from the Clean Up Plan (ERM 2010) and the recommendations of subsequent Audit Reports as per requirements of the Clean Up Notice and Supplementary Clean Up Notice issued pursuant to Section 62A of the Environment Protection Act 1970. Also see the recommendations of this report.
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Table 2 Physical site information
Summary information required
Groundwater segment Although parts of the foreshore near the shoreline may be more appropriately classified as Segment D, Segment C was assumed to apply across the site.
Surrounding land use The Refinery and Terminals sites are generally immediately surrounded by buffer zones, with the exception of those areas directly adjacent to the Corio Bay foreshore to the east, Geelong Grammar including the equestrian centre to the northeast, and Cheetham Salt and Incitec Pivot to the south.
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Table of contents
Executive Summary ...... i Abbreviations ...... viii 1. Introduction...... 1 1.1 Site description ...... 1 1.2 Background ...... 1 1.3 Previous audits ...... 2 1.4 Document reviews ...... 3 1.5 Audit site inspections ...... 7 1.6 Scope and limitations ...... 7 2. Scope and objectives of the audit ...... 9 2.1 How the scope was defined ...... 9 2.2 The objectives of the audit ...... 9 2.3 Audited activities ...... 10 2.4 The segment of the environment to be audited ...... 10 2.5 The elements of the environment to be considered ...... 11 2.6 Beneficial uses of the segment ...... 11 2.6.1 Background ...... 11 2.6.2 Beneficial uses of the land segment ...... 11 2.6.3 Beneficial uses of the groundwater segment ...... 12 2.6.4 Beneficial uses of the surface water segment ...... 13 2.6.5 Beneficial uses of the air segment ...... 13 2.7 Exclusions from the scope of works ...... 14 2.8 Relevant audit criteria ...... 14 2.9 Auditor support team...... 14 2.10 Methodology for the environmental audit...... 14 2.10.1 Overall ...... 14 2.10.2 Progress on clean up ...... 15 2.11 Period of time over which the audit is to be conducted ...... 15 2.12 Use of risk assessment ...... 16 2.13 Level of stakeholder involvement in the environmental audit ...... 16 2.14 Environmental audit report ...... 16 3. Regulatory compliance ...... 17 4. Beneficial uses requiring protection ...... 18 4.1 Beneficial uses of land to be protected ...... 18 4.2 Beneficial uses of groundwater to be protected ...... 19 4.3 Beneficial uses of surface water to be protected ...... 22 4.3.1 Port Phillip Bay and Corio Bay ...... 22 4.3.2 Mixing zones ...... 24 4.3.3 Shell Creek ...... 24 4.3.4 Jetty ...... 24 4.4 Beneficial uses of the air segment ...... 25
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5. Approach to Contamination Management ...... 26 5.1 Clean Up Plan ...... 26 5.1.1 CUP implementation schedule ...... 27 5.2 Geelong Refinery management system ...... 28 5.3 Site management plans ...... 29 5.4 On-site LNAPL management ...... 30 5.4.1 On-site LNAPL management plan ...... 30 5.4.2 Auditor review of on-site LNAPL MP...... 31 5.4.3 Supplementary Clean Up Notice ...... 35 5.5 Foreshore LNAPL management ...... 35 5.5.1 Remediation implementation design ...... 35 5.5.2 Auditor review ...... 35 5.6 Operation of boundary containment system ...... 37 6. Review of works undertaken ...... 39 6.1 Process used to assess progress and adequacy ...... 39 6.2 Conceptual site models...... 39 6.3 Groundwater monitoring plan ...... 41 6.3.1 2012 Groundwater monitoring plan...... 41 6.3.2 2013 Groundwater monitoring plan...... 41 6.3.3 2014 Groundwater monitoring plan...... 42 7. Primary source management – current status ...... 43 8. On-site management – current status ...... 44 8.1 Overview ...... 44 8.2 Remediation trials ...... 44 8.3 On-site LNAPL management plan ...... 45 8.4 Implementation of the on-site LNAPL management plan ...... 46 8.5 Groundwater monitoring ...... 47 8.6 Loss of primary containment ...... 47 8.7 On-site health risk assessment ...... 48 8.7.1 CO2 / Methane ...... 48 8.7.2 Other volatile contaminants ...... 49 8.7.3 Permit to work system ...... 49 8.8 Plume 2 investigation ...... 49 8.9 On-site plume assessment – priority for action ...... 50 9. Boundary containment – current status ...... 53 9.1 Performance metrics ...... 53 9.2 North of NGIT ...... 54 9.3 NGIT...... 54 9.4 GIT Gap ...... 55 9.5 CGIT...... 56 9.6 SGIT ...... 58 9.7 Separation and measurement unit (SMU) ...... 60 9.8 West of SGIT ...... 60 9.9 Overall requirements relating to the containment systems ...... 60
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10. Off-site management – current status ...... 62 10.1 General ...... 62 10.2 Geelong Grammar School ...... 62 10.3 Foreshore plumes (Plume 9, 10, 11A and 11B) ...... 63 10.4 Terminals plumes (Plumes 12 and 13) ...... 64 10.5 Plume 14 ...... 65 10.6 NAPL on the beach at other locations ...... 66 10.7 AFFF ...... 66 10.8 Off-site plume assessment – priority for action ...... 66 11. Assessment of risk ...... 68 11.1 Reappraisal of risk to beneficial uses of land and groundwater ...... 68 11.1.1 Methodology ...... 68 11.1.2 Findings ...... 68 11.2 Reappraisal of priority ranking for remedial response ...... 69 11.3 Assessment of risk from AFFF ...... 69 11.4 On-site health risk assessment ...... 70 12. Conclusions and recommendations ...... 71 12.1 Risk assessment ...... 71 12.1.1 Risks to beneficial uses ...... 71 12.1.2 Priorities for remedial response ...... 71 12.2 Progress on actions to manage soil and groundwater contamination ...... 72 12.2.1 Overview ...... 72 12.2.2 Primary source management ...... 72 12.2.3 On-site management ...... 72 12.2.4 Boundary containment ...... 72 12.2.5 Off-site management ...... 73 12.3 Recommendations ...... 73 13. References ...... 75
Table index
Table 1 Summary of audit information ...... i Table 2 Physical site information ...... iii Table 3 Documents reviewed ...... 3 Table 4 Site inspections ...... 7 Table 5 Beneficial uses of land segment ...... 12 Table 6 Beneficial uses of groundwater on-site and immediate surrounds ...... 12 Table 7 Beneficial uses of Corio Bay ...... 13 Table 8 Beneficial uses of land segment ...... 19 Table 9 Protected beneficial uses of groundwater ...... 19 Table 10 Beneficial uses of groundwater on-site and immediate surrounds ...... 21
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Table 11 Protected beneficial uses of the waters of Port Phillip Bay ...... 22 Table 12 Beneficial uses of Corio Bay ...... 23 Table 13 Progress against CUP implementation schedule ...... 27 Table 14 CUP requirements for SMP ...... 29 Table 15 Key considerations relating to the on-site LNAPL management plan ...... 33 Table 16 CUP requirements for management of on-site LNAPL ...... 34 Table 17 CUP requirements for off-site LNAPL management ...... 36 Table 18 CUP requirements for boundary containment ...... 37 Table 19 On-site plume assessment ...... 51 Table 20 Off-site plume assessment ...... 67 Table 21 Recommendations ...... 73
Figure index
Figure 1 Site location Figure 2 Site layout plan Figure 3 CUP action plan
Appendices
Appendix A - EPA documentation Appendix B - Action management table Appendix C – 2013 SMP annual report Appendix D – 2014 SMP annual report Appendix E – PSM report Appendix F – Updated risk assessment
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Abbreviations
AFFF Aqueous Film Forming Foam ANZECC Australian and New Zealand Environment and Conservation Council BOPL Black Oil Pipeline CAP Community Advisory Panel CSM Conceptual Site Model CUN Clean Up Notice CUP Clean Up Plan EPA Environment Protection Authority ESA Environmental Site Assessment GIT Groundwater Interception Trench GWMP Groundwater Monitoring Plan GRMS Geelong Refinery Management System LMP Landscape Management Plan LNAPL Light non-aqueous phase liquid (also referred to as PSH) LOPC Loss of Primary Containment
m Metres mg/L milligrams per litre NAPL Non-aqueous phase liquids OM & MM Operation, Maintenance and Monitoring Manual PFOA Perfluorooctanoic acid PFOS Perfluorooctanyl sulfonate PSH Phase Separated Hydrocarbons (also referred to as LNAPL) PPE Personal Protective Equipment RAA Remedial Alternatives Analysis RAP Remedial Action Plan SEPP State Environment Protection Policy SMP Site Management Plan TDS Total Dissolved Solids
µg/L Micrograms per litre WAG Westernport – Altona – Geelong WOPL White Oil Pipeline
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1. Introduction
1.1 Site description
The Geelong Refinery (the Refinery) was built in 1954 and owned by Shell Refining (Australia) until 1 August 2014. The Vitol group purchased Shell Australia (down stream) via a share sale during 2014 and as of 1 August 2014 the Geelong Refinery is operated by Viva Energy Refining Pty Ltd (Viva Energy). This report refers to Viva Energy as the operators of the Geelong Refinery, which was formerly operated by Shell Refining (Australia) Pty Ltd and formerly known as the Shell Refinery.
The Refinery occupies 120 hectares of land on the shore of Corio Bay, 60 kilometres from Melbourne (refer Figure 1). The area is relatively flat and is a highly engineered environment designed for the receipt and processing of hydrocarbon feedstocks and storage and transfer of hydrocarbon products. Storage of hydrocarbon feedstocks and products occurs in above ground tanks and transfers occur via both above and below ground pipes. The Refinery is secured by fencing and gates and access is restricted.
Viva Energy advises that the Geelong Refinery is Australia’s second largest refining facility and accounts for 22 per cent of Australia’s domestic refining capacity. It supplies approximately 50 per cent of Victoria’s and 30 per cent of South Australia’s fuel demand. Each year, the facility processes around five million tonnes of crude oil and other feedstocks. Products include LPG, gasoline, kerosene, solvents, diesel, bitumen, marine fuel oil, sulphur and propylene feedstock.
The Refinery includes the western tank farm and Nerita Gardens and is bound by School Road to the north, Shell Parade to the east, Wharf Road to the south, and buffer zone, Station Street and Princes Highway to the west. The Refinery operational area is defined in Figure 2. Nerita Gardens and buffer zones to the north and west are controlled by the Refinery.
Prior to construction, the land is believed to have either been vacant or used for agricultural purposes. Since 1954 the Refinery has experienced numerous phases of development and expansion in relation to manufacturing and product storage.
The Refinery is surrounded by undeveloped paddocks (buffer zones), a public reserve (foreshore), and the Geelong Grammar School located to the north east. Industrial land uses exist to the south and south west that includes the Terminals, Cheetham Salt and Incitec Pivot industrial operations. The Refinery and its surrounds are shown in Figure 2.
Land uses surrounding the Refinery are as follows. North – Nerita Gardens / buffer zone;
East – foreshore / Geelong Grammar School equestrian centre;
South – Terminals / Shell Creek / industrial zone; and West – buffer / Northern Water Reclamation Plant / industrial and residential land
1.2 Background
A Clean Up Notice (CUN) was first issued for the Refinery in 2004 by the Environment Protection Authority (EPA) based on information that pollution in the form of dissolved phase and phase separated petroleum hydrocarbon contamination was detected in a number of monitoring wells. Non-aqueous phase liquids (NAPL) is the term referred to in EPA guidance for phase separated hydrocarbons and has been generally used in this audit report. In the context of the Refinery NAPL has at times been referred to as Phase Separated Hydrocarbons (PSH), and the two terms have been used interchangeably.
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Since 2004, the CUN has been revised a number of times and environmental audits in relation to the risk of any possible harm or detriment to land and groundwater caused by past and current industrial processes and activities, waste or substance at the premises have been undertaken. Dr Peter Nadebaum has been engaged by Viva Energy as the environmental auditor for the Refinery and has carried out five previous audits in accordance with Section 53V of the Environment Protection Act 1970 (the Act). The current CUN (90000024) dated 30 November 2011 (EPAV 2011) follows the GHD Report for Shell Geelong Refinery, Environmental Audit Contaminated Land and Groundwater, October 2010 (2010 Audit Report) which included a review of the DRAFT Clean Up Plan, Shell Geelong Refinery (ERM 2010) (the CUP). The CUP proposes that 53V audits be carried out in 2012, 2014, 2017 and every subsequent three years.
EPA issued Supplementary Notice 90004215 on 24 September 2013 (the Supplementary Notice). In this Supplementary Notice EPA acknowledges the auditor’s recommendation for a change to the implementation of Requirement 2 of the CUN, that full scale remediation of LNAPL across the Refinery can be delayed until safe access becomes practicable. Copies of the CUN and Supplementary Notice are provided in Appendix A of this report.
Environmental audits of the Refinery in relation to the risk of any possible harm or detriment to land and groundwater caused by past and current industrial processes and activities, waste or substance at the premises have been undertaken since 2007. The 2010 audit included an assessment of the requirement for clean up and the adequacy of the CUP provided to EPA. The 2012 audit included an assessment of the clean-up and on-going management measures undertaken as specified in the CUN, an assessment of the risk of harm to beneficial uses arising from land and groundwater contamination at the site, and an assessment of compliance and implementation of the CUP, previous EPA advice and audit recommendations. The 2014 Audit is the second audit to be undertaken based on the 2011 CUN and the scope of audit was based on the outcomes of the GHD Report for Shell Geelong Refinery, 53V Environmental Audit Report (2012b) (2012 Audit Report).
1.3 Previous audits
Over the operating life of the facility, numerous Environmental Site Assessments (ESAs) have been undertaken at the Refinery. These date back to the early 1970s.
The information obtained to date through various assessments and monitoring events has enabled an assessment of risk to the relevant beneficial uses of the Refinery and surrounding area. The work to date has allowed an understanding of the extent of contamination to be developed, and has facilitated the identification of data gaps and the development of the CUP.
In conducting this audit the auditor has had access to the following previous audit reports: GHD 2012. Report for Shell Geelong Refinery, 53V Environmental Audit Report September 2012, herein referred to as the 2012 Audit Report; GHD 2010. Report for Shell Geelong Refinery, Environmental Audit Contaminated Land and Groundwater, October 2010, herein referred to as the 2010 Audit Report; GHD 2009. Report for Shell Geelong Refinery, Environmental Audit Contaminated Land and Groundwater, July 2009, herein referred to as the 2009 Audit Report; GHD 2008. Report for Shell Geelong Refinery, Environmental Audit Contaminated Land and Groundwater, May 2008 (re-issued July 2008);
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GHD 2008. Shell Geelong Refinery, Environmental Audit Contaminated Land and Groundwater, December 2007 (revised and re-issued July 2008);
GHD 2008. Environmental Audit – Geelong Refinery Management System Report, March 2008;
GHD 2005 Shell Geelong Refinery Statutory Environmental Audit Report (EMS Audit); GHD 2005. Shell Geelong Refinery Statutory Environmental Audit Report (Heat Exchangers), August 2005;
V&C Environment Consultants Pty Ltd 2005. Environmental Audit of the Shell Refinery Jetty Report, July 2005;
SAI Global 2004 Audit Report – Triennial Audit, Quality and Environmental, April 2004; and PB 2003 Environmental Audit of Groundwater Management at the Geelong Refinery, July 2003.
1.4 Document reviews
Previous audits have assessed the risk of harm to beneficial uses of various elements of the environment arising from land and groundwater contamination at the Refinery and have verified the adequacy of management and clean up. The 2014 Audit provides an update on the distribution of pollution, the implementation of the CUP, the implementation of recommendations from the 2012 Audit Report and the adequacy of actions to address risks from land and groundwater contamination.
Key documents listed in Table 3 were reviewed as part of the current audit. Table 3 Documents reviewed
Author / Date Document Title Purpose Referred to in this report as ERM Conceptual Site Model Plume Provides details of the Plume 2 CSM 2 July 2012 2 conceptual site model for (received Plume 2. 25/07/2013) ERM 2013 Drilling and Well Factual summary of the well 14 March 2013 Decommissioning Factual drilling and decommissioning Report Shell Geelong Refinery works carried out between ref: 0186597_Draft January and February 2013. ERM Shell Geelong Refinery - End to end strategy document 18 April 2013 foreshore (Plumes 9, 10, 11A) that details the remedial - Site-Specific E2E Strategy approach for the foreshore. Plan - Final ERM Shell Geelong Refinery - End to end strategy document 18 April 2013 foreshore (Plume 11B) - Site- that details the remedial Specific E2E Strategy Plan – approach for the foreshore. Final ERM Conceptual Site Model - Provides details of the Plume 7 & 13 23 April 2013 Plumes 7 and 13 conceptual site model for CSM Plumes 7 and 13. ERM Foreshore Remediation To assess the remediation RAA 23 April 2013 Alternatives Analysis (RAA) options for the foreshore area. Shell Geelong Refinery Shell Refining (Australia) Pty Ltd 23 April 2013 (ref: 0169835RAA_Final_v2
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Author / Date Document Title Purpose Referred to in this report as ERM Conceptual Site Model Plume Provides details of the Plume 6 CSM 23 April 2013 6 ref: 0195533CSM_Plume conceptual site model for 6_Final Plume 6. ERM Final W5 Offsite/Onsite To integrate the various W5 Investigation 30 May 2013 Investigation Factual Report aspects of the management, Report Shell Geelong Refinery ref: monitoring and remediation 0173654_0174596_W5_Final activities conducted that resulted in revocation of the Minor Works Pollution Abatement Notice (MWPAN Notice ID: 90003135). ERM Site Management Master Plan Provides an overview of the SMMP 9 July 2013 ref: 0200351SMMP_Final strategy for managing hydrocarbon impacts to soil and groundwater which have resulted from historical operation of the Refinery. ERM On-site Light Non-Aqueous Presents the strategy for On-site LNAPL 16 July 2013 Phase Liquid (LNAPL) managing the onsite LNAPL MP Management Plan plumes within the site boundaries. ERM MPVE Pilot Trial Provides a summary of the MPVE Pilot Trial 16 July 2013 works carried out and Report observations made during the MPVE Pilot Trial. Evaluates the findings of the trial and assesses whether the current conceptual site model and LNAPL recovery theory are supported by the pilot trial results. ERM Targeted Gas Sampling To assess what gases were 27 July 2009 Assessment at the Shell present in the air columns of Geelong Refinery, Corio, selected monitoring wells, and Victoria ref: whether these concentrations 0098427_L01_Final Draft.doc potentially present an acute risk and merit further investigation and/or monitoring. ERM 2013 Site Management Plan Presents the site data 2013 SMP 1 Aug 2013 Annual Report ref: 0200341 gathered as part of the Site Annual Report SMP AR_Draft V2 Management Plan over the reporting period (April 2012 through March 2013) and document how the information obtained informs proposed future actions and the risk profile of the site. This document also provides an update on compliance against the CUP implementation schedule dated 26 March 2013 and progress at addressing the recommendations included in the 2012 Audit Report. ERM Remediation Implementation Provides implementation RID 5 August 2013 Design Shell Refining details for the proposed (Australia) Pty Ltd 5 August foreshore remediation actions. 2013 ref: 0169835RID_Final_v2 ERM Final Draft Conceptual Site Provides details of the Plumes 8 & 12 Model Plumes 8/8A/8B/8C conceptual site model for
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Author / Date Document Title Purpose Referred to in this report as 3 September 2013 and 12 ref: Plumes 8/8A/8B/8C and 12 CSM 0175223CSM_Plumes 8_12_FD_130903 ERM 2013 Groundwater Monitoring Prepared to guide 2013 GWMP 4 September 2013 Plan Shell Geelong Refinery, groundwater monitoring 80 Refinery Road, Corio, activities at the site between Victoria (Final Draft_V2) ref: quarter 2 2013 and quarter 1 0187858_2013_GWMP_Final 2014. Draft_v2.docx ERM Methane and Carbon Dioxide Presents the proposed 26 September Monitoring at the Shell approach to complete 2013 Geelong Refinery ref: methane and carbon dioxide 0195487_L01.DOCX monitoring at the site. ERM Effectiveness testing and Describes the protocol for ETOP 1 October 2013 optimisation plan - testing and optimising the groundwater interception recently installed sumps as trench (GIT) upgrades ref: part of the GIT extension and 0188711L01DB.DOCX upgrades program. ERM Final Draft Groundwater Provides information on the GWIT Extension 14 October 2013 Interception Trench Extension construction of the additional Construction Construction Report ref: trench, installation of additional Report 0186062R01_FD extraction points and in-trench groundwater monitoring wells across the GIT extension areas. The program was implemented to prevent further migration of historic LNAPL beyond the site boundary. ERM Proposed changes to Details Proposed changes to 15 October 2013 schedule for LNAPL schedule for LNAPL fingerprint fingerprint analysis in the analysis. GWMP (Letter) ERM Letter Update - Foreshore Provides details of the low- 12 December Low-energy Light Non- energy LNAPL recovery works 2013 Aqueous Phase Liquid conducted during 2013 in the (LNAPL) Recovery Works foreshore. 2013, Shell Geelong Refinery, Corio, Vic ERM Final draft LNAPL Baildown LNAPL baildown testing and 14 January 2014 Testing and Analysis Report reanalysis of historic data was undertaken to obtain data from the LNAPL saturated internals of each well for estimation of transmissivity; and provide a data set of estimated LNAPL values on the foreshore. ERM Draft SumpN Investigation, Provided a summary of the SumpN Report 14 February 2014 Maintenance and Closure LNAPL sampling and repair Report, Shell Geelong works undertaken at SumpN. Refinery, Corio, Vic (Annex H to 2014 SMP) 17 February 2014 Scope and Overview Plume 2 Work plan for the intrusive Plume 2 Work 2014 works associated with Plan delineation of Plume 2. Various Documents relating to Primary A site visit at the Refinery was Source Management undertaken to interview (obtained during site various individuals and sight inspection 6 & 7 February relevant documents in relation 2014). to primary source
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Author / Date Document Title Purpose Referred to in this report as management. Various Terminals and GGS meeting Meeting minutes updating minutes and Terminals Safety groundwater sampling results Manual in these areas. ERM 2014 Plume 2 Drilling Drilling and installation of nine Plume 2 Report 24 June 2014 Summary Report monitoring wells was undertaken to further assess the extent of Plume 2. ERM CSM Addendum Memo prepared to clarify 24 June 2014 aspects of the CSMs prepared for the LNAPL plume areas inferred across the Refinery and portions of the adjacent Corio Bay Foreshore. ERM Q2(2013) - Q1(2014) Presents the groundwater 2014 27 June 2014 Groundwater Monitoring monitoring data collected Groundwater Report (Annex E to SMP) between Q2 Monitoring 2013 and Q1 2014. Report ERM 2014 Site Management Plan - Presents the site data 2014 SMP 27 June 2014 Annual Report gathered as part of the Site Annual Report Management Plan over the reporting period (April 2013 through March 2014) to assess the effectiveness of the remedial and boundary containment actions, the effectiveness of the site PSM processes and the stability of the existing hydrocarbon plumes. The SMP Annual Report also provides an overview of progress against the CUP Actions, CUP Implementation Schedule and additional actions identified in previous SMP Annual Reports or 53V Environmental Audit Reports and other auditor recommendations. ERM Indoor Methane and Carbon Provides a summary of Methane and June 2014 Dioxide Monitoring (Annex G methane and carbon dioxide CO2 Monitoring to SMP) concentrations observed in Report infrequently accessed, enclosed, above-grade spaces (buildings) where ground gases (generated from the biodegradation of petroleum hydrocarbon impacts) may accumulate. The report also characterised the risk of explosion or asphyxiation associated with accumulation of these gases. ERM Proposal for Well Installation, Proposal for well installation, 1 July 2014 Decommissioning and Repairs decommissioning and repair at the Shell Geelong Refinery activities at the Refinery. ERM Groundwater Monitoring Plan Prepared to guide 2014 GWMP 1 July 2014 (Annex F to SMP) groundwater monitoring activities at the site between quarter 2 2014 and quarter 1 2015.
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The key document for assessing the implementation of the CUP (ERM, 2010) actions were the 2014 SMP Annual Report provided in Appendix D and the draft 2013 SMP Annual Report provided in Appendix C, however, the auditor reviewed various additional documents during the audit period as listed above. A number of workshops and meetings were also held during the audit period. The additional documents reviewed and the workshops and meetings undertaken were part of the process for implementation and refinement of the CUP actions. A summary map of CUP action areas is provided in Figure 3. Comments were provided to Viva Energy and their consultants Environmental Resources Management Australia Pty Ltd (ERM) on the documents received and minutes were prepared for the workshops and meetings.
1.5 Audit site inspections
The audit team conducted a number of site inspections during the audit period. A summary of the works observed during these inspections are summarised in in Table 4 below: Table 4 Site inspections
Date of inspection Works observed
1 March 2013 Construction of the Southern GIT extension
20 March 2013 Key in of Central GIT extension to existing Central GIT
23 October 2013 Groundwater sampling event
29 November 2013 Indoor methane and carbon dioxide sampling
6 & 7 February 2014 Primary source management procedures and practices
22 & 23 May 2014 Construction of northern end of foreshore trench B
1.6 Scope and limitations
This environmental audit report (“Report”) has been prepared in accordance with Part IXD of the Environmental Protection Act 1970. The report represents the Auditor’s opinion of the risks that soil and groundwater contamination at and immediately adjacent to the Refinery poses to beneficial uses of land, groundwater and surface water, at the date of completion of the audit. The scope of this audit is limited to the specific scope as defined in this Report and the Auditor makes no other statement, warranty, comment in respect of the environmental conditions, risks or otherwise in relation to the site beyond this defined scope in this Report. This Report:
1. has been prepared by Peter Nadebaum of GHD Pty Ltd (“GHD”) and his team as indicated in the appropriate sections of this Report for Viva Energy Refining Pty Ltd and its Affiliates (collectively, “Viva Energy”);
2. may be used and relied on by Viva Energy;
3. may be used by and provided to EPA for the purpose of meeting statutory obligations in accordance with the relevant sections of the Environment Protection Act 1970;
4. may be provided to other third parties but such third parties’ use of or reliance on the Report is at their sole risk because of, and subject to, the uncertainties associated with this audit as noted in the following paragraphs and in this Report; and
5. may only be used for the purpose as stated in Section 2.2 of the Report (and must not be used for any other purpose).
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To the maximum extent permitted by law, all implied warranties and conditions in relation to the services provided by GHD and the Report are excluded unless they are expressly stated to apply in this Report. The services undertaken by the Auditor, his team and GHD in connection with preparing this Report were undertaken in accordance with current professional practice and by reference to relevant environmental regulatory authority and industry standards in accordance with section 53V of the Environment Protection Act 1970.
The opinions, conclusions and any recommendations in this Report are based on assumptions made by the Auditor, his team and GHD when undertaking services and preparing the Report (“Assumptions”), as specified throughout this Report.
In preparing the audit, the Auditor and his team have considered the available information in reaching a conclusion regarding the level of risk to beneficial uses; and this has required consideration of information that in some cases was not capable of being verified within the time scale of the audit, is of a nature that does not allow it to be quantified, or had a high degree of uncertainty with respect to magnitude of effect and likelihood of effect. In some cases information was not available and was not able to be obtained within the time scale of the audit. Where information was not available or was uncertain, the Auditor has made a judgment regarding the situation that, in his opinion, is likely to apply. The assessment of risk requires a consideration of the magnitude of effect and the likelihood that an effect of that magnitude will occur; this is inherently uncertain and depends on the significance that persons place on the effect, and other persons may reach an alternative conclusion as to the level of risk that applies. Because of these factors, caution is required in the use of the information in this Report, and persons referring to, relying on or using in any way the conclusions of this Report should make their own assessment and seek independent advice from persons with the relevant expertise in the field to satisfy themselves that they understand the underlying information and level of uncertainty, and the level of risk that they would assign, which may differ from the level of risk that the Auditor has assigned.
Subject to the paragraphs in this section of the Report, the opinions, conclusions and any recommendations in this Report are based on conditions encountered and information reviewed at the time of preparation of this Report and are relevant until such times as the site conditions or relevant legislations changes, at which time, GHD expressly disclaims responsibility for any error in, or omission from, this Report arising from or in connection with those opinions, conclusions and any recommendations.
The Auditor and GHD have prepared this Report on the basis of information provided by Shell Refining (Australia) Pty Ltd (Shell) prior to the sale of the Refinery, by Viva Energy subsequent to the sale, and Shell/Viva Energy’s consultant ERM, the Auditor and his team have carried out checks of samples of this information in accordance with industry practice; this checking did not extend to all information; and the Auditor and GHD have not carried out field work to independently verify the information. Where the Auditor considered that the level of uncertainty or errors in the information could lead to a significantly different finding, the Auditor has made recommendations for further work to be carried out in the future to resolve the uncertainty. Because of this, there is uncertainty in the conclusions regarding the risk to beneficial uses and the Auditor and GHD expressly disclaim responsibility for errors that have arisen because of uncertainty in the information.
This Report should be read in full and no excerpts are taken to be representative of the findings of this Report.
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2. Scope and objectives of the audit
2.1 How the scope was defined
An environmental audit of an activity can range from a full assessment of large industrial premises to a focussed assessment of a small component of an activity. EPA Publication 952.2 Environmental Auditor Guidelines for the Preparation of Environmental Audit Reports on Risk to the Environment (EPAV, 2007) provides guidance to environmental auditors undertaking an environmental audit pursuant to section 53V of the Environment Protection Act 1970. The auditor has referred to the information contained in this guideline to establish the scope of the audit for this site. The scope of this audit was detailed in the GHD draft document Shell Refinery, Corio Scope of the 2013/2014 Environmental Audit provided to EPA in January 2014 and updated in March 2014 to incorporate the requirements of the Supplementary Notice. This document referred to as the Audit Scope throughout this report This audit forms one of a series of audits conducted at the Refinery, and its scope has been based on:
The requirements of the 2011 CUN and Supplementary Notice;
Advice from the EPA; The 2012 Shell Geelong Refinery Environmental Audit Report; and
Information or observations made by Viva Energy or their consultants during the course of the Audit that may have a bearing on the objectives of the Audit.
2.2 The objectives of the audit
The objectives of the environmental audit were based on the CUN issued to Shell Refining (Australia) Pty Ltd (now Viva Energy) on 30 November 2011 and the Supplementary Notice issued on 24 September 2013 and were intended to confirm that the clean up and on-going management measures were undertaken as specified in the notice. The audit has assessed the risk of harm to beneficial uses of various elements of the environment arising from land and groundwater contamination at the site. The audit incorporated a review of all monitoring data action plans, work plans and management plans to comment on the adequacy of proposed actions prior to their implementation. The audit has assessed compliance and implementation of previous EPA advice and audit recommendations and clarified some of the uncertainties identified in previous audits. The implementation of the CUP was assessed in terms of whether the various requirements of the CUP and recommendations in the 2012 Audit Report have been carried out. Because of the evolving state of knowledge about the nature of the contamination and how it may be cleaned up and managed, the auditor has accepted changes in the clean up and management approach if he considers the approach and expected outcomes are consistent with EPA policy and guidance. The audit report is intended to provide an update for EPA on the work undertaken since the previous audit report (2012 Audit Report) with specific reference to the current extent of pollution and the risk posed to beneficial uses, the current state of implementation of the CUP, and the adequacy of remediation action plans and works undertaken to address the risks. In particular, the audit report has included consideration of the risk of any possible harm or detriment to relevant beneficial uses of land and groundwater caused by the known releases of refinery related products, existing LNAPL under the Refinery and off-site areas; or in relation to the implementation of clean-up activities.
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The auditor has made additional recommendations in this audit report for the ongoing management, and clean up of contamination at the site for consideration by Viva Energy and EPA and, where agreed in writing between Viva Energy and EPA, the CUN requires these further recommendations to be implemented.
Note that in this audit report the recommendations have been framed in terms of the key matters that need to be carried out or determined. Suggestions regarding matters that should be considered relating to these recommendations have been recorded in the form of “suggested actions”; these recommendations and suggested actions will be assembled in an Action Management Table to assist in the management and auditing of the various further tasks that are to take place.
2.3 Audited activities
The activities under audit are the monitoring, management and clean-up of pollution associated with the Refinery. The audit is ongoing and this report has considered:
The monitoring and operation of the groundwater interception trenches (GITs); Monitoring, action plans and testing associated with further containment works required at the premises;
The adequacy of action plans, management plans and clean up of LNAPL;
Primary source control and associated documentation on primary source control; Stakeholder communication including community consultation associated with the clean up and management of public land; The implementation of controls on the use of soil and groundwater on off-site polluted land;
Whether the CUP is adequate to manage the identified risks; Potential risks to beneficial uses that could be generated by the implementation of clean- up activities or by stopping clean-up activities; and
Past and current industrial processes and activities. The audit was restricted to these considerations, and did not consider the risk associated with: Activities that occur or have occurred at premises external to the Refinery which may give rise to soil and groundwater contamination, other than if they were directly related to refinery activities or have been known to have given rise to soil or groundwater contamination at the Refinery; Discharges of cooling water to Corio Bay; or
Spillage of hydrocarbons from ship unloading operations.
2.4 The segment of the environment to be audited
The segment audited includes the Refinery site and the area in the immediate vicinity of the Refinery (off-site) within which groundwater quality is affected by the Refinery and areas of LNAPL impact both on and off-site, including the foreshore. LNAPL has affected much of the Refinery and surrounding areas including Nerita Gardens, the foreshore and Terminals and the western buffer zone, and these areas and those subject to clean-up activities have been a particular focus. The audit has also considered the potential for impact on Corio Bay with a particular focus on the intertidal zone, and the significance of Shell Creek / the Shell Creek Drain.
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The timeframe of the ongoing audit is outlined in Section 2.11 of this document.
2.5 The elements of the environment to be considered
The elements audited within the segments of the environment upon which the audit has focused include:
Land; Groundwater; Surface waters; and Air (where it may be affected by contamination or the clean up of contamination). Other elements considered included vegetation, aesthetics, fish, stock animals and wildlife.
2.6 Beneficial uses of the segment
2.6.1 Background
A beneficial use is a use of the environment or any element or segment of the environment which is conducive to public benefit, welfare, safety, health or aesthetic enjoyment and which requires protection from the effects of waste discharges, emissions or deposits, or from the emission of noise.
The beneficial uses to be protected for the segments of the environment are declared in State Environment Protection Policies (SEPPs). The SEPPs describe the beneficial uses that apply to a particular geographic region or class of water, and identify indicators to be employed in measuring environmental quality and objectives necessary to sustain designated beneficial uses.
In particular, the following SEPPs are relevant:
State environment protection policy (Groundwaters of Victoria), 1997 (hereafter identified as the ‘Groundwater SEPP’); State environment protection policy (Prevention and Management of Contaminated Land), 2002 (hereafter identified as the ‘Land SEPP’); State environment protection policy (Waters of Victoria), 2003 (hereafter identified as ‘SEPP (WoV)’); State environment protection policy (Waters of Victoria) Schedule F6. Waters of Port Phillip Bay, 1997 (hereafter identified as ‘SEPP (WoV) F6’); and State environment protection policy (Air Quality Management), 2001 (hereafter identified as the ‘Air SEPP’). Depending on the current and likely future uses of the land, surface water and groundwater on and near the Refinery, some of the beneficial uses defined in these SEPPs will be relevant and others may be unlikely to be realised. In the case of the Groundwater SEPP, the beneficial uses to be protected are based on level of total dissolved solids (TDS). In the case of the Air SEPP, the beneficial uses of air relate to those that may be impacted by contaminated soil and groundwater, and will be considered as an extension of the Land SEPP assessment.
The beneficial uses of the relevant segments of the environment for the present audit have been described in the Audit Scope document.
2.6.2 Beneficial uses of the land segment
The following table identifies the beneficial uses of land from the Land SEPP, relevant to the Refinery as originally identified in the 2009 Audit Report and updated for this audit.
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Table 5 Beneficial uses of land segment
Industrial Recreational & Sensitive use – (on site including Nerita Gardens, open space schools buffer zones southern off site) (foreshore) (Geelong Grammar School)
Natural
Modified
Highly Modified
Maintenance of of Maintenance ecosystems
Human Health Buildings and Structures
Aesthetics Production of food
flora and fibre
Empty cell Land SEPP does not require the beneficial use to be protected
Land SEPP nominates the beneficial use to be protected, however it is not likely to be relevant to the segment
Land SEPP nominates the beneficial use to be protected and it is likely to be relevant to the segment
2.6.3 Beneficial uses of the groundwater segment
The following table identifies the beneficial uses of groundwater from the Groundwater SEPP, relevant to the Refinery as originally identified in the 2009 Audit Report and updated for this audit. Note that the entries in Table 6 relating maintenance of ecosystems on-site and primary contact recreation off-site have been revised from that indicated in the previous audits to reflect the current understanding of the relevance of these beneficial uses. Table 6 Beneficial uses of groundwater on-site and immediate surrounds
On site (Segment C) Off site (Segment C)
Maintenance of ecosystems
Potable water Desirable supply
Acceptable
Potable mineral water supply
Agriculture, parks and gardens
Stock watering
Industrial water use
Primary contact recreation
Buildings and structures
Empty cell Groundwater SEPP does not require the beneficial use to be protected
Groundwater SEPP nominates the beneficial use to be protected; however it is not likely to be relevant to the segment
Groundwater SEPP nominates the beneficial use to be protected and it is likely to be relevant to the segment
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2.6.4 Beneficial uses of the surface water segment
Port Phillip Bay and Corio Bay The following table identifies the beneficial uses of Corio Bay from the SEPP(WoV)F6, relevant to the Refinery as identified in the Audit Scope and previous audit reports and updated for this audit. Table 7 Beneficial uses of Corio Bay
Corio Bay Maintenance of aquatic Natural ecosystems ecosystems and associated wildlife Substantially natural ecosystems with some modification Highly modified ecosystems with some
habitat values Water based recreation Primary contact
Secondary contact
Aesthetic enjoyment
Production of molluscs for Natural populations human consumption Aquaculture Commercial and recreational use of edible fish and crustacean
Navigation and shipping
Industrial water use
Empty cell SEPP (WoV) F6 does not require the beneficial use to be protected
SEPP (WoV) F6 nominates the beneficial use to be protected; however it is not likely to be relevant to the segment
SEPP (WoV) F6 nominates the beneficial use to be protected and it is likely to be relevant to the segment Further discussion of the beneficial uses applicable in the context of this audit, with particular regard for mixing zones, Shell Creek and the Jetty (as shown on Attachment C of the 2011 CUN) are discussed in Section 4.3.1.
2.6.5 Beneficial uses of the air segment
As noted under beneficial uses of the land and groundwater segments, consideration has been given to the requirement for protection of the beneficial uses of air such as may be affected by land and groundwater contamination. In this respect, the beneficial uses to be protected are human health and aesthetic enjoyment (e.g. odour) as required in the Air SEPP.
Such affects can arise through: Volatiles present in the soil and groundwater and which may migrate into buildings or into the ambient air and adversely affect the health of persons or give rise to aesthetic (e.g. odour) effects; and Particulate material (e.g. dust arising from soil) that becomes suspended in air and inhaled.
Because these effects are linked to land and groundwater contamination, these requirements have been included in the consideration of the effects of land and groundwater contamination, rather than separately considering the requirements for protection of the beneficial uses of the air segment.
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2.7 Exclusions from the scope of works
The audit has not assessed activities at the Refinery that may occur, other than those specified in Section 2.3. The audit has not considered the risk associated with discharges of cooling water to Corio Bay, or the risk to the waters of Corio Bay associated with spillage of hydrocarbons from ship unloading operations. The audit will not consider activities that occur or have occurred at premises external to the Refinery and which may give rise to soil and groundwater contamination, other than if they are directly related to refinery activities or are necessary to clarify whether contamination of soil and groundwater at the Refinery originates from on site or off site.
The audit area did not include: the Westernport-Altona-Geelong (WAG) pipeline easement along the eastern boundary of the fenced Refinery area, the White Oil Pipeline (WOPL), Black Oil Pipeline (BOPL), the Melbourne-Geelong railway line easement, and the Northern Water Reclamation Plant located to the west of the Refinery and south west of the western tank farm.
The LyondellBasell Australia Plant is not operated by Viva Energy and for the purposes of this audit has been considered to be external to the Refinery and is not included in the audit, although groundwater contamination that might migrate from this area and form part of the groundwater contamination at the Refinery is included.
2.8 Relevant audit criteria
The audit criteria needed to meet the objectives of the audit and was derived from a number of sources including:
The environmental quality objectives prescribed by each of the relevant SEPPs and schedules to the SEPPs, as identified above;
The requirements of the CUN and Supplementary Notice; and
The conditions of EPA Licence number 46555 as amended on 24/09/2013.
2.9 Auditor support team
Members of the auditor’s support team utilised for this audit include:
Peter Egberts (hydrogeology and remediation);
Eric Friebel (contaminant transport and assessment of exposure pathways and risk); and
Barry Mann (hydrogeology). In addition, the auditor was assisted by other members of GHD as required, including Joanne Roolker, Diane Kovacs and Julie Davies.
2.10 Methodology for the environmental audit
The following sections provide a brief outline of the methodology adopted as per the Audit Scope. Further detail on the process for assessing progress and adequacy is provided in Section 6.1.
2.10.1 Overall
The 2014 Audit has focused on the requirements of the CUN and Supplementary Notice; and monitored the implementation of the CUP, Site Management Master Plan (SMMP) and Site Management Plan (SMP) Annual Reports, as well as the implementation of recommendations from the 2012 Audit Report.
Previous audit reports included a risk assessment of soil and groundwater contamination at the Refinery to identify the receptors, contaminants and exposure pathways that pose the greatest
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risk to beneficial uses, and therefore should form a particular focus for further review and assessment. The 2014 audit has reassessed the assigned risk rankings in light of new information. A key objective is to minimise the risk that NAPL might pose to beneficial uses and to achieve a situation whereby the risks are at an acceptable level.
2.10.2 Progress on clean up
The SMMP provides an overview of the strategy for managing hydrocarbon impacts to soil and groundwater which have resulted from historical operation of the Refinery. Site Management Plan Annual Reports present data gathered as part of the SMMP and provide interpretation of data and an overview of progress against actions detailed in the CUP and auditor recommendations.
ERM prepared two Site Management Plan Annual Reports in the 2013/2014 audit period:
2013 Site Management Plan Annual Report ref: 0200341 SMP AR_Draft V2 (herein referred to as the ‘2013 SMP Annual Report’); and
2014 Site Management Plan - Annual Report (herein referred to as the ‘2014 SMP Annual Report’). Review of the SMP Annual Reports has included consideration of:
The requirements of the CUN and Supplementary Notice;
Feedback from Stakeholders including the EPA and the community;
Relevant EPA guidance; and
Relevant data gathered prior to and during the current audit period.
The actions and progress of the implementation of the CUP actions and Audit Report recommendations are summarised in an Action Management Table (AMT) provided in Appendix B which outlines the actions and recommendations from these documents along with recommendations from auditor correspondence since the 2012 Audit Report. This audit has assessed the progress that has occurred on each action in the AMT (See Appendix B).
The AMT has been re-structured to include consideration of various reports, as well as checking progress on the four pillars of contamination management relevant to the site: Primary Source Control, On-site Management, Boundary Containment, and off-site Management. The AMT also includes on-going requirements such as groundwater monitoring. The auditor expects that the AMT will further evolve during subsequent audits as progress is made towards reducing risk and a better understanding of the requirements for clean up is obtained.
In this audit report the recommendations have been framed in terms of the key matters that need to be carried out, and additional detailed information and suggestions as to matters that should be considered relating to these recommendations have been recorded in the form of “suggested actions”.
2.11 Period of time over which the audit is to be conducted
The 2011 CUN follows the 2010 Audit report which included a review of the 2010 draft CUP. The CUP included a reporting schedule within the Site Management Plan identifying 30 September 2014 as the due date for the 2014 Audit report, with subsequent reports submitted on 30 September 2017 and every 3 years following.
Information received between September 2012 and July 2014 was considered in this audit report.
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2.12 Use of risk assessment
The significance of the risks to the environment was assessed and reported in the 2009 Audit Report using a semi-quantitative risk assessment methodology based on AS/NZS ISO 31000:2009 Risk Management – Principles and guidelines and IEC/ISO 31010:2009 Risk management – Risk assessment techniques. This audit includes: A review of any additional information that has become available; and
A review of works undertaken and their effect on risk levels.
2.13 Level of stakeholder involvement in the environmental audit
The audit involves ongoing liaison with a number of relevant stakeholders, including: Viva Energy Refinery personnel and their consultants;
The Community Advisory Panel (CAP) and other relevant stakeholders including the Greater Geelong City Council (GCC), DSE, Parks Victoria, and representatives of the Wathurung People; and
The EPA.
2.14 Environmental audit report
The 2014 environmental audit report has focused on assessing the extent to which the CUP and previous audit comments and recommendations have been implemented, through reviewing the SMMP, 2013 SMP Annual report and 2014 SMP Annual Report, and the reports on specific activities undertaken by Viva Energy or its consultant. The risk of any possible harm or detriment to land and groundwater caused by past and current industrial processes and activities, waste or substance at the premises has also been reviewed in light of the site management and clean up conducted since the 2012 audit.
This audit report contains the auditor’s comments on progress, its adequacy, changes in the risk profile, and recommendations for further work.
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3. Regulatory compliance
The Clean Up Notices issued by EPA under section 62A of the Environmental Protection Act 1970 by EPA for the Refinery were discussed in Section 1 of this report.
Currently regulatory compliance is based on the 2011 Clean Up Notice and 2013 Supplementary Notice. The CUN refers specifically to the CUP and the 2010 Audit Report which broadly endorsed the CUP and provided additional recommendations. The CUN requires that:
An auditor (appointed pursuant to Section 55S of the Environment Protection Act 1970) must review the CUP and make additional recommendations as appropriate. Shell (now Viva Energy) must implement the CUP in accordance with :
– The recommendations of the 2010 Audit Report; and – Recommendations agreed in writing between Shell (now Viva Energy) and EPA contained in subsequent environmental auditor reports. The formulation of the CUN recognises the long timeframe of the CUP and the requirement to have it periodically reviewed, and that this may result in the details of compliance evolving during the currency of the CUN. It is in this context that this audit seeks to determine whether the progress / implementation of clean up at the premises is in accordance with the CUP, recommendations made in the 2010 and 2012 Audit Reports, and the updated CUP implementation schedule provided to EPA on 19 November 2013. Where deviations are noted, the auditor has sought to determine whether these have been adequately justified and considers new information that has become available. Where new information has been provided, the auditor has undertaken a reappraisal of risks to beneficial uses and the rankings assigned for remedial action as identified in the 2010 Audit Report.
As discussed in Section 2.10.2, the auditor prepared an Action Management Table (AMT) which has evolved throughout the course of the audit as actions and recommendations have progressed. For the purpose of the audit, the AMT forms a basis for tracking progress. The suggestions in the Table are not mandatory, and there may be alternative ways of achieving the indicated outcome.
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4. Beneficial uses requiring protection
The beneficial uses of the segment were discussed in Section 2.6 of this audit. The actual and potential beneficial uses of the segment of the environment need to be identified before the risk of possible harm or detriment to them can be assessed. The relevant beneficial uses for land, groundwater, surface water and air for this audit are discussed in the following sections.
4.1 Beneficial uses of land to be protected
The Land SEPP identifies a number of land use categories and protected beneficial uses for each land use category. Those that are relevant for this audit are as follows:
On site Industrial land on which the Refinery operates as shown on Figure 2 as the Refinery and Nerita Gardens.
Off site Parks and Reserves and Recreation/Open Space located along the foreshore area;
Industrial land to the north and west of the Refinery that is used as a buffer zone and adjacent land to the south of the premises (Terminals and southern industrial zone); and
Sensitive Use to the north east of the Refinery at the Geelong Grammar School, including the equestrian centre. Given that this area is zoned ‘farming’, agricultural land use may be considered more appropriate; however, Sensitive Use includes all beneficial uses under the agricultural land use category and assuming agricultural land use would not alter the outcome of the audit.
The Land SEPP defines beneficial uses protected by the Policy for land as being:
Maintenance of natural ecosystems, modified ecosystems and highly modified ecosystems;
Human health;
Buildings and structures;
Aesthetics; and
Production of food, flora and fibre.
For the purposes of this audit, the Refinery and its surrounds were considered to fall under three segments based on the land use and geographic location. Table 8 shows the beneficial uses nominated by the Land SEPP for each segment, and indicates whether they are likely to be realised. Residential zones are located up gradient of the Refinery to the north-west. As such, residential beneficial uses are not relevant to the assessment of soil and groundwater impact as a consequence of the Refinery’s activities. The consumption of produce grown at Geelong Grammar School is not considered a likely beneficial use of the land for a school, although it is considered in the case of Geelong Grammar in view of its rural location. The school is also used as residential for boarders living at the school. The beneficial uses for residential use are covered under the sensitive use segment.
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In the case of the protection of human health, this includes consideration of the potential for impact via ingestion, dermal contact, and inhalation. In the case of inhalation, this may occur through inhalation of particulates (e.g. dust) and volatiles that might occur from contamination of land (soil and groundwater). Note that protection of human health includes consideration of the requirements for protection of the beneficial uses of air such as may be affected by land contamination. Table 8 Beneficial uses of land segment
Industrial Sensitive use – Recreational & schools (on site including Nerita open space Gardens, buffer zones (Geelong Grammar (foreshore) southern off site) School)
Natural
Modified ecosystems
Maintenance of of Maintenance Highly modified
Human health
Buildings & structures
Aesthetics
Production of food flora and fibre
Empty cell Land SEPP does not require the beneficial use to be protected
Land SEPP nominates the beneficial use to be protected, however it is not likely to be relevant to the segment
Land SEPP nominates the beneficial use to be protected and it is likely to be relevant to the segment
4.2 Beneficial uses of groundwater to be protected
The beneficial uses to be protected for each of the segments of groundwater are defined in the Groundwater SEPP, and are reproduced as Table 9. Table 9 Protected beneficial uses of groundwater
Segments (mg/L TDS) A1 A2 B C D (0-500) (501-1 000) (1 001- (3 501- (> 13 000) Beneficial Uses 3 500) 13 000)
Maintenance of ecosystems
Potable water supply
Desirable
Acceptable
Potable mineral water supply
Agriculture, parks & gardens
Stock watering
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Segments (mg/L TDS) A1 A2 B C D
Industrial water use
Primary contact recreation (e.g. Bathing, swimming)
Buildings and structures
The TDS of the groundwater is generally in the range of 4 000 – 12 000 mg/L, with some higher TDS concentrations in the order of 40 000 mg/L being reported. The Groundwater SEPP classifies the water quality in this TDS range as Segments C and D. Given that Segment C is most conservative, it has been referenced as the relevant classification across the site (including offsite areas) in this report. In parts of the foreshore, in the vicinity of the shoreline, the quality of the groundwater is affected by seawater and the groundwater may be more appropriately classified as Segment D. Given the variability of TDS in the foreshore area, the more conservative classification (segment C) has been considered for the purpose of this audit.
It is noted that, in the context of this audit, TDS and Segment refer to shallow groundwater; this is most relevant for the Refinery as impacts of soil and groundwater contamination are most likely to occur in the upper portion of the aquifer. It is possible that deeper groundwater (e.g. 100 m) might be less saline and if so, a wider range of beneficial uses could be relevant.
Groundwater flow at the site was inferred to be to the east/southeast, however, there can be some local variation to this.
The following areas are down gradient of the Refinery and are those most likely to be affected by soil and groundwater contamination at the Refinery:
Corio Bay; Nerita Gardens in the northern section of the Refinery; Shell Creek; Geelong Grammar School Terminals industrial zone; equestrian centre to the north-east Southern off site industrial zone; of the Refinery;
Foreshore; and
Public transport (railway) land use zones to the east of the Western Tank Farm.
The following areas are cross gradient to the Refinery and are less likely to be affected by soil and groundwater contamination:
Geelong Grammar School; The following segments are up gradient of the Refinery and are not likely to be affected by soils and groundwater contamination at the Refinery:
Western buffer zones; Residential zones to the west and north-west; and Public transport (railway) land use zones to the west; with Commercial and Industrial. the exception of the rail loading gantry area;
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Princes Highway;
A groundwater database search carried out in September 2014 showed that there were 149 registered groundwater bores within a 1 km buffer of the Refinery (including the Refinery). One hundred and thirty-five bores were registered for investigation or observation purposes. Seven bores were registered as ‘not known’ including one located approximately 800 m to the east of the site on the grounds of Geelong Grammar School. This is located cross gradient of the Refinery, other bores registered as ‘not known’ are located up gradient of the Refinery, and near the north eastern boundary of the Refinery. Five bores were registered as ‘domestic and stock’, these were located to the south of the Refinery. One well registered as ‘industrial’ and one well registered as ‘irrigation’ are located to the north (and up gradient) of the Refinery.
As discussed above, the beneficial uses to be protected are determined by the TDS of groundwater, regardless of the land use. In particular: On the Refinery, the use of groundwater is controlled by Viva Energy which limits groundwater uses.
Off site it is possible that groundwater could be used for a range of uses such as industrial purposes, stock watering, irrigation and primary contact recreation, with use for stock being more likely at the Geelong Grammar School equestrian centre to the northeast of the Refinery. It is understood that a bore located at the Grammar School has been used for irrigation purposes.
Immediately down gradient of the Refinery (along the foreshore) it is unlikely that groundwater would be extracted for use, given that the area is currently zoned primary conservation and resource and public park and recreation, and a reticulated water supply is available. In addition, groundwater in the foreshore area is also likely to be saline, limiting the potential extractive uses for industrial use.
There is potential for contact with groundwater through digging on the foreshore, therefore the primary contact recreation beneficial use is considered relevant for the foreshore down gradient of the Refinery.
Table 10 shows the beneficial uses nominated by the Groundwater SEPP under Segment C, and indicates whether they are likely to be realised onsite and in the farming/special use zone and the primary conservation and resource / public park and recreation zone (foreshore). Table 10 Beneficial uses of groundwater on-site and immediate surrounds
On site (Segment C) Off site - Foreshore (Segment C)
Maintenance of ecosystems
Potable water Desirable supply
Acceptable
Potable mineral water supply
Agriculture, parks and gardens
Stock watering
Industrial water use
Primary contact recreation
Buildings and structures
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On site (Segment C) Off site - Foreshore (Segment C)
Empty cell Groundwater SEPP does not require the beneficial use to be protected
Groundwater SEPP nominates the beneficial use to be protected; however it is not likely to be relevant to the segment
Groundwater SEPP nominates the beneficial use to be protected and it is likely to be relevant to the segment At some locations groundwater may discharge to an outfall-mixing zone defined in the waste discharge licence, and it is proposed that the approach outlined in Section 4.3.2 of this report will apply.
While not specifically identified in the Groundwater SEPP, consideration was also given to the need to protect the beneficial uses of air such as may be affected by volatile contaminants present in groundwater. This exposure route and potential for impact will be considered as part of the assessment of impact on human health associated with land (soil and groundwater) as noted in Section 4.1.
4.3 Beneficial uses of surface water to be protected
4.3.1 Port Phillip Bay and Corio Bay
Corio Bay lies within 100 metres east of the Refinery boundary and groundwater flowing beneath the Refinery is expected to discharge into the bay.
SEPP (WoV) F6 is an insertion into the SEPP (WoV) which identifies all the protected beneficial uses for Port Phillip Bay. SEPP (WoV) F6 applies to all the waters of Port Phillip Bay and identifies a number of protected beneficial uses within Port Phillip Bay; it also includes provisions that relate to management of the greater Port Phillip Bay catchment.
The Refinery itself lies within what is described as the Corio Segment in SEPP (WoV) F6, and defined as that portion lying west of a line drawn between Point Henry and Point Lillias and bounded by the high water mark. The protected beneficial uses for Port Phillip Bay, including the Corio Segment (as highlighted), are identified in Table 1 of SEPP (WoV) F6 and reproduced in Table 11. The auditor has had regard for these protected uses in making his assessment on the risk posed to the surface water segment. Table 11 Protected beneficial uses of the waters of Port Phillip Bay
Segment
Beneficial Use Aquatic Corio Hobsons Werribee Inshore General Reserves
Maintenance of aquatic
ecosystems and associated wildlife
Natural ecosystems
Substantially natural ecosystems with some modification
Highly modified ecosystems with some habitat values
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Segment
Beneficial Use Aquatic Corio Hobsons Werribee Inshore General Reserves
Water based
recreation
Primary contact
Secondary contact
Aesthetic enjoyment
Production of molluscs for
human consumption
Normal # populations
Aquaculture #
Commercial and recreation use of # edible fish and crustacean
Navigation and # shipping
Industrial water use
# beneficial use is protected only in parts of the segment where the activity is permitted under approved management plans
Table 12 shows the beneficial uses of Corio Bay that are nominated to be protected by the SEPP (WoV) F6, and indicates whether they are likely to be realised. Table 12 Beneficial uses of Corio Bay
Corio Bay
Maintenance of aquatic Natural ecosystems ecosystems and associated wildlife Substantially natural ecosystems with some modification
Highly modified ecosystems with
some habitat values
Water based recreation Primary contact
Secondary contact
Aesthetic enjoyment
Production of molluscs for Natural populations human consumption Aquaculture
Commercial and recreational use of edible fish and crustacean
Navigation and shipping
Industrial water use
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Corio Bay
Empty cell SEPP (WoV) F6 does not require the beneficial use to be protected
SEPP (WoV) F6 nominates the beneficial use to be protected; however it is not likely to be relevant to the segment
SEPP (WoV) F6 nominates the beneficial use to be protected and it is likely to be relevant to the segment
4.3.2 Mixing zones
It is noted that in the vicinity of cooling water outfalls (Discharge Points W2 – W5 and associated mixing zones as defined in the EPA Licence Shell Refining (Australia) Pty Ltd 46555 as amended 30/06/2013). As referred to in Condition LI_DW2 of the Licence, discharge to waters must be in accordance with the ‘Discharge to Water’ Table provided in the Licence. Therefore the State Environment Protection Policy (Waters of Victoria) (Victorian Government, 2003) objectives do not apply in these areas. The discharge of wastewater must not contain visible floating oil. For the purposes of this audit it has been assumed that this requirement should also apply to groundwater that might discharge to these mixing zones.
4.3.3 Shell Creek
Land and groundwater at the Refinery may also affect Shell Creek, an ephemeral creek running from the west past the Refinery and discharging to Corio Bay. Cooling water from the Refinery discharges to the Creek and the Creek forms a major outfall to the Bay. Because the flow in Shell Creek is largely determined by cooling water, the quality of the discharge to Corio Bay can be expected to be determined by the quality of the cooling water, although the quality of water in the portion of the Creek immediately upstream of the cooling water discharge point will be determined by groundwater and stormwater runoff discharging to the Creek.
The section of the Creek in the vicinity of the Refinery has been realigned and would appear to fall within the definition of an artificial stormwater drain. For such a drain, the requirements of the SEPP (Waters of Victoria) Part IV is that an artificial environment of this type needs to be managed for the purposes for which they were constructed and so that their impact on surface waters is minimised. For the purposes of this audit, it has been assumed that the key requirement is to ensure that the beneficial uses of the surface water into which the Creek discharges (Corio Bay) are protected.
4.3.4 Jetty
The jetty is shown in Attachment “C” of the 2011 CUN, however, for the purposes of this audit the jetty has not been distinguished as a separate area for risk assessment and contamination associated with the jetty activities was considered in the assessment of the foreshore.
In taking this approach, it is noted that contamination is not expected to be a significant issue for the jetty structure and it is unlikely that jetty activities would give rise to contamination of sediments in the immediate vicinity of the jetty. The auditor understands that ship maintenance has not been undertaken at the jetty and that spillages are very infrequent and would be expected to give rise to hydrocarbon contamination on the surface of the water and sediments along the broader shoreline rather than along the alignment of the jetty and, as such, it is appropriate to consider the risk associated with contamination in the area of the jetty in the foreshore area risk assessment.
The auditor notes that there have been tetraethyl lead spills in the foreshore area and, while related to jetty activities, it is understood that the spillages occurred in the vicinity of W3 on the foreshore and would not be related to the footprint of the jetty.
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4.4 Beneficial uses of the air segment
As discussed in Section 2.6.5, the beneficial uses to be protected under the Air SEPP are human health and aesthetic enjoyment. Effects can arise through odour and particulate material however; as these effects are linked to land and groundwater contamination, these requirements have been included in the consideration of the effects of land and groundwater contamination, rather than separately considering the requirements for protection of the beneficial uses of the air segment.
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5. Approach to Contamination Management
5.1 Clean Up Plan
As discussed in previous sections, a condition of the 2007 CUN required that a CUP for the clean up of polluted soil and groundwater on and from the premises be submitted to EPA. ERM prepared a CUP with the objective of meeting this requirement. The purpose of the CUP was to provide a plan including proposed actions to be implemented to address hydrocarbon impact present at the Refinery and in down gradient areas relating to historical refinery operations. The 2007 CUN also required that the environmental auditor verify that the CUP adequately addressed the requirements of the 2007 CUN.
In the 2010 Audit Report the auditor undertook a review of the CUP against the requirements of the CUN, the EPA Licence and the broader Victorian regulatory framework. The auditor found that the CUP broadly addressed most of the requirements of the CUN at a conceptual level; some inconsistencies were noted within the document, and the CUP lacked the level of detail required to be able to adequately implement the proposed actions. He concluded that further detail would be required to be included in remediation action plans or work plans for each action item to enable the auditor to assess the adequacy of the CUP. Where further detailed plans were required, they were included as recommendations, and have been included in the AMT (Appendix B).
The CUP stated that ‘the intent of the SMP and the individual elements is to establish a comprehensive programme with inter-connected data collection, communication and reporting that establish multiple barriers to prevent potential offsite migration and manage existing historic impacts following the implementation of the proposed remedial actions’. (pg vi ERM 2010a) This is to be achieved through a series of ‘barriers’ to protect receptors while the proposed remedial actions are implemented and beneficial uses are restored.
The barriers, also referred to as ‘pillars’ are:
Primary source management – prevention of additional hydrocarbon releases;
On-site management – recovery of on-site NAPL where practicable;
Boundary containment – containment of existing impact to within the site boundaries; and
Off-site management – control of exposure to, and recovery of, offsite NAPL where practicable.
CUP general actions include: Preparation and implementation of an integrated Primary Source Management Plan on-site.
Updating the current site Groundwater Monitoring Plan and network to assess effectiveness of remedial actions being proposed and evaluate plume conditions over time.
Implementing the revised Groundwater Monitoring Plan. Clarifying methane and carbon dioxide concentrations in soil on-site.
Implementing off-site exposure control actions to address direct contact with PSH by excavation/construction workers (via Dial B4 U Dig) and recreational users of the southern portion of the Foreshore (via an approved Coastal Management Plan / DSE consent).
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Maintaining existing off-site land use between the Saltwater intake and the Jetty (i.e. maintain Viva Energy control over permitting system and restrict access to the public). Maintaining existing controls at the Terminals site so that subsurface works are managed in accordance with their safety management system and comply with major hazard facility requirements. Continuing operation and maintenance of boundary containment.
Evaluating routine site data collection results in accordance with the SMP and completing response measures following trigger value exceedances. The above general actions are discussed and addressed in the 2013 and 2014 SMP Annual Reports.
The CUP also detailed plume specific actions for each LNAPL plume. These actions have been revised through SMPs with consideration to additional information that is available.
The CUP specified audit reports be completed by 30 September in 2012, 2014, 2017 and every three years subsequent. The draft implementation schedule provided in the CUP indicated that implementation of exposure controls related to the Coastal Management Plan, construction of trench extensions and commissioning of trench extraction points would be completed by the end of year 2 (2012). While the physical works have largely been completed, work is still underway to report on the work carried out and to confirm that these new systems are working satisfactorily. Because of this, it is recommended that the change to a three yearly audit report frequency be delayed until these actions have been fully implemented and reported.
Recommendation Continue with biennial audit reporting with the next audit report to be prepared in 2016.
5.1.1 CUP implementation schedule
The most recent CUP Implementation Schedule was provided to EPA on 19 November 2013 (see Appendix A). The following Table details the actions and proposed completion date from the CUP Implementation Schedule, and outlines progress of each action. Table 13 Progress against CUP implementation schedule
Action Scheduled completion date Progress
On-site Actions
Install monitoring wells Quarter 2 2011 Complete
CGIT extension Quarter 1 2013 Works completed; reporting on trench adequacy still to be reviewed
SGIT extension Quarter 1 2013 Works completed; reporting to be completed
SGIT additional pumping point Quarter 1 2013 Works completed; reporting to be completed
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Action Scheduled completion date Progress
Remediation Plumes 6&7 Quarter 3 2013 No longer required
Remediation of accessible low Quarter 4 2013 Further assessment priority areas required for Plume 2
On-site on-going management program
On-going groundwater monitoring On-going On track
PSM plan implementation On-going On track
SMP Annual Report On-going On track
Off-site actions - foreshore
LMP and GITs Quarter 1 2014 Works completed; reporting to be completed
Revegetation works Quarter 4 2013 Progressing
Remediation of accessible low Quarter 4 2013 Proposed remediation priority areas detailed in RID
Off-site on-going management programs
On-going groundwater monitoring On-going On track
The implementation of actions is largely on track in accordance with the 2013 schedule. Boundary containment upgrade works have been completed and reports on the works have been provided and reviewed as part of the audit process. Further work to confirm the effectiveness of the boundary containment systems is underway. The remediation works on the foreshore are substantially complete and their implementation has been witnessed by the audit team; documentation and reporting confirming the adequacy / functionality of the foreshore works has yet to be provided.
5.2 Geelong Refinery management system
The Geelong Refinery Management System (GRMS) is the overall management system for the various aspects of the Refinery operations including soil and groundwater management. The GRMS includes the Environmental Management System that is used to manage environmental matters at the Refinery. The GRMS includes more than 100 procedures and processes to assist in preventing loss of product. In the 2012 Audit Report it was noted that the auditor had requested further information to better understand how the system extends to avoid uncontrolled releases to soil and groundwater. The auditor visited the Refinery in February 2014 to assess the GRMS for primary source management and the implementation of occupational health and safety controls related to exposure to soil and groundwater contamination through the Refinery permitting system. The results of this assessment are provided in Sections 7 and 8.7.3 of this report.
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5.3 Site management plans
In order to provide for an integrated approach to the management of the soil and groundwater contamination at the Refinery, the CUP included a draft Site Management Plan (SMP) and indicated that this would be modified periodically. Updates to the SMP have included:
Site Management Plan Report, Shell Geelong Refinery, 80 Refinery Road, Corio, Victoria (ERM, 2011);
Draft 2012 Site Management Plan Report, Shell Geelong Refinery, Refinery Road, Corio, Victoria (ERM, 2012b); Site Management Master Plan (ERM, 2013h);
Draft 2013 Site Management Plan Annual Report, Shell Geelong Refinery, Refinery Road, Corio, Victoria (ERM, 2013k); and 2014 Site Management Plan – Annual report (ERM, 2014g).
The SMMP provided an overview of the site management approach and updated the management approach to reflect data obtained since the CUP and outline key outstanding actions. The 2013 and 2014 SMP Annual Reports present works undertaken and data collected in the reporting periods. The Annual Reports provide an overview of progress against CUP actions, the CUP implementation schedule and additional actions from previous SMP documents and audit reports.
The 2013 and 2014 SMP Annual Reports incorporate various supporting documents which assist in site management and document progress to ultimately prevent further releases, effectively contain contamination already present and minimise the risk that NAPL may pose to beneficial uses, and achieve a situation whereby the risks are at an acceptable level.
The 2013 and 2014 SMP Annual Reports provide the information required to make decisions on the adequacy of clean up. The SMP Annual Reports provide the mechanism for outlining the progress in managing contamination and confirming effective containment, and the strategy for clean up and management of LNAPL. Details of management, monitoring and discussion on remediation requirements are included in the SMP Annual Reports and, as such, cover the requirements of the CUP and there is not a need for a separate, updated CUP.
The SMP Annual Reports include GWMPs which were prepared as separate documents that cover this aspect of site management.
The CUP lists items which were proposed to be included in the SMP, Table 14 below details these items and indicates whether the overview of the site management approach presented in the SMMP satisfies these requirements. Table 14 CUP requirements for SMP
Item Requirement Included in SMMP
1 Timeframe for initiating detailed design and Provided in Implementation Schedule implementation of remedial actions.
2 Details for the implementation of remedial actions. Sections 3.4 and 5.4
3 Metrics to define effectiveness of boundary Refers to metrics outlined in SMP (CUP containment and remediation systems. Annex)
4 Approach to management of hydrocarbon impact Sections 3, 4 and 5 during and after implementation.
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5 Flow diagrams depicting triggers and response Refers to flow diagram in SMP (CUP actions to assess conditions over time and the Annex) need for further actions.
6 Monitoring, reporting and auditing programs to be Monitoring and reporting discussed in conducted. SMMP. Auditing program outlined in CUP but not discussed in SMMP.
The CUP lists items which were proposed to be included in annual reports: New sources identified or migration of existing plumes apparent based on data from routine monitoring and primary source management processes.
Effectiveness of the boundary containment and other remediation infrastructure. Whether remedial objectives (i.e. removal of PSH to the extent practicable) has been achieved at a plume. Practicability of PSH recovery (for initiation or cessation).
Additional assessments or remedial actions undertaken in the reporting period. Timeline for actions proposed for the upcoming year.
Required updates to the SMP, routine data collection regimes or decision-making processes (as needed) based on site conditions and observations.
These items have been discussed in the 2013 and 2014 SMP Annual Reports. Issue of the Supplementary Notice and implementation of the RID and LMP at the foreshore have allowed for the remediation of each on-site plume to be delayed until clean-up can be carried out safely. An assessment by the auditor of whether remedial objectives have been achieved for each plume will be delayed until clean-up is undertaken.
The 2012 Audit Report included a recommendation that the SMP should include a schedule of work that will allow tracking the progress of work against the requirements of the 2010 CUP (ERM, 2010) and the schedule of works presented in the letter to EPA on 18 March 2011, avoiding the need for a separate schedule outside the SMP. The 2014 SMP includes a copy of the latest CUP Implementation Schedule showing works until the end of the 2014 calendar year, which addresses this recommendation. It is recommended that a more detailed schedule of works including assessments of boundary containment, addressing audit recommendations and provision of reports to the auditor be provided with the schedule extending until the next audit report deadline.
Recommendation Provide a schedule of works up until the due date of the next audit report including assessments of boundary containment, addressing audit recommendations and action items, and provision of reports to the auditor.
5.4 On-site LNAPL management
5.4.1 On-site LNAPL management plan
ERM outlined the proposed management strategy for on-site LNAPL in the On-site LNAPL MP. The management strategy includes the following elements:
Continued implementation of the existing Primary Source Management programs;
Continued operation, maintenance and monitoring of the boundary containment system using the GITs;
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Continued off-site LNAPL management through implementation of the GWMP, implementation of foreshore GITs and LNAPL recovery; and
Continued implementation of the GWMP to monitor the nature and extent of the on-site LNAPL plumes.
The management strategy does not include full scale active recovery of NAPL and remediation of on-site NAPL while the Refinery is in operation. An analysis of the basis for this has been provided, with key documents being the Final LNAPL Baildown Testing and Analysis Report (ERM 2014a), and the On-site LNAPL MP. Key reasons provided in the On-site LNAPL MP for not undertaking full scale recovery of NAPL were that it was unlikely to: Change the current plume extent;
Change the risk profile;
Materially lessen the time it will take for natural attenuation; Change the conditions of NAPL-affected areas where access is not able to be undertaken safely;
Remove a substantial percentage of the LNAPL in the subsurface;
Materially reduce remedial costs or timeframe when the Refinery closes; and
Provide an environmental benefit greater than the environmental costs of energy and resources consumed, and wastes produced by partial remediation. The On-site LNAPL MP states that ‘The overall assessment of on-site LNAPL remediation concluded that on-site remediation during refinery operation does not present a net benefit in terms of safety, the environment or cost’ (pg i ERM 2013i).
5.4.2 Auditor review of on-site LNAPL MP
In his review of the On-site LNAPL MP the auditor has particularly considered the following issues:
Avoidance of further releases: the avoidance of further releases of product at the Refinery has been the subject of work by Viva Energy, and has been considered in previous audits. Considerable work has been carried out by Viva Energy to avoid leakage from storage tanks, and the Refinery has a large number of management systems to avoid and manage leakage and uncontrolled releases. The auditor considers that these provisions are appropriate and reduce the risk of further releases, and that the systems provide a rapid and appropriate response in the case that a release should occur. The auditor has undertaken a review of the management systems to assess their effectiveness (see Section 7 of this audit report).
Containment: assuring containment of LNAPL present at the Refinery has been a key focus of a program of work by Viva Energy and ERM, and has been considered in detail in previous audits. This resulted in a program of works to improve the trench system, including extending sections of the trenches. This latter work has been recently undertaken by Viva Energy. Reports on this work and monitoring of the trench performance are in preparation by ERM, and the auditor will be undertaking a review of this as part of the next audit to confirm that containment is effective, and that the risk associated with a lack of containment of LNAPL is low.
Risk on-site: the previous audits have assessed the risk that results from LNAPL present at the Refinery. The Refinery has operating procedures to provide for safe working practices by Refinery workers. The auditor has considered the risk that might result from vapours
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(BTEX, naphthalene, methane and carbon dioxide) arising from LNAPL, and investigations and assessments undertaken by ERM have shown that the risk to site workers is low. The risks associated with hydrocarbon components including BTEX and naphthalene were assessed in 2009. Other contaminants including styrene, heptane, and hexane were detected in the head space of groundwater monitoring wells where NAPL was present; these contaminants were not assessed in the 2009 risk assessment and will need to be assessed. This may require reference to in-building ambient air monitoring; however, as it has previously been concluded that benzene poses a low risk to on-site workers it is likely that these other contaminants will also pose a low risk. The assessment of methane and CO2 was completed in 2014 as documented in Section 8.7.1 of this report.
LNAPL Plume stability: ERM considers that the findings of their investigations, monitoring and assessments show that the LNAPL plumes are stable and are not migrating. The auditor has considered the information and the various lines of evidence, and concludes that, while LNAPL is able to move in the sense that some LNAPL will enter the containment trenches and recovery wells, the plumes are not migrating as a whole and can be referred to as effectively stable.
Feasibility of LNAPL treatment or recovery: the feasibility of LNAPL treatment or recovery has been the subject of early work by Viva Energy’s consultant, and has been the focus of a trial of MPVE on Plume 7 during the current audit period. The Plume 7 location was selected on the basis of being an area where recovery is most likely to be high relative to other locations at the Refinery.
The auditor notes that the Plume 7 MPVE pilot trial achieved quite a high rate of recovery, but the trial only took place over a short time period and recovered only a small percentage of the LNAPL that was likely to be present in the formation in the area where recovery extended to. In this respect, the trial was inconclusive as to what level of recovery might be achieved if recovery took place over an extended period.
In seeking to make a determination on whether LNAPL recovery is feasible and therefore what further work should be recommended, the auditor considered the following particularly relevant: – The extent of the hydrocarbon present in the formation practically able to be recovered by MPVE or other methods such as skimming or interception trench systems is limited. Industry experience is that recovery of LNAPL will typically be a small percentage of the LNAPL present in the formation, perhaps 30 – 40%, although this varies with the nature of the formation and the LNAPL properties. In the case of the Refinery, recoverable LNAPL appears to be restricted to thin permeable lenses, and there can be a larger mass of hydrocarbons that is present as adsorbed phase (although this varies with location). – Access to install recovery wells is very limited while the Refinery is in operation and is largely confined to roadways. The auditor notes that the Plume 7 work faced these constraints, and even installing wells in roadways was difficult, and there are concerns regarding safety of such works if carried out across the Refinery. ERM prepared a map showing the areas of the Refinery where plumes are present and the notional percentage of hydrocarbon that is likely to be recovered through a well-based recovery approach (such as MPVE). This supports the conclusion that the percentage of the total hydrocarbon present in the soil able to be recovered will be small. – A relatively complete level of hydrocarbon removal is possible through high energy methods such as excavation and thermal treatment, or in-situ thermal treatment;
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however the auditor accepts that these methods are not feasible on an operating refinery because of the access and safety limitations. – The combination of limitations in access while the Refinery is in operation, limitations in the extent to which recoverable LNAPL is able to be recovered via MPVE or skimming, and limitations in the extent of the total hydrocarbon present in the formation (including adsorbed phase) which is potentially recoverable, leads the auditor to the conclusion that the extent of LNAPL able to be recovered will be only a minor part of the total hydrocarbons present in the soils of the Refinery. If only a small percentage of the total hydrocarbon present in the soil is able to be recovered, then it follows that recovery will not result in a material reduction in risk, or a material saving in the requirements for future remediation when access become possible. Particular key considerations relating to the On-site LNAPL MP are listed in the Table below, with the auditor’s observations and comment on matters important in decision making being indicated. Table 15 Key considerations relating to the on-site LNAPL management plan
Consideration Auditor’s observations and comment
Objectives are appropriately framed and Yes in accordance with the Clean Up Plan.
Beneficial uses to be protected have Yes been identified.
Risks to beneficial uses have been Yes. assessed and the proposed strategy is The practicability of LNAPL remediation during Refinery directed to reducing off-site risks through operation has been considered, as has the likely level of boundary containment, reducing on-site remediation achievable when conducting remediation within risks through management practices, the constraints of an operating Refinery, and the and reducing the risk of further implications for remediation at site closure. contamination through primary source management.
An analysis of remediation options has Yes. been undertaken, and a trial of the A remediation feasibility assessment was included in the identified remediation technology CUP. The purpose of the assessment was to identify implemented. remedial technologies which could be implemented on-site, taking into consideration technical, logistical and financial criteria (On-site LNAPL MP). The preferred technology identified during the remediation feasibility assessment was pilot trialled.
The proposed management strategy includes:
Primary source management to reduce The auditor has undertaken an assessment of the primary the risk of further NAPL contamination source management systems at the Refinery. The on-site. assessment found that systems were in place to manage primary sources including risk assessment, change management, infrastructure management, leak detection and identification of uncontrolled releases.
Boundary containment to reduce the risk Upgrade works have been undertaken to improve the of on-site NAPL migrating off-site. effectiveness of the interception trenches, further testing to demonstrate the effectiveness of the system is planned. The auditor will review the outcomes of this testing when provided.
Groundwater monitoring plan with The groundwater monitoring plan and results of the triggers to implement further monitoring for each audit period will be reviewed by the
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Consideration Auditor’s observations and comment management actions to address any auditor. changes to the current contamination status on-site.
The auditor’s review supports the conclusion that ERM has reached in preparing the On-site LNAPL MP. However, these considerations relate generally to LNAPL present at the Refinery. The auditor notes that in the particular case of the location near Nerita Gardens, access is possible. Additional information is required before a decision can be made as to what is required in this area, and this will be the subject of further work. This may require further delineation of the contamination in this area, and a review of the effectiveness of boundary containment and the potential risk to off-site receptors before a management strategy is accepted for Nerita Gardens.
The CUP provided an approach to management of on-site LNAPL. The Table below details the general and specific actions for on-site plumes and indicates whether the On-site LNAPL Management Plan is compliant with these requirements. Table 16 CUP requirements for management of on-site LNAPL
Item Requirement Included in On-site Management Plan
1 Continue on and off-site monitoring in Yes accordance with GWMP
2 Plume 1 – perform PSH recovery (where On-site LNAPL reduction no longer accessible) if PSH present at property line. required as per Supplementary Notice, however this issue is related to boundary containment of LNAPL. See Table 19 for an assessment of priority for boundary containment.
3 Plume 1 – install additional monitoring wells Yes MW292 installed February 2011
4 Plume 2 – perform PSH recovery (where On-site LNAPL reduction no longer accessible) if PSH present at property line required as per Supplementary Notice, however this issue is related to boundary containment of LNAPL. See Table 19 for an assessment of priority for boundary containment.
5 Plume 2 – install additional monitoring wells A number of additional monitoring wells have been installed within and downgradient of Plume 2
6 Plume 6 – install recovery point in vicinity of On-site LNAPL reduction no longer MW068 and perform periodic recovery via required as per Supplementary Notice, vacuum truck however this issue is related to boundary containment of LNAPL. See Table 19 for an assessment of priority for boundary containment
7 Plume 7 – Perform active PSH recovery from MPVE Pilot Trial undertaken in MW307 new wells, additional monitoring wells may be and surrounding wells. Further recovery warranted (exact number and spacing to be no longer required as per Supplementary determined in detailed design) Notice
8 Plume 7 – Install proposed monitoring wells MW300 and MW301 installed February 2011
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5.4.3 Supplementary Clean Up Notice
EPA issued Supplementary Notice 90004215 on 24 September 2013. In this Supplementary Notice EPA noted the auditor’s recommendation for a change to the implementation of Requirement 2 of CUN 90000024 [NO10056] and that full scale remediation of LNAPL across the Refinery can be delayed until safe access becomes practicable, and EPA agreed in principle that active full scale recovery of on-site LNAPL from the Refinery could be postponed until such time that access to the site was available or until the Refinery had ceased to operate. Copies of the CUN and Supplementary Notice are provided in Appendix A of this report.
5.5 Foreshore LNAPL management
5.5.1 Remediation implementation design
The Remediation Implementation Design (ERM 2013l) (RID) detailed the remedial goals and objectives to manage risks to human health and the environment related to hydrocarbon in the foreshore. The RID states that it was made clear through stakeholder engagement that full-scale excavation of the foreshore and beach (required to immediately restore beneficial uses and mitigate human health risks) was not a desirable alternative. A remedial approach to restore beneficial uses over time with exposure controls was adopted. The RID notes that the strategy proposed is intended to address the following objectives:
Recovery of LNAPL in accordance with the principles of CUTEP;
Protect human health by reducing potential exposure to LNAPL;
Reduce the likelihood of migration of LNAPL toward the beach;
Preserve and improve foreshore amenity; and
Provide a favourable outcome for stakeholders.
A Remediation Alternatives Assessment was undertaken which identified the preferred approach to addressing LNAPL in the foreshore as a combination of actions including:
Installing passive containment trenches;
Manually recovering LNAPL via low energy technology;
Controlling traffic, discouraging pedestrian access and installing warning signage to deter digging in the beach;
Revegetating the foreshore;
Implementing controls such as dial before you dig to warn subsurface workers of exposure risks; Monitoring groundwater; and
Continuing operation of the GITs (ERM 2013e).
It is understood that the method for revegetating the foreshore has been altered; however the end result remains the same.
5.5.2 Auditor review
The auditor reviewed draft and final versions of the RID document. Auditor comments were provided for consideration as further works were undertaken; these comments related to:
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Potential for NAPL from Plume 10 to enter backfill around the W3 discharge line up gradient of the foreshore trenches and for the discharge line to provide a preferential pathway past the trenches to the bay;
Monitoring of groundwater and LNAPL following trench construction will provide information on mounding and flattening due to the trench; Thickness of HDPE, contact between layers of HDPE and well construction;
Monitoring to detect changes in hydraulic head as well as NAPL presence and thickness; and Methodology for categorising areas of the beach as impacted.
The auditor considers that removing the connection of NAPL in the beach zone to upgradient NAPL can be expected to increase the rate of natural depletion and clean up of NAPL in the beach zone (the location with highest risk of exposure to NAPL).
The CUP included requirements relating to the management of existing off-site LNAPL on the foreshore. The Table below details the general and specific actions for the foreshore in this approach and indicates whether the RID is compliant with these requirements. Table 17 CUP requirements for off-site LNAPL management
Item Requirement Where requirement is addressed
1 Continue ongoing groundwater Included in RID and SMP Annual Report monitoring in accordance with the GWMP
2 Continue operation of the LNAPL This requirement has been agreed to be modified skimming system which operated in given the implementation of the NAPL barrier and the Foreshore at the time of the CUP passive interception trench as discussed in the 2014 SMP Annual Report
3 Reduce the potential for risks to Addressed by implementation of Landscape foreshore recreational users by Management Plan implementing measures to control exposure to LNAPL in the beach area via a Coastal Management Plan
4 Implement off-site exposure control Included in RID and the Dial Before You Dig actions to address direct contact with notification process has been demonstrated to be LNAPL by excavation/construction in operation; this addresses this requirement. workers via a Dial Before You Dig notification
5 Attempt hydrocarbon recovery from a MPVE has not been undertaken in the foreshore limited number of wells in the as the approach to remediation has now been Foreshore via mobile multi-phase modified as outlined in the 2012 Audit and low vacuum extraction (MPVE) energy recovery has been implemented in conjunction with installation of a NAPL barrier and passive recovery trench and discussed in the 2014 SMP Annual Report.
6 Maintain existing off-site land use While not discussed in the RID, restriction of public between the saltwater intake and the access to this area is discussed in the 2014 SMP jetty (ie maintain Viva Energy control Annual Report over permitting system and restrict access to the public)
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Item Requirement Where requirement is addressed
7 Continuation of operation and Included in RID and 2014 SMP Annual Report maintenance of boundary containment
Recommendation Continue to implement the foreshore Remediation Implementation Design and Landscape Management Plan.
5.6 Operation of boundary containment system
The Groundwater Remediation Systems: Operation, Maintenance and Monitoring Manual (OM & MM) (ERM 2009b) was prepared to describe the design and operation of the three GITs which have been installed to intercept and contain NAPL and groundwater present on the Refinery. At the request of Viva Energy the OM&M Manual was not reviewed. Since preparation of the OM&M Manual there has been considerable change to the containment system and its operation, and as such the 2009 OM&M Manual is now largely redundant and requires updating. Section 6.1.1 of the draft 2012 SMP (ERM, 2012b) referred to a 2012 version update and a summary of OM&M Manual Updates; however, these have not been provided to the auditor for review.
The 2014 SMP Annual Report indicates that operational metrics will be incorporated into an updated Operation and Maintenance Manual, and lists the proposed metrics. The primary performance metric proposed is a gradient from groundwater elevation in the natural formation to the trench fluid elevation and/or a gradient towards an extraction point. A gradient into the trenches from the adjoining formation is considered the primary performance metric. Percentage drawdowns of static levels in sumps have also been proposed as a metric for assessing trench effectiveness. These percentages will be reviewed once the ETOP report has been reviewed by the Auditor. Table 18 CUP requirements for boundary containment
Item Requirement Where requirement is addressed
1 Continue OM&M of boundary SMMP containment
2 NGIT – improve SumpN operational Reported in 2014 SMP Annual Report status and flow rate data retrieval
3 CGIT – extend CGIT approximately Discussed in 2013 SMP Annual Report. The auditor 70 m including additional extraction understands that his previous comments on the point GWIT Extension Construction Report have been addressed in a report issued on 15 September 2014, however this report has yet to be reviewed.
4 SGIT – convert MW289 to an Installation of SumpS2 in the vicinity of MW289 is extraction point reported in the 2014 SMP Annual Report. The auditor’s comments on the GWIT Extension Construction Report are yet to be addressed.
5 SGIT – extend SGIT approximately Discussed in 2013 SMP Annual Report. The auditor’s 65 m to the west, including and comments on the GWIT Extension Construction additional extraction point Report are yet to be addressed.
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Recommendation The OM&M Manual should be revised (Item C.1.18 of the AMT).
Suggested actions In updating the OM&M Manual, consideration should be given to the following:
Including measures and indicators that provide assurance that the system is operating as designed, that containment will be effective, and that any malfunction is identified and rectified in a timely way (Item C.1.21.1 of AMT).
Including requirements for monitoring that will provide verification that the system has been providing effective containment. Such monitoring may be included in the GWMP, if convenient (Item C.1.21.2 of AMT).
Whether the OM&MM should be regularly updated to reflect the changes that have occurred in the design and operation of the containment trench system (Item C.1.21 of AMT).
Including the requirement for periodic sump shutdown and groundwater recovery tests to confirm that the trenches are providing effective containment (Item C.1.5 of AMT).
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6. Review of works undertaken
6.1 Process used to assess progress and adequacy
In this section the implementation of the actions proposed in the CUP, the recommendations made in the 2012 Audit Report and additional recommendations made throughout the audit (as captured in the AMT) are assessed and reported on.
This review considers the requirements relating to the Site Management Plan and the broader site management, and progress on specific actions undertaken against each of the four pillars and listed in the Action Management Table. The findings of the latter review are summarised in the Action Management Table, and are discussed in the following sections. Available documentation and information on actions carried out were assessed against the actions proposed in the CUP the recommendations of the 2012 Audit Report and additional recommendations in the AMT. The 2013 and 2014 SMP Annual Reports were the primary sources of information, and reference was also made to a number of supplementary documents listed in Section 1.4 of this audit report. This review also assessed progress against the implementation schedule / timeline submitted to EPA on 18 November 2013 (and included as Annex B in the 2014 SMP Annual Report).
Many of the actions involve complex matters, and there is an evolving state of knowledge that can affect a proposed action and its timing. Viva Energy and its consultant have been carrying out investigative work and have been preparing many documents, and this body of work is being reviewed by the auditor as it evolves. The process of preparation and review of documents will continue beyond this audit, and the status of documents and actions will be reported on in subsequent audits.
In assessing adequacy of the works undertaken, the auditor has considered whether particular matters are now understood to a level that allows them to be adequately managed, whether management actions are now in place to adequately manage the issue, whether further action is required, and whether, overall, progress is generally consistent with the requirements of the CUP and the auditor’s previous recommendations.
The progress of actions to address recommendations in the 2012 Audit Report AMT is outlined in Appendix B. This table indicates where recommendations have been addressed, are on-going or are outstanding.
6.2 Conceptual site models
The following CSM documents have been reviewed over the 2013/2014 audit period:
Foreshore Conceptual Site Model Plumes 9, 10, 11A and 11B dated 5 July 2012 and response to auditor’s comments dated 30 June 2014; ERM letter of 30 June 2014 responding to comments on the Foreshore CSM;
Conceptual Site Model Plume 6 dated 23/04/2013;
Conceptual Site Model – Plumes 7 and 13 dated 23/04/2013;
Conceptual Site Model Plume 2 versions dated 26/06/2013 and 2/07/2013;
Final Draft Conceptual Site Model Plumes 8/8A/8B/8C and 12 dated September 2013; and
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CSM Addendum Final Draft Memo dated 24 June 2014.
The auditor considers that the approach of developing individual CSMs is consistent with international and national guidance on environmental and NAPL assessment and considers the source, distribution and risk of migration of NAPL plumes, with a particular focus on plumes where a risk to a receptor or loss of boundary containment was possible. GHD provided comments on the CSMs (except for the Plume 8 and 12 CSM) and ERM responded with the CSM Addendum and letter dated 30 June 2014 responding to comments related to the Foreshore CSM. The CSM Addendum provides a discussion on geology and LNAPL distribution, and recognises the complexity of the geology and the uncertainty of the presence of higher permeability zones and their influence on plume migration. The CSM Addendum notes that the following are key concepts the auditor considers when assessing CSMs:
Historic evidence, when combined with data such as that gathered by LIF, indicates that the distribution of NAPL within permeable zones is interconnected although the migration path can be complex and result in a NAPL plume that is not laterally continuous across an entire area.
Without an ongoing primary source of NAPL, significant migration of NAPL into previously un-impacted zones appears unlikely. However, there is uncertainty in this, and it is not clear that the distribution and extent of NAPL has been well defined, or that inferred plumes are in fact continuous or discrete as inferred in the plume maps that have been prepared. There is also uncertainty with respect to time: the presence of NAPL in wells may change over time, particularly in response to hydrological changes.
Whether the GITs fully intersect the NAPL and have or will have the ability to prevent further migration of NAPL off-site (even if within an existing LNAPL plume), and the degree of certainty that there is this. Where there is uncertainty (i.e. where no GIT exists, or in areas still to be addressed such as within the SGIT etc) the summary statement should indicate the risk that is posed (e.g. whether further migration could occur), and the wells that can be used to monitor this.
Although the auditor’s understanding of the site conditions point to a greater level of uncertainty in plume stability than discussed in the CSM Addendum, the auditor considers that with the implementation of the On-site Management Plan (and issue of the Supplementary CUN), foreshore RID, GIT upgrades and further assessment of Plume 2 the risks posed by potential migration of LNAPL are being appropriately assessed and/or managed.
The auditor has provided a number of other comments specific to each CSM that have not been addressed. The information provided in the CSMs and CSM Addendum has been useful in prioritising where additional assessment is required (such as Plume 2) and in the reappraisal of risk for each plume. When a CSM is updated in the future to consider new information or to assist in understanding of the situation at a particular focus area, these comments should be considered.
Suggested action If there is a change to understanding of any areas of the site due to an uncontrolled release/ new contamination issue or if undertaking a risk re-appraisal, CSMs should be reviewed and updated as necessary (Item B.1.4 of the AMT).
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6.3 Groundwater monitoring plan
Groundwater monitoring reported in the 2013 SMP Annual Report was undertaken in accordance with the Draft 2012 Groundwater Monitoring Plan (ERM 2012) (2012 GWMP) which was included as Annex E of the Draft 2012 Site Management Plan, Shell Geelong Refinery (ERM 2012b). Groundwater monitoring reported in the 2014 SMP Annual Report was undertaken in accordance with the 2013 GWMP. The 2014 SMP Annual Report included a Groundwater Monitoring Plan for quarter 2 2014 to quarter 1 2015 dated 1 July 2014 (the 2014 GWMP).
GWMPs outline the proposed groundwater and NAPL monitoring for on-site and off-site plumes. GWMPs include a groundwater monitoring schedule and information on the basis for the plan, including well network selection, groundwater gauging and sampling methodology and a plan for data interpretation. Also included in the GWMP documents are triggers for additional analysis and assessment of potential for LNAPL migration or new LOPC.
6.3.1 2012 Groundwater monitoring plan
The 2012 GWMP provided proposed monitoring for the period quarter 2 2012 to quarter 1 2013. The results of this monitoring were reported in the 2013 SMP Annual Report.
The 2012 GWMP was reviewed during the previous audit period and discussed in the 2012 Audit Report. In response to the 2012 Audit Report recommendation ‘Review the GWMP to further reduce groundwater sampling requirements in low risk on-site areas where NAPL gauging is of greater value and resources could be redirected to higher priority activities’ (pg 31 GHD 2012b) a number of wells were excluded from dissolved phase hydrocarbon analysis during the quarter 2 2012 groundwater monitoring event.
6.3.2 2013 Groundwater monitoring plan
The 2013 GWMP provided proposed monitoring for the period quarter 2 2013 to quarter 1 2014. The results of this monitoring were reported in the 2014 Groundwater Monitoring Report which was provided as Annex E to the 2014 SMP Annual Report.
The audit review of the draft 2013 GWMP found that:
The GWMP had been revised in general accordance with the requirements of the 2012 Audit.
The GWMP provided a clear and well-structured risk-based monitoring plan appropriate for the Refinery.
The GWMP generally provided a clear guide to well selection for gauging and sampling. The following comments were provided for consideration:
• In the case of increasing dissolved phase concentrations followed by LNAPL in an on-site well, consideration should be given to whether bi-annual gauging is enough to identify and monitor plume migration.
• If GP17 will not be replaced, considerations should be given to how GIT effectiveness in this area can be demonstrated. • Consideration should be given to whether the proposed sampling and gauging is enough to identify and monitor plume migration and GIT effectiveness.
• Some wells were not proposed for gauging and/or sampling due to close proximity to other wells. A number of these wells are located considerable distances (50 m or more) away from the gauged or sampled well discussed in the ‘comments’ column of Table 1 of the
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GWMP. Consideration should be given to the distance to other wells proposed for gauging or sampling, and the geology and construction of these wells when discounting wells from the gauging and sampling program.
• Section 3.4.2 of the GWMP stated that dissolved phase sampling will focus on demonstrating NAPL migration beyond the site boundary. However there are a number of boundary areas not covered by gauging and/or sampling including, western tank farm (MW135 and others) and foreshore (MW062).
• The sampling methodology proposed may not result in the samples collected being representative of formation water. While low flow sampling is the preferred method, where other methods are adopted consideration needs to be given to purging until water quality parameters stabilise and groundwater turbidity is minimised. Care should be taken to reduce the loss of volatiles during purging and sampling.
These points were considered in the preparation of the 2014 GWMP.
6.3.3 2014 Groundwater monitoring plan
The 2014 GWMP provides proposed monitoring for the period quarter 2 2014 to quarter 1 2015. Groundwater monitoring for this period has not yet been completed and the results of monitoring for the period have not been reviewed in this audit report.
The auditor’s review of the 2014 GWMP found that:
GP17 is damaged, and has not been replaced and is proposed for ongoing sampling. The set of data for this well is not reliable and this will need to be considered in the appraisal of the upgraded SGIT.
The sampling methodology proposed may not result in the samples collected being representative of formation water. While low flow sampling is the preferred method, where other methods are adopted consideration needs to be given to purging until water quality parameters stabilise and groundwater turbidity is minimised. Care should be taken to reduce the loss of volatiles during purging and sampling.
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7. Primary source management – current status
The auditor and his assistant undertook a site visit of the Refinery on 6 and 7 February 2014. During the site visit, the auditor interviewed individuals in various roles and sighted relevant documentation regarding primary source management. A report has been prepared and is included in Appendix E. With respect to the management of risks, mitigation measures and emergency response for primary source management at the Refinery, the audit found:
An integrated management system is in place; this includes appropriate environmental management practices and extends to primary source management.
A well-established risk assessment process is in place; this includes the identification of where uncontrolled product releases might occur and the controls that should be applied.
A well-established process is in place for managing change to plant and infrastructure to avoid uncontrolled releases.
Documentation is available that demonstrates good practice management, including a top down approach with the identification of regulatory and environmental risks. Strategies and management plans for the various classes of assets are risk based, appropriate, and logical. There is a well-established process for management of change. Significant funding is allocated to projects and/or programs that address higher risk areas with the potential of uncontrolled product release.
A structured program is in place to manage tanks to reduce the risk of leakage. The program includes tank decommissioning and replacement, refurbishment of tanks and a program of ongoing monitoring and maintenance.
A program is in place to identify leaks in underground assets; this includes repair or replacement of assets where required. A Permit to Work system is in place; this includes the assessment and control of risks to occupational health and safety and public health when works are being undertaken on assets.
In particular, this includes a tundish and drainage line replacement program, and a project for replacing Field Sump 5. A well-established program is in place to identify uncontrolled releases of product, and there is a structured emergency response plan to manage releases should they occur.
Recommendation Continue implementation of the tundish and drainage line replacement program, and replacement of Field Sump 5.
Suggested action Provide the auditor with quarterly updates on the tundish and drainage line replacement program to confirm compliance with project timelines, and the project for replacing Field Sump 5.
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8. On-site management – current status
8.1 Overview
On-site, the core monitoring objectives relate to understanding the risk posed by NAPL and minimising this risk. In terms of monitoring, this particularly involves providing information on the extent of NAPL and its potential for recovery, the location of NAPL with respect to the site boundaries and confirming that NAPL is contained and does not migrate beyond the boundary of the Refinery, and confirming that there have not been further releases of NAPL. In previous audits it was considered that, because of the extent of NAPL at the Refinery, an assessment of the concentrations of dissolved phase hydrocarbons generally had limited value other than near site boundaries where no measurable NAPL had been identified. Because of this, seeking to identify trends in dissolved phase concentrations has not been a focus of the audits. It is recognised that there are practical limitations in much of the data: the monitoring wells generally have screens intersecting a number of more permeable zones to depth and therefore groundwater samples are unlikely to be good indicators of proximity to NAPL; and the sampling methodology adopted has the potential to give rise to turbid groundwater samples which may not be representative of dissolved phase concentrations. While there are practical limitations, the data is assessed in the SMP Annual Reports to determine whether there may be increasing trends in dissolved phase concentrations of contaminants of concern.
Previously, the management of on-site NAPL has been subdivided into eight on-site plumes, with sub-plumes being identified for two of these plumes (Plumes 3 and 8) to assist in describing areas of the plumes adjacent to the site boundary. It is recognised that the extent of plumes may vary from that inferred: some of the plumes may be joined, and some of the plumes may not have NAPL continuously present across the inferred extent.
In previous audits the requirements for management of on-site NAPL plumes have been prioritised for action on the basis of risk and the requirement of achieving containment. The 2010 Audit concluded that total clean up of NAPL at the site in the short term was likely to be impractical given the extent of contamination at the site and that the Refinery is still operational. It was considered that the overarching statutory objectives to remove NAPL and restore beneficial uses were unlikely to be realised in the short term and, instead, in the short to medium term clean up should be carried out in accordance with the principles of clean up to the extent practicable.
The 2012 Audit Report considered the further work that had been carried out prior to the completion of the 2012 audit. The risk-based strategy outlined in the 2010 Audit and 2010 CUP for the on-site contamination was supported. Core objectives were to prevent further releases of NAPL, to confirm that NAPL is contained and does not migrate beyond the boundary of the Refinery, and to determine the potential for useful recovery of NAPL given the logistical constraints posed by the Refinery operations.
8.2 Remediation trials
To determine the potential for useful recovery of NAPL, bail-down testing and a MPVE pilot trial were undertaken during the 2013/2014 audit period. Plume 7 was selected for this trial because it was considered to offer the greatest potential for LNAPL recovery. The objective of the pilot trial was to evaluate the feasibility of using well-based MPVE to recover LNAPL from the subsurface within the Refinery site boundaries. Details of the MPVE Pilot Trial were reported in MPVE Pilot Trial (ERM 2013j). The trial took place over five days, and involved vapour, LNAPL and total fluids removal with approximately 537L of
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LNAPL equivalent being recovered. The MPVE Pilot Trial Report concluded that remedial technologies based on wells would not make for an efficient, effective or sustainable remedial solution, as it would not result in a material difference in condition of the existing sub surface, a reduced risk profile, or reduced need for clean up following Refinery shutdown.
The results of the trial indicated:
The LNAPL recovery rate was variable, with a relatively high initial rate of recovery being achieved from well MW312, the LNAPL to water ratio was low (2%) and the data was not sufficient to provide a reliable estimate of the LNAPL capture zone and radius of influence, but it appears that the radius of influence may be in the order of 20-30 m in the area of the trial.
The trial was of limited duration, and the report did not provide information on whether the rate of LNAPL recovery would reduce with time. The MPVE trial involved substantial drawdown of the groundwater, and it was observed that there were wells where the thickness of NAPL increased following MPVE, and one well where NAPL was present after MPVE that had previously not contained NAPL. Baildown testing was undertaken across the site and the results were reported in the Draft LNAPL Baildown Testing and Analysis Report – Shell Geelong Refinery, Corio, Vic (ERM 2014a) The baildown report provides both a re-analysis of old data as well as additional transmissivity data; generally the interpretation of data was appropriate. The auditor notes that:
The baildown testing indicates that transmissivity is variable across the Refinery and within plumes.
There is some uncertainty as to whether the baildown results provide a representative characterisation of recoverability and transmissivity, as they can be dependent on whether a permeable layer is located near the watertable. In some areas the site has multiple layers of NAPL and a greater volume of NAPL may be recovered from confined layers in a MPVE trial, than are recovered during baildown testing.
It was noted that MW307 was assessed as having low transmissivity, yet the pilot trial recorded very high recovery rates of NAPL from this well and well MW312. The auditor also provided discussion on items to be considered when assessing remediation options in the future (when access to the site is available or the Refinery has ceased to operate).
The information provided in the MPVE Pilot Trial Report and Baildown Testing Report was used to develop a management plan for on-site LNAPL.
8.3 On-site LNAPL management plan
Developing a plan for management of on-site LNAPL involved a range of considerations and discussions between Shell, ERM and the auditor. The auditor notes the following key considerations:
The trials show that LNAPL can be recovered in some locations; The extent of recovery that will be achieved in practice using technologies such as MPVE is uncertain and likely to be limited to only a portion of the total hydrocarbon contamination present in the subsurface; and
The ability to undertake recovery across the Refinery while the Refinery is in operation is severely limited by safety considerations.
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Based on the various considerations, ERM developed an On-site LNAPL Management Plan (MP) which proposed a strategy for management of LNAPL in groundwater on the Refinery site. This Plan concluded that ‘the potential for LNAPL recovery using well-based hydraulic recovery technology is considered limited and would not be scalable under the current operational access constraints’ (pg 17 ERM 2013i).
This plan and a letter providing comments from the Auditor were provided to EPA. EPA subsequently issued a Supplementary Clean Up Notice in September 2013. In this Supplementary Notice EPA acknowledged the auditor’s recommendation for a change to the implementation of Requirement 2 of CUN 90000024 [NO10056], that full scale remediation of LNAPL across the Refinery can be delayed until safe access becomes practicable. EPA agreed in principle that active full scale recovery of on-site LNAPL from the Refinery could be postponed until such time that access to the site was available or until the Refinery had ceased to operate.
Based on these considerations, the auditor has concluded that the priority for remediation of on- site plumes is low, and the priority should be directed to ensuring there is good on-site management of groundwater contamination including:
Boundary containment;
Management of on-site risk to workers; and
Groundwater monitoring to identify potential loss of primary containment or migration of plumes off-site.
Site wide recommendations from the AMT have been closed out with the exception of the on-going recommendations noted below.
Recommendation Continue monitoring NAPL plumes and groundwater quality in accordance with the GWMP (Item B1.1 of the AMT).
Suggested action If changes occur to monitoring observations or remediation systems that could have risk implications, the risk should be re-appraised (Item B1.3 of the AMT).
8.4 Implementation of the on-site LNAPL management plan
The requirements of the On-site LNAPL MP include:
Continued implementation of the existing Primary Source Management programs;
Continued operation, maintenance and monitoring of the boundary containment system using the GITs; and Continued implementation of the Groundwater Monitoring Plan to monitor the nature and extent of the on-site LNAPL plumes.
The results of the above requirements for the reporting period are provided in the 2014 SMP Annual Report.
Recommendation Continue to implement On-site LNAPL Management Plan and comply with the Supplementary Notice.
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8.5 Groundwater monitoring
Groundwater monitoring was undertaken in accordance with the GWMPs and reported in the 2013 SMP Annual Report and the 2014 SMP Annual Report.
Where routine groundwater monitoring identified conditions (exceeding triggers relating to LNAPL) suggesting a LOPC may have occurred, the wells are placed on a Watch List. The 2013 SMP Annual Report indicates that LNAPL triggers were exceeded in six wells during the monitoring period reported. These wells were placed on a Watch List resulting in continued monitoring and collection of an unscheduled sample for LNAPL fingerprinting analysis. The fingerprinting analysis indicated that LNAPL composition was consistent with historical analysis and no further action was warranted. The wells remain on the Watch List and will be routinely gauged. The 2014 SMP Annual Report identified four monitoring wells where LNAPL thickness triggers were exceeded in the monitoring period. Two of these wells were located within a trench and investigation of a faulty pump likely caused increased LNAPL in a third well. Well MW186 has reported increasing LNAPL thickness since 2005, a sample of LNAPL was collected in quarter 2 2014 and will be reported in the next SMP Annual Report. This well has been placed on the Watch List.
The SMP Annual Reports provide trends of dissolved phase contaminants using software developed by Shell who previously owned and operated the Refinery. There are some discrepancies between the output of the software and the assignment of trend in the SMP Annual Reports. The Auditor proposes to undertake a more detailed review of the process for assigning trends (including the range of data used) if required at as part of decisions regarding boundary containment or in the re-appraisal of risks.
8.6 Loss of primary containment
The Refinery Incidents and Actions Database (IAD) contains suspected Loss of Primary Containment (LOPC) events (such as leaks and spills of product), and these events are investigated. The SMP Annual Reports provide summaries of potential LOPC to land events added to the IAD, and where there is a potential for impact on soil and groundwater a process of investigation is followed including review of groundwater gauging data.
Additional monitoring to investigate a potential amine release from process unit ARU2 was undertaken in quarter 4 2012 and reported in a letter titled Draft-Summary of Unplanned monitoring to Assess a Potential Amine Release from Process Unit ARU2 at the Shell Geelong Refinery, Corio, Vic dated 31 January 2013 which is included as an Annex to the 2013 SMP (ERM 2013k). Wells around ARU2 were sampled; the concentrations of contaminants of concern were determined to be below the laboratory detection limit except for nitrate / nitrite, which was below the concentration measured in a background monitoring well. The results suggest that the suspected LOPC which occurred near ARU2 has not impacted the local groundwater. The auditor understands that further sampling and analysis has been undertaken and will be reported in the next SMP Annual Report. The 2013 SMP Annual Report also states that monitoring data was reviewed in response to suspected LOPC in areas above Plume 3 central and Plume 3D, but no evidence of significant LOPC was identified.
The 2014 SMP Annual Report discusses seven potential LOPC to land with the potential to impact soil and groundwater. Evidence of significant impact to groundwater was not identified in four
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cases, the other three cases occurred after the monitoring period reported in the 2014 SMP Annual Report. Monitoring wells associated with the LOPC events have been added to the Watch List. Additional actions were not triggered by identified LOPC on site during the reporting period. The suspected LOPC of amines in 2012 will continue to be followed up via additional monitoring in the next reporting period. During the Auditor’s PSM site inspection it was noted that Field Sump 5 (FS5) has been identified as being a significant contributor to the Refinery groundwater plume, with instances of overflows from the sump occurring. There is an approved project for the replacement of FS5 which is in the construction phase. The IAD database identified overflows in November 2003, October 2007 and July 2010 and these incidents and follow up investigations have led to this significant replacement/upgrade project. There needs to be consideration of whether overflows from this field sump have impacted groundwater contamination and should be considered by ERM for inclusion in SMP Annual Reports.
Recommendation Determine whether overflows from Field Sump 5 have been considered as a possible source of groundwater contamination for inclusion in the SMP Annual Report, and include in the SMP if necessary.
8.7 On-site health risk assessment
8.7.1 CO2 / Methane
Methane and carbon dioxide monitoring was undertaken once a week over a period of four weeks over November and December of 2013. The gas monitoring was undertaken as an initial reading from locations identified as potential preferential pathways for gas migration into buildings such as from utility conduits, crawl spaces and floor and wall joints before conducting monitoring for an extended period of between 6 and 8 hours in six buildings which were infrequently occupied and where ground gases (generated from the biodegradation of petroleum hydrocarbons below the Refinery) could accumulate potentially providing an acute risk of explosion or asphyxiation.
The monitoring in higher risk buildings was conducted over a range of atmospheric conditions including over decreases in atmospheric pressure that can provide a pressure gradient conductive to advective flow of ground gases. Methane was not detected in any of the enclosed spaces either during the monitoring of potential gas migration pathways or during extended monitoring within the buildings. No exceedances of the carbon dioxide screening criteria were detected with a maximum concentration of 0.09% vol. detected and there was no evidence of depleted oxygen environments identified.
Overall the monitoring methodology appeared appropriate to gather methane and carbon dioxide readings within higher risk buildings over an extended time period and spatially distributed across the site and the results indicate gas build up in these environments is a low risk on the Refinery.
The risks to workers potentially exposed to vapours in on-site excavations was assessed separately by the Auditor in 2014 via a review of the site management practices and how they are applied in both operational and non-operational areas (eg. Nerita Gardens) of the Refinery. The Auditor found onsite procedures appropriate to manage risks associated with intrusive ground works at the site.
The Auditor considers that further investigation into methane and carbon dioxide gas build up is not required given the low risk identified by the assessor’s monitoring program. The AMT items B.10.1 to B.10.8 have effectively been closed out by the Auditor site inspection and the methane and carbon dioxide monitoring report.
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8.7.2 Other volatile contaminants
The ERM 2009 Targeted Gas Sampling Assessment Report reported elevated concentrations of styrene, benzene, heptane, hexane and toluene in headspace gas samples taken from monitoring groundwater monitoring wells that intersect NAPL. ERM completed a human health risk assessment in 2009 which included monitoring of benzene and toluene in site buildings and using monitoring patches on site personnel. The monitoring did not include styrene, heptane or hexane. However it is likely that the assessment of benzene would be the main driver of risk and that if the risks associated with benzene and toluene were acceptable, and it can be expected that the risk posed by other contaminants to on-site workers will be acceptable. The auditor understands that ERM is preparing a note confirming this.
Recommendation Review information relating to soil vapour and on-site building monitoring and confirm that the risk posed by volatile gases is acceptable (Item B.10.9 of AMT).
8.7.3 Permit to work system
A site visit was conducted at the Refinery on 6 & 7 February 2014 by the auditor and his assistant. During the site visit, individuals in various roles were interviewed and relevant documentation was sighted regarding primary source management and the Permit to Work system.
The Permit to Work system includes evaluation of occupational health and safety and environmental risks and, where applicable, risks to the public. A Permit to Work approval must be obtained before any work (other than routine monitoring tasks) can be undertaken at the site. This includes non-plant areas, such as the gardens and other areas surrounding the Refinery. Excavation Permits are required for any digging or excavation works where the depth exceeds 75 mm. An application is made for excavation works with a detailed description of all works to be undertaken, including drawings. Only approved individuals are allowed to sign off an excavation permit; this requires extensive checking of drawings and documentation, with a particular focus on underground services and risks (such as the presence of NAPL). Excavation permits are issued as part of the Permit to Work system.
It was concluded that the Refinery assesses and controls risks for occupational health and safety, and for public health, for works being undertaken on assets, as part of the Permit to Work system.
8.8 Plume 2 investigation
Additional works to delineate contamination in the Nerita Gardens area were undertaken and reported in the 2014 Plume 2 Drilling Summary Report (ERM 2014d) (Plume 2 Report) and summarised in the 2014 SMP Annual Report. Nine monitoring wells were installed on and off-site with soil samples collected and analysed during drilling. The wells have been incorporated into the GWMP. The Plume 2 Report concluded that Plume 2 may extend along the down gradient edge of Nerita Gardens to the north between MW325 and MW333. However, hydrocarbon odour and black staining were observed in MW333 during drilling, indicating that hydrocarbon impact may extend to the north beyond this point. The report also concluded that Plume 2 may extend along the down gradient edge of Nerita Gardens to the south between MW059 and MW329. However dissolved phase hydrocarbon concentrations exceeding the site-specific solubility limit for TRH C15-C28 were reported for MW059 indicating that hydrocarbon impact may extend to the south of this point.
No evidence of hydrocarbon impact was observed during drilling in wells across Shell Parade on GGS property, however it is not clear how far under Shell Parade the contamination extends, or
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whether the newly installed monitoring wells would interest LNAPL if present. Suggested practices to assess boundary containment should include: Monitoring dissolved phase contamination in newly installed wells to further assess the extent of contamination on and off-site;
Considering the need for further monitoring wells both on and off-site given the NAPL plume is not delineated on-site (Item B.3.4 from AMT); and
Reaching agreement with the auditor on the requirement for demonstrating that NAPL will not migrate beyond the boundary (Item B.3.9 from AMT).
Recommendation Determine the requirements for management or remediation of the source of NAPL associated with Plume 2.
Suggested actions Further investigate the extent of contamination associated with Plume 2 to enable better assessment of risk to off-site receptors.
Assess the feasibility of containing NAPL associated with Plume 2 within the site boundary.
Consider and determine the requirements for management or remediation of the source of NAPL associated with Plume 2, noting the approach being adopted elsewhere on the Refinery for management of NAPL, and that access is less restricted in the Nerita Gardens area than elsewhere on the Refinery (Item B.3.2 from AMT).
8.9 On-site plume assessment – priority for action
Previous audit reports have assigned a priority to each plume for NAPL reduction and containment. Now that a strategy for management of NAPL at the Refinery has been developed and agreed (the On-site LNAPL MP (and Supplementary Notice)), the priority for recovery of NAPL from the on-site plumes has reduced, and is now assigned a low ranking. Because the management strategy relies on effective containment, the considerations applied with regard to containment in the 2012 audit report are relevant. These are outlined in the Table below, and have been updated considering the works that have been undertaken. The adequacy of boundary containment is assessed in Section 9.
The works undertaken since the previous audit have been considered against the proposed actions in the CUP and the recommendations in the 2012 Audit Report. The auditor has also provided commentary on the adequacy of those actions, changes in understanding of the plumes or the risk profile and further recommendations. A summary of findings, observations and recommendations is provided in the Table, with further detail provided in the Action Management Table (Appendix B).
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Table 19 On-site plume assessment
Plume Priority for Works undertaken and assessment results Updated Priority boundary containment as per 2012 Audit Report
Plume 1 Medium Groundwater monitoring including MW292 where NAPL has not been identified. The 2014 GWMP proposes quarterly gauging and Low biannual sampling. Suggested action If NAPL enters well MW292 the priority for action in this area would increase to high (Item B.2.4 of AMT). Prepare a plan to confirm the adequacy of containment along the boundary near Plume 1 (Item C.3.1 of AMT).
Plume 2 High See Section 8.8. High
Plume 3 Central: medium Off-site well MW302 was replaced with MW317. Central: Medium 3A: low Wells down gradient of the GIT Gap, Plume 3A (MW032) and Plume 3B (MW039) have reported hydrocarbon concentrations 3A: Low exceeding site specific solubility criteria. 3B: low 3B: Medium The CGIT was extended to the north into the GIT Gap to improve boundary containment of Plume 3C. Further monitoring is required to 3C: high assess the presence of LNAPL to the north of the extended CGIT. 3C: High 3D: medium ERM proposes to install an additional well in the GIT Gap to the south of Sump N. 3D: Medium An increase in LNAPL thickness in SUMP N and MW246 was investigated; this is discussed in the context of boundary containment in Section 9.3.
Suggested action Install additional wells to confirm that plumes related to Plume 3 near the NGIT sump in the area of the W5 drain and the northern part of the GIT Gap have not extended off-site (Item C.24.3 of AMT).
Plume 4 Low Low
Plume 5 Low Low
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Plume Priority for Works undertaken and assessment results Updated Priority boundary containment as per 2012 Audit Report
Plume 6 Low to medium Baildown tests were completed at MW068. Low to medium While the monitoring wells located between Plume 6 and Shell Creek have not reported measureable NAPL since 2009, dissolved hydrocarbon concentrations were reported above the site specific solubility criteria in MW077 and MW089. The 2014 GWMP requires that Shell Creek will be inspected for signs of visible sheens in the vicinity of Plume 6 as part of bi-annual gauging. Suggested action Assess available information on the passive containment trenches near Plume 6 (construction, lining, details of termination at ends, location). Identify which wells are located within trenches, as trend information may not be relevant for these wells (Item B.7.6 from AMT). Provide a Figure in the Plume 6 CSM that shows the location of trenches and SC-1 and SC-2 on Figure 1.
Plume 7 High MPVE pilot trials completed as discussed in Section 8.2. Medium The SGIT was extended to the west to improve boundary containment of Plume 7. Further monitoring is required to determine whether LNAPL is present to the west of the extended SGIT, noting that a number of on and off-site wells down gradient of Plume 7 and the SGIT reported hydrocarbon concentrations exceeding the site-specific solubility criteria.
Plume 8 High LNAPL continues to be observed in MW299 located down gradient of the SGIT and Plume 8C. LNAPL is sporadically observed in High several of the Plume 8C delineation wells including MW131, GP17, MW65 and MW66.
MW236 is located down gradient of the CGIT and Plume 8 and reported dissolved phase hydrocarbon concentration exceeding site specific solubility criteria. LNAPL was observed for the first time in August 2012 in GP17 down gradient of the SGIT and Plume 8b. Wells MW071 and MW199 are located down gradient of the SGIT and Plume 8b, these wells reported hydrocarbon concentrations exceeding the site specific solubility criteria. Other wells down gradient of the CGIT and Plume 8a, and the SGIT and Plume 8b also exceed hydrocarbon solubility criteria; however, these wells are in the vicinity of foreshore plumes and may therefore be related to remnant LNAPL in the foreshore. Improvements have been made to the operation and maintenance of the SGIT including an additional extraction point. However operational issues with the sumps have continued. Suggested action Assess the operation of sumps and effectiveness of the SGIT. Consider installing additional wells to confirm that NAPL is effectively contained (Item B.9.3 of AMT). Consider what further investigation should be undertaken in the area of Plume 8C (Item B.9.9 of AMT).
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9. Boundary containment – current status
Boundary containment is currently maintained through the operation of three groundwater interception trenches (GITs) and associated sumps, extraction bores, pumps, and collection tanks, and a separation and measurement plant. The trenches are referred to as the Northern GIT, Southern GIT and the Central GIT.
The design and operation of the GITs is described in the Groundwater Remediation Systems: Operation, Maintenance and Monitoring Manual (ERM 2009b). The auditor has not completed a full review of this document as it is understood that it has recently been updated following trench upgrades and testing. This is further discussed in Section 5.6. The trenches are approximately 0.45 m wide and up to 3 m deep, and include gravel overlain by geofabric and compacted soil. The GITs do not incorporate an impervious liner on the walls, apart from an approximate 40 m long portion of the Northern GIT which was rebuilt in 2001, and the recently constructed extensions to the CGIT and SGIT. The GITs provide a preferential pathway to capture fluids entering by inducing a gradient within a high permeability zone to contain and prevent migration of fluids (beyond the trench) within the depth interval the GIT. The fluid within the trench migrates towards collection sumps located at the end of each GIT. Following recovery, extracted fluids are sent to the central slops system for treatment and disposal.
If a GIT does not operate with sufficient drawdown to cause groundwater to migrate into the trench along the entire length of the trench, the trench may become ineffective and NAPL may pass through the trench. Confirming that each trench is operating effectively with respect to NAPL capture is an essential requirement of the ongoing operation. Trench performance metrics are discussed in Section 9.1.
The primary operational objective of the GITs is to contain NAPL and dissolved phase contamination, with a secondary operational objective being recovery of NAPL. The extent to which GITs intercept groundwater and NAPL depends on the extent to which there is drawdown and a positive inflow into the trench.
9.1 Performance metrics
During the 2013 and 2014 SMP Annual Report reporting periods the effectiveness of the boundary containment system was assessed using performance metrics as detailed in the 2014 SMP Annual Report as:
Primary – maintenance of a hydraulic gradient within the trench towards the recovery point(s);
Secondary – maintenance of a hydraulic gradient from the formation toward the trenches;
Tertiary – operational metrics, including: – Continuous operations of the extraction / pumping system with less than five days of down-time per month; – Regular checks of system operation; – Extraction rates maintained within nominated ranges; and – Apparent LNAPL thickness less than 0.1 m measured in each GIT. It is reported that the operational metrics will be updated and included in the updated OM&MM. The proposed updated metrics are detailed in the 2014 SMP Annual Report. The proposed primary metric is a gradient from groundwater elevation in the natural formation to the trench fluid
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elevation and/or a gradient towards an extraction point. Removing the ‘or’ from this compliance metric should be considered. Percentage drawdowns of static levels in sumps have also been proposed as a metric for assessing trench effectiveness. These percentages will be reviewed once the ETOP report and updated O&MM have been provided to the auditor. The auditor suggests that, following GIT specific monitoring and trench upgrades, consideration is given to whether improvement of the inlet screen to each sump is required. The current inlet screen can be partially blocked by aggregate, reducing recoverability and potentially limiting full NAPL recovery (Item C.1.26 of AMT).
Recommendation Revise the OM&MM to include goals and metrics for performance and ongoing operation of the containment systems, including requirements for drawdown and NAPL thickness.
Suggested actions In revising the OM&MM, consider new information and changes that have occurred in the containment systems including trench upgrades and shutdown and recovery tests of all GITs (Item C.1.12 of AMT).
Consider adjusting the primary metric proposed in the 2014 SMP Annual Report to require both a gradient from groundwater in the natural formation to the trench, and a gradient within the trench towards an extraction point.
Document volumes of NAPL removed from all GITs, where this information is available.
9.2 North of NGIT
The Refinery boundary containment system ends at the northern extent of the NGIT, and does not extend into Nerita Gardens where the LNAPL plume (Plume 2) has been observed extending to the eastern boundary of the Refinery. Details of the assessment undertaken in this area and recommendations made are included in Section 8.7.
Recommendation Prepare a plan to confirm the adequacy of containment along each boundary of the Refinery, resolving specific issues related to particular locations noted in the Audit Reports including the boundary near Nerita Gardens (Item C.1.3.2 of AMT).
9.3 NGIT
The 2010 Audit found that the NGIT was effective and further actions to upgrade the NGIT were not proposed.
The 2013 SMP Annual Report reported that during works to remove a redundant sewer line that passed through the NGIT (see Section 10.6 for details) aggregate was replaced in an approximate 10m length of the trench and maintenance work was undertaken on SumpN.
An investigation triggered by increased LNAPL thicknesses in SumpN and MW246 found a faulty non-return valve. Following replacement of the valve and weekly pumping of SumpN, pump operation was observed to be normal and LNAPL in the sump was consistent with historical observations. This was reported in the 2014 SMP Annual Report and the Draft SumpN Investigation, Maintenance and Closure Report (ERM 2014b). This addresses the only CUP recommendation related to the NGIT. However, LNAPL thicknesses greater than the 0.1 m performance metric were observed in SumpN and MW246 in quarter 1 2014. The 2014 SMP
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Annual Report states that weekly pump outs and fortnightly gauging of SumpN will continue to prevent accumulation of LNAPL. The 2014 SMP Annual Report states that there was an absence of LNAPL in wells down-gradient of the NGIT which was interpreted to mean that the boundary containment system remains effective at preventing LNAPL migration. However, Section 3.5 of the Groundwater Monitoring Report discusses wells MW032 and MW039 having concentrations of TRH C15-C28 that exceeded the solubility limit. This could potentially indicate the presence of LNAPL and should be considered when assessing trench performance. A gradient within the trench towards the extraction point was not observed during the 2012 monitoring, in addition, GIT fluid elevations were not consistently below levels in the formation. However monitoring undertaken from quarter 2 2013 to quarter 1 2014 showed a gradient was present towards the extraction point and fluid elevation in the GIT was lower than that of the formation.
A detailed review of the performance of the NGIT will be undertaken following auditor review of trench effectiveness testing results.
Recommendation Confirm that the NGIT provides effective boundary containment.
Suggested Actions Undertake effectiveness testing at the NGIT and report results.
Carry out periodic shutoff of the NGIT with gauging of the fluid level in the NGIT and adjacent wells to confirm that the NGIT is operating with drawdown (Item C.1.5 of AMT). Viva Energy is to provide schedule for shutdown to the auditor for endorsement.
Continue pump outs and gauging of LNAPL in SumpN and further investigate if LNAPL thicknesses greater than the performance metric continue.
Update CSM for Plume 3 central/3A/3B (Item C.1.8 of AMT) if necessary after trench testing and assessment of boundary containment has been completed.
9.4 GIT Gap
The CGIT was extended approximately 70m into the southern section of the GIT Gap. Wells down gradient of the GIT Gap have reported hydrocarbon concentrations exceeding site specific solubility criteria. Further groundwater assessment is required to assess the presence of LNAPL to the north of the extended CGIT (see Section 8.9). ERM has prepared a Proposal for Well Installation, Decommissioning and Repairs at the Shell Geelong Refinery (2014) that includes the installation of one well in the northern portion of the GIT Gap, and potential for another well off-site to confirm the adequacy of containment in this area.
Whether the installation of this monitoring well addresses the recommendations in the AMT for the northern portion of the GIT Gap will depend on the results of drilling and groundwater monitoring. Further investigation may be required into the area of the GIT Gap north of the CGIT extension.
Recommendation Confirm that the extension of the CGIT provides effective boundary containment in the vicinity of the GIT Gap.
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Suggested actions Prepare plans to confirm the adequacy of containment just south of NGIT by carrying out monitoring (Item C.2.1 of AMT). Note that installing the additional monitoring well in the northern part of the GIT Gap may address this with respect to the northern portion of the GIT Gap; this will depend on the results of drilling and groundwater monitoring. Install additional monitoring wells to confirm that plumes related to Plume 3 near the NGIT sump in the area of the W5 drain and the northern part of the GIT Gap have not extended off site. If this is not possible due to access difficulties, additional evidence to support this is required [W5 investigation adequate but still applies south of NGIT] (Item C.2.3 of AMT).
Following installation of additional wells, reassess monitoring program following the CGIT extension and monitoring south of the NGIT (Item C.2.7 AMT). Re-assess risk / priority as part of Groundwater Monitoring Program (Item C.2.8 of AMT).
9.5 CGIT
The 2010 audit assessed the CGIT, and found that an upgrade of the CGIT was required to improve the operation of the CGIT and address the uncertainty of containment along the GIT Gap. The 2013 SMP Annual Report details the following works that were undertaken:
Extension of the CGIT into the GIT Gap;
Installation of an additional extraction point (SumpC2) to provide boundary containment in the southern GIT Gap and northern section of the CGIT; and
Installation of three in-trench monitoring wells.
These works address recommendations from the CUP.
The auditor re-assessed the performance of the CGIT based on its continued ability to create a groundwater flow towards SumpC and SumpC2, whether the trench water elevations are consistently lower than the groundwater elevations in the surrounding formation, and whether downgradient wells have shown new or increasing thicknesses of LNAPL or increased concentrations of dissolved phase components.
From quarter 2 2012 to quarter 1 2013 monitoring wells MW049 and MW175 down gradient of the southern section of the CGIT (from SumpC to MW096) reported groundwater elevations lower than those in the GIT. The 2013 SMP Annual Report states that no additional action was taken as LNAPL accumulation greater than 0.1 m was not observed in the southern section of the trench and LNAPL was not observed in wells down gradient of the southern section of the trench. Fluid elevations in MW175 continued to be below that of the trench from quarter 2 2013 to quarter 1 2014 (with MW049 and MW317 reporting levels lower than the trench in some quarters) as reported in the 2014 SMP Annual Report.
LNAPL thickness greater than 0.1 m was reported in the northern section of the CGIT (from MW096 to GITC1) during quarter 2 2012 to quarter 1 2013, along with a groundwater elevation in down gradient well MW302 lower than that of the trench. LNAPL was recovered from GITC1 in November 2012; it was reported in the 2013 SMP Annual Report that a minimal reduction in apparent LNAPL thickness was observed. Gradients towards the sump were determined to not be applicable for this section of the trench as the gradient was not affected by the existing Sump and corrective actions were planned. In the 2014 SMP Annual Report monitoring period LNAPL greater than 0.1 m thickness was observed in MW296 in quarter 4 2013 and quarter 1 2014. Following commissioning of SumpC2 a gradient was observed towards the extraction point in this section of the trench.
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As discussed above, fluid elevations in some down-gradient wells were below the CGIT fluid elevation. As LNAPL was not observed in the down-gradient wells and associated trench wells boundary containment effectiveness has been interpreted as adequate. However foreshore wells MW083 and MW273 which are down-gradient of MW290 and MW175 (where fluid elevation in the trench is higher than the surrounding formation) have reported dissolved phase concentrations above the solubility limit. Also, dissolved phase concentrations in MW240 may be interpreted as increasing. These issues should be considered when assessing effectiveness of boundary containment. As the trench performance metrics were not always complied with, the auditor concludes that further work is required to confirm that the CGIT provides an adequate level of certainty of containment. This will be considered further following auditor review of trench effectiveness testing results.
As discussed in the previous audit report, assessment of whether improvement of the inlet screen to each sump is required should also be undertaken following the upgrades. See recommendations in Section 9
Recommendation Confirm that the CGIT provides effective boundary containment.
Suggested actions Address Auditor’s comments on the Final Draft Groundwater Interception Trench Extension Construction Report (ERM 2013g) to fully address Item C.4.1 of AMT. Note: an updated report addressing these comments was provided to GHD on 15 September 2014, but this has not yet been reviewed by the auditor.
Confirm the effectiveness of the new extraction point Sump C2 north of the W4 drain after the upgrade of the CGIT (Item C.4.3 of AMT).
Further consider the issue of increasing dissolved phase hydrocarbon impact in groundwater sampled from MW240. If monitoring data and/or confirmation shutdown and recovery testing does not provide a clear indication that the trench is causing drawdown from both up gradient and downgradient, then additional monitoring wells immediately downgradient of the CGIT could be considered (Item C.4.5 of AMT).
Further assess boundary containment to confirm that NAPL does not continue to migrate beyond the site (Item C.4.6 of AMT). Draft ETOP report provided to GHD on 4 September this recommendation will be considered during the review of the ETOP.
Carry out periodic shutoff of the CGIT with gauging of the fluid level in the CGIT and adjacent wells to confirm that the system is operating with drawdown and containment is effective (Item C.1.5 of AMT). A schedule for shutdown is to be provided to the auditor for endorsement. Additional monitoring wells may be required to confirm that containment is effective. Continue monitoring in accordance with the GWMP (Item C.1.10 of AMT). This recommendation may be re-considered following review of the draft ETOP issued to GHD on 4 September 2014.
Install additional monitoring wells adjacent to the extended CGIT (Item C.2.6 of AMT). Document trench upgrade and re-assess trench effectiveness including interpretations of hydraulic testing and trench shut down data (Item C.4.2 of AMT).
Confirm adequacy of monitoring wells MW296 and MW297 (Item C.4.7 of AMT).
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9.6 SGIT
The 2010 audit assessed the SGIT and found that upgrade of the SGIT was required to improve operation and address uncertainty regarding containment to the west of the SGIT and in the south eastern area of the Refinery where the drawdown was muted and there may be a blockage.
The 2013 SMP Annual Report details the following works that were undertaken:
Extension of the SGIT to the west terminating approximately 15 m past the start of the influent flume;
Installation of two additional extraction points (SumpS2 and SumpS3); and
Installation of four in-trench monitoring wells within the SGIT extension. These works address recommendations from the CUP.
The auditor has re-assessed the performance of the SGIT based on its continued ability to create a groundwater flow towards SumpS, SumpS2 and SumpS3, whether the trench water elevations are consistently lower than the groundwater elevations in the surrounding formation, and whether down gradient wells have shown new or increasing thicknesses of LNAPL or increased concentrations of dissolved phase components. Accumulation of LNAPL in GIT wells greater than 0.1m was observed during the monitoring periods. The 2013 SMP Annual Report states that a total of 14,300 litres of LNAPL and groundwater were extracted from MW230 and MW300 over two days during November 2012, and that this was ineffective in reducing the LNAPL thickness in MW230 to below 0.1 m. Gauging data presented in the 2014 SMP Annual Report indicates that LNAPL thickness in MW230 reduced to below 0.1 m in quarters 2 and 3 2013, but was above 0.1 m from November 2013 to March 2014.
While a gradient was observed towards the extraction point between SumpS and MW229, this metric was considered not applicable for other sections of the trench before the additional sumps were installed. From quarter 2 2013 to quarter 1 2014 gradients towards extraction points were observed in all sections of the trench.
Groundwater elevations in some down gradient wells were below the SGIT fluid elevation throughout the monitoring periods except for the section of trench between SumpS and MW229.
The 2014 SMP Annual Report discusses LNAPL observed in down gradient monitoring wells:
GP17 in quarter 3 2012;
MW131 in quarter 4 2012 and quarter 1 2013; and
MW299 throughout the monitoring period.
It should also be noted that a number of wells down gradient of the SGIT reported concentrations of dissolved phase hydrocarbons in excess of the site specific solubility criteria including MW199, MW071, MW197, MW196, MW194, MW193 and MW085.
The 2013 SMP Annual Report states that additional gauging events were conducted in September 2012 in response to identification of LNAPL in down gradient monitoring well GP17. The report states that while LNAPL had not previously been observed in this well, dissolved phase concentrations were suggestive of the presence of LNAPL.
As discussed in the previous audit report, assessment of whether improvement of the inlet screen to each sump is required should also be undertaken following the upgrades. See recommendations in Section 9
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Observations of NAPL in a down gradient well (MW299) indicates that further investigation is required to confirm that containment is effective in the area of the above ground pipe track where the 2010 audit identified there may be a blockage or a missing section of trench. Presumably the NAPL in MW299 has originated from material upgradient on the Refinery; however, it is possible that it is remnant material. In terms of the risk posed by ineffective containment in the vicinity of the above ground pipe rack, the auditor notes that this location is some distance from the shoreline and the shoreline in this area has restricted access, reducing the risk that NAPL migrating past the trench would pose. However the containment of NAPL is a critical element of on-going management of groundwater contamination at the Refinery. Monitoring well MW316 has been installed between Plume 12 and the bay. LNAPL has not been observed in this well. Further monitoring of wells in this area is required to provide greater certainty that effective containment is being provided.
As the trench performance metrics were not always complied with, the auditor concludes that further work is required to confirm that the SGIT provides an adequate level of certainty of containment. This will be considered further following auditor review of trench effectiveness testing results.
Dependant on the review of the ETOP report and completion of the review process for the 2014 SMP Annual Report the auditor will consider the value of potential additional monitoring wells to identify the extent of NAPL downgradient of the SGIT in the south east corner of the Refinery, noting that NAPL was identified in a monitoring well downgradient of the GIT in the area of Plume 8C. This, together with data from GP17 could indicate a connection between the on-site Refinery NAPL plume and Plume 12 off-site (Item C.5.16 of AMT). Based on information supplied in the 2014 SMP there may be a connection of the two plumes although that may be reflective of the historic release and not an indication of failure of the SGIT; however this is yet to be determined by the auditor.
Recommendation Confirm that the SGIT provides effective boundary containment.
Suggested actions Address Auditor’s comments on the Final Draft Groundwater Interception Trench Extension Construction Report (ERM 2013g) to fully address Item C.5.1 of AMT.
Carry out periodic shutoff of the CGIT with gauging of the fluid level in the CGIT and adjacent wells to confirm that the system is operating with drawdown and containment is effective (Item C.1.5 of AMT). A schedule for shutdown is to be provided to the auditor for endorsement. Consider whether additional monitoring wells are required to confirm that containment is effective. Continue monitoring in accordance with the GWMP (Item C.5.7 of AMT).
Re-assess trench effectiveness including interpretations of hydraulic testing and trench shut down data (Item C.5.2 of AMT).
Continue monitoring to assess whether adequate containment is provided in the vicinity of the above ground pipe track where there may be a blockage (Item C.5.14 of AMT). Additional monitoring wells may be required in this area.
Determine type and lateral extent of NAPL (Item C.5.12 of AMT).
Review and improve the management of the SGIT system to provide greater assurance that the system provides effective containment. This should include the implementation of
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measures to avoid the situation where a NAPL recovery pump may not be operating for an extended period (Item C.5.5 of AMT).
9.7 Separation and measurement unit (SMU)
Maintenance actions were undertaken over the 2014 SMP Annual Report reporting period to address poor operation of the SMU. The 2014 SMP Annual Report suggests that further maintenance works are likely to be necessary to achieve adequate performance of the unit. It is recognised that measuring the quantity and composition of NAPL entering and being recovered from the various boundary interception trenches has proven to be a difficult and costly matter. However, the auditor considers that measurement of the quantity and composition of NAPL entering / being recovered from each GIT will provide important information for assessing the performance of the various boundary interception trenches, and should be pursued.
Recommendation Improve the performance of the Separation and Measurement Unit.
Suggested actions Viva Energy, the assessor and auditor should reach agreement on the further work required to improve the performance of the Separation and Measurement Unit following review of the ETOP reports and OM&M manual (Item C.1.11 of AMT).
Improve collection of flow rate data by improving instrumentation to quantify NAPL and groundwater removed (Item C.1.14 of AMT).
Reach agreement on timing and installation of improved instrumentation (Item C.1.15 of AMT).
9.8 West of SGIT
The Refinery boundary containment system ends at the western extent of the SGIT, and does not extend along the southern Refinery boundary where Plume 6 is located. Details of the assessment undertaken in this area and recommendations made are included in Section 8.9
9.9 Overall requirements relating to the containment systems
Providing effective containment of NAPL to within the Refinery boundary is a key requirement, and there is an ongoing program of work to demonstrate and maintain containment.
Recommendation Demonstrate and maintain effective containment of NAPL along each boundary of the Refinery (Item C.1.1 of AMT).
Suggested actions Update trench CSMs as part of the appraisal of the effectiveness of trenches following GIT shutdown and recovery events, and after upgrade works have been completed. This may be documented in the ETOP which is yet to be reviewed by the auditor. The new documents should consider potential preferential pathways (Item C.1.8 of AMT).
Re-assess risk following GIT upgrades and required shutdown and recovery confirmation tests, review the ETOP and OM&MM
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Continue to carry out monitoring as outlined in the GWMP (Item C.1.10 of AMT) and re- assess risk as part of the groundwater monitoring program (Item C.1.13 of AMT). Carry out a systematic identification of possible preferential flow paths (such as drains W3, W4, W5 and other drainage lines, perhaps decommissioned) that might allow NAPL to migrate to the beach, and confirm that NAPL is not present in the vicinity of these possible pathways (Item C.1.2 of AMT).
Prepare plans to confirm adequacy of containment along each boundary of the Refinery (Item C.1.3 of AMT). Consider the importance of the assessment of dissolved phase concentrations to monitor the extent of LNAPL and operation of GITs including dissolved phase concentrations above site specific solubility levels. Confirm that there is a continual gradient towards the GIT sumps, and resolve situations where the gradient is not continuous to a sump including (Item C.24 of AMT):
– CGIT where hydrographs for April and October 2011 and February 2012 indicate a depression in the vicinity of W3 and W4 discharge lines (Item C.24.2 of AMT). – SGIT where observations indicate mounding up gradient of the sump, NAPL build up in MW099 and reduced recovery from the sump over a period of 5 months (Item C.24.3 of AMT).
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10. Off-site management – current status
10.1 General
The 2010 Audit (GHD 2010) concluded that, as for on-site plumes, NAPL clean up and management of off-site contamination should be considered in the light of the practicability of clean up, the effectiveness of containment, the risk that the NAPL poses to beneficial uses, and the timeframe over which clean up should take place.
The Geelong Grammar School (GGS) is located to the east of the Refinery. Although there is no evidence of an LNAPL Plume at GGS, it is located down gradient of Nerita Gardens where Plume 2 has been identified at the Refinery boundary and there is an absence of boundary containment. Therefore the GGS is considered in the off-site management of groundwater contamination from the Refinery.
The off-site plumes include Plumes 9, 10, 11A and 11B (now collectively referred to as the foreshore plumes), Plumes 12 and 13 (Terminals) and Plume 14. These plumes have been defined on maps; however, the auditor considers that in view of the complex nature of the geology and the dependence on the occurrence of NAPL on preferential flow paths, the plume areas are notional and indicative, and do not necessarily provide a clear delineation of where NAPL may or may not be found.
Because the off-site plumes are the result of historical releases and can be expected to have occurred in the absence of an effective containment system, a key requirement is that contamination is contained to the Refinery, and migration of contamination from the Refinery to off- site areas is avoided.
Similarly to the on-site NAPL plumes (refer to Section 8), monitoring of key wells is undertaken in accordance with the GWMP; this includes measuring the presence of NAPL and any changes that occur. Further discussion on the GWMP was provided in Section 6.3.
Recommendation Undertake periodic reappraisal of risk posed by NAPL and dissolved phase contamination to off- site areas, and requirements for response (Item D.1.1.1 of AMT).
10.2 Geelong Grammar School
Dissolved phase hydrocarbon was reported in monitoring well MW212 at the Geelong Grammar School Equestrian Centre in 2013; however during two subsequent monitoring events hydrocarbon concentration were reported as less than the laboratory limit of reporting. The Off-site Landowner Communication Schedule contained in the CUP requires at least one annual meeting between Viva Energy and GGS to discuss key findings (of groundwater monitoring) and answer questions. Minutes of meetings were provided to the Auditor for the following dates:
8 August 2013; and
3 March 2014.
The SMMP requires on-going communication with GGS to ensure that changes to the current groundwater or land use does not occur without conducting a risk assessment. Minutes of the meetings listed above did not include mention of whether changes to land or groundwater usage at GGS had occurred or been discussed.
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Recommendation At the annual meetings that form part of the ongoing liaison with GGS, issues that arise regarding soil and groundwater contamination should be discussed and minuted.
Suggested actions Confirm that there are no underground services (e.g. sewer, stormwater) that could provide a conduit for LNAPL migration off site (Item D.7.1 of AMT).
10.3 Foreshore plumes (Plume 9, 10, 11A and 11B)
As reported in the 2012 Audit Report ERM had prepared a Remedial Alternatives Analysis (RAA) and Landscape Management Plan (LMP) to manage the risks to beneficial uses of NAPL on the foreshore and the beach. The restoration of beneficial uses, achieving an acceptable level of risk, and the principles of CUTEP and sustainability were key aspects considered in determining the preferred approach to cleaning up and managing the foreshore contamination.
The proposed approach involved the following main elements: Low-energy recovery of LNAPL from foreshore monitoring wells;
Installation of two passive containment trenches;
Restriction of public access to the area between the saltwater intake and the Jetty, and control over works through the Viva Energy permitting system;
Landscaping of publically accessible areas of the foreshore to prohibit vehicle access, discourage pedestrian access and deter recreational users from digging in the beach;
Rehabilitation of the foreshore area through native revegetation; and
Establishing institutional controls such as Dial Before You Dig to reduce risk to workers.
Details of the works that have been implemented in the foreshore were documented in the Remediation Implementation Design (RID). The auditor supported the proposed approach on the basis that:
The provision of a cut off barrier and passive recovery trench were expected to encourage natural attenuation of remnant NAPL at the beach.
Other methods of treating NAPL at the beach were expected to involve considerable disturbance of the beach and the auditor understands that these were not acceptable to some stakeholders.
NAPL will be recovered from the trench if observed. The auditor noted that the methods to be applied were low energy methods and would not be as effective as higher energy and more intensive methods. However, higher energy and more intensive methods would incur greater disruption of the foreshore environment and be less acceptable to some stakeholders. The measures proposed to be implemented to deter access (fencing, rock barrier, signage) to reduce risk associated with remnant NAPL while treatment is underway are limited by stakeholder requirements and the auditor considers them to be an appropriate set of provisions.
Recovery of NAPL upgradient of the cut-off barriers and passive recovery trenches would be carried out in accordance with a set of triggers and contingencies. The foreshore will be revegetated, with long term management of vegetation through a LMP.
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EPA provided confirmation that the approach appeared broadly consistent with EPA Policy on 1 October 2012. The 2014 SMP Annual Report provided discussion on the progress of implementation of the RID as follows:
Access to land between the saltwater intake and the Jetty continues to be prohibited to the public and is under Viva Energy control with a permitting system in place for any subsurface works.
The foreshore containment barriers and passive recovery trenches have been installed and rehabilitation works are under tender.
Dial Before You Dig notification for subsurface works outside of the Refinery was implemented in October 2013. An example Dial Before You Dig enquiry response was provided to the auditor. The response included a figure showing the area where soil and groundwater contamination may be encountered on Wharf Road, Shell Parade and the Corio Bay foreshore. The area highlighted extends along Shell Parade adjacent to Nerita Gardens in the vicinity of Plume 2; however, given the uncertainty of the northern extent of the Plume, further north should be considered to be included in the contamination zone.
The auditor understands that a report detailing the installation of the NAPL containment barriers and passive recovery trenches is being prepared by ERM.
The priority for NAPL reduction in these plumes remains medium (Plumes 9 and 11) and has been reduced from high to medium (Plume 10).
Recommendation Complete the remaining actions in the Remediation Implementation Design for the foreshore works.
Suggested actions Report on trench installation (Item D.1.1 of AMT).
Implement Landscape Management Plan (Item D.2.6 of AMT).
Consider detecting changes in hydraulic head when assessing monitoring data (Item D.2.9 of AMT).
Agree on trigger values for accumulation of LNAPL within foreshore trenches.
Consider extending the area of contamination shown on Dial Before You Dig figures further north.
10.4 Terminals plumes (Plumes 12 and 13)
As discussed in Section 9.6 above, NAPL was identified in a new well (MW299) installed downgradient of the SGIT. This may indicate a connection between Plume 8 (onsite) and Plume 12 off-site. Monitoring well MWTB09 showed an increasing trend in dissolved phase hydrocarbon concentrations which also exceeded site specific solubility criteria, however this well has historically contained LNAPL and therefore increased concentrations are not unexpected. The Off-Site Landowner Communication Schedule contained in the CUP requires at least one annual meeting between Viva Energy and Terminals to discuss key findings (of groundwater
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monitoring) and answer questions. Minutes of meetings were provided to the Auditor for the following dates: 13 August 2013; and
16 May 2014.
The SMMP actions for Terminals include seeking agreement from Terminals to continue the current OH&S and permitting procedures. Terminals have provided Viva Energy with Section 3.6.5.1 of the Terminals Safety Manual dated 28/11/2013. This section warns that excavation works may encounter contaminated soils and instructs workers to wear PPE and stop work and inform Terminals if visual or olfactory indications of soil contamination are encountered.
Institutional controls have been implemented through Dial Before You Dig Notification to alert third party sub-surface workers of the potential to encounter LNAPL when digging along Wharf Road in the vicinity of Plumes 12 and 13.
Maintaining effective boundary containment along the southern boundary between the Refinery and Terminals has been considered under Section 9.6. The priority for reduction of NAPL to reduce risks to beneficial uses has been reduced to low.
Recommendations Continue to monitor Plumes 12 and 13 and liaise with Terminals.
Suggested actions At the annual meetings between Viva Energy and Terminals, discussions on groundwater should be recorded in the minutes of the meeting.
10.5 Plume 14
Plume 14 relates to LNAPL that originates from off site, and is associated with a BP Terminal and possibly a Caltex Terminal. It is understood that the source sites are subject to EPA CUNs and subject to Audit.
The 2010 audit required that Viva Energy will continue to liaise with BP and continue to monitor Plume 14. The auditor understands that these actions are being implemented, and that Plume 14 is being managed under a separate CUN. While NAPL thicknesses reported in wells MW203 and MW287 do not appear to be increasing, the absence of wells down gradient of this plume does not allow for plume delineation or assessment of plume stability.
The priority for LNAPL reduction remains low.
Recommendation Continue to liaise with relevant parties to determine progress on clean up of Plume 14 that has migrated onto Refinery land from off site, and continue monitoring to confirm that the extent of the plume is not increasing.
Suggested actions Consider the need for additional wells to delineate the plume.
Continue to liaise with BP and/ or Caltex with a view to achieving clean up (Item D.6.1 of AMT).
Prepare a report on plume extent and clean up progress (Item D.6.2 of AMT).
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10.6 NAPL on the beach at other locations
The previous audit report discussed the identification of NAPL at the beach as a thin film some 50 – 150 mm below the surface in the vicinity of the W5 outfall. Before this NAPL was identified, it was understood that NAPL was present at the beach only in the vicinity of Plumes 9, 10 and 11.
Following observation of a sheen in the Corio Bay foreshore near the W5 outfall EPA issued a Minor Works Pollution Abatement Notice (MWPAN) (and later an amended MWPAN). Trenching, soil assessment and groundwater assessment works were undertaken to assess the potential for a preferential pathway in this area. The works identified a redundant sewer pit and line which was removed and plugged to prevent further transfer of contaminants. Investigative trenching around the W5 outfall indicated that it was not likely to be the source of sheen identified in the foreshore as reported in Final W5 Offsite/Onsite Investigation Factual Report Shell Geelong Refinery (ERM 2013g). The works undertaken were reported to EPA and the amended MWPAN was revoked. The identification of NAPL at the beach in an unexpected location illustrates the uncertainty that is associated with identification and delineation of contamination in the beach area. The auditor has considered whether there is a need to undertake an investigative program along the full length of the beach. However, the recent occurrence is associated with faulty infrastructure and, while some minor localised ill-defined remnant historical contamination might be present, the auditor considers that the approach taken for the area in the vicinity of Plumes 9, 10 and 11A involving improved containment and then relying on natural attenuation can be expected to be appropriate. In view of this, the auditor concludes that the focus should be on ensuring that there is effective boundary containment, rather than undertaking an extensive beach investigation program.
10.7 AFFF
AFFF has been identified as a potential contaminant of concern and was raised in the 2010 Audit Report as an issue relating to off-site management. ERM prepared a scope and risk assessment report for assessing AFFF and monitoring of selected wells for constituents of AFFF was undertaken in accordance with the GWMP. Further sampling and analysis is planned for 2014 in accordance with the 2014 GWMP. When the results of this sampling are reported an assessment to review data and assess whether concentrations are stable or decreasing should be undertaken.
Recommendation Undertake further monitoring to confirm that concentrations of fluorosurfactants at the foreshore are stable or decreasing and not increasing (Item D.2.7 of AMT).
10.8 Off-site plume assessment – priority for action
Previous audit reports have assigned a priority to each off-site plume for NAPL reduction. Priority for NAPL reduction in the foreshore plumes is expected to reduce following the implementation of the RID and LMP. The priority for NAPL reduction as applied in the 2010 Audit Report (no updates to priority for off-site plumes were included in the 2012 Audit Report) is outlined in the table below, along with relevant works undertaken and an updated priority.
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Table 20 Off-site plume assessment
Plume Priority for Works undertaken Updated Priority NAPL reduction as per 2010 Audit Report
Foreshore
Plume 9 Medium RID and LMP are currently being implemented. Medium
Plume 10 High RID and LMP are currently being implemented. Medium
Plume 11 Medium RID and LMP are currently being implemented. Medium
Terminals
Plume 12 Low/medium Terminals are managing risks associated with Low NAPL as detailed in the Terminals Safety Manual. Institutional controls have been established to alert third party sub-surface workers of the potential to encounter LNAPL via Dial Before You Dig Notification that includes wharf Road in the vicinity of Plume 12.
Plume 13 Low Terminals are managing risks associated with Low NAPL as detailed in the Terminals Safety Manual.
Western buffer zone
Plume 14 Low Routine groundwater monitoring undertaken. Low
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11. Assessment of risk
11.1 Reappraisal of risk to beneficial uses of land and groundwater
11.1.1 Methodology
The auditor carried out a detailed assessment of the risk that soil and groundwater contamination at the Refinery poses to beneficial uses in the 2007 Audit Report (GHD, 2008b) and 2010 Audit Report (GHD, 2010). These assessments included an exposure pathway analysis involving a large number of combinations of receptors, general exposure pathways and relevant beneficial uses to be protected (refer to Section 4 of this audit report). The significance of the risks to the environment was assessed using a semi-quantitative risk assessment methodology consistent with the Australian and New Zealand Standard: Risk Management – Principles and Guidelines (AS/NZS ISO 31000:2009) and International Standard: Risk Management – Risk Assessment Techniques (IEC/ISO 31010:2009). This assessment process involved:
Identification of the relevant beneficial uses and receptors;
Identification of potential contaminants of concern;
Identification of possible exposure pathways and contamination exposure scenarios;
Assessment of the likelihood of contamination exposure scenarios occurring (i.e., that the contaminant is present at concentrations of concern and that the exposure pathway is complete and receptors would be affected);
Assessment of the consequences associated with each of the contamination exposure scenarios;
Characterisation of the risks based on the likelihood and consequences of each scenario using a risk assessment matrix that considers consequences on people (health), assets and environment; and
Evaluation of where further monitoring and investigation is required to fully characterise the risks.
Details of the method are included in the 2007 Audit Report (GHD, 2008b) and 2010 Audit Report (GHD, 2010). The 2012 Audit Report stated that risks remained unchanged.
A reappraisal of the risks to the beneficial uses of land and groundwater was undertaken for this audit report. Rather than repeating the detailed assessment, the reappraisal considered where change has occurred during the audit period: ie where clean-up works and management systems have been implemented, and where the understanding of the presence or impact of contamination has changed.
11.1.2 Findings
A number of clean up actions were implemented during the audit period and, as noted in the tables of risk in preceding sections of this report, this has reduced the risk for some items. In particular, the 2010 Audit Report assigned risk rankings of “medium” for human health to sub-surface workers in the foreshore for risk from vapours in excavations and dermal contact with contaminated soil and groundwater in excavations. The establishment of an institutional control to
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protect subsurface workers from exposure to vapours from LNAPL via a Dial Before You Dig notification has reduced these risks to “low”. There is still some reporting on works and testing results (such as that related to the GITs) that is underway and has not been finalised. As this further work is completed, it can be expected that the risks will further reduce. As was determined in the 2010 Audit Report (GHD, 2010), the residual risks are ranked as “medium” to “low”, and none of the risks have been ranked as “high”. In particular, the “medium’ risks primarily relate to the presence of NAPL on the foreshore intertidal zone and particularly the risk that it presents to persons who might use the foreshore for recreational purposes. This risk will reduce over time as the remnant LNAPL degrades.
The remaining risks were ranked as “low”; this includes the risks to the health of workers at the Refinery; the risks to the health of persons and ecology at the Geelong Grammar School and associated land; and the risks to the ecology of Corio Bay. With respect to the ecology of the intertidal zone, it was concluded that it is most likely that hydrocarbon discharges are not significantly affecting the ecology of the zone, although there is the possibility that there is a localised impact.
Details of the updated risk assessment are included in Appendix F.
11.2 Reappraisal of priority ranking for remedial response In the 2010 Audit Report (GHD, 2010), the auditor assigned a ranking for remedial response for each of the plumes. The priority ranking for remedial response was based on the understanding of site conditions at the time the 2010 Audit Report was prepared. The 2010 Audit Report (Sec 10.3) emphasised that the rankings may change with further consideration of information and as the actions from the CUP are implemented. In the 2012 Audit Report the priority for improving boundary containment was changed for Plume 1 (reduced to “medium”) and Plume 2 (increased to “high”), and the priority for reduction of NAPL changed for Plume 2 (increased to “medium”).
Updates to the priorities assigned in the 2010 Audit Report and updated in the 2012 Audit Report are provide in Sections 8.9, and 10.8.
11.3 Assessment of risk from AFFF Prior to the previous audit report the auditor reviewed a scope and risk assessment report for assessing AFFF. From this review the auditor concluded:
There is a reasonable level of rigour to the assessment of health risk from PFOS and PFOA. The auditor accepts the methodology for deriving the PFOS and PFOA SSTLs and considers that there is merit in the considerations presented, including the application of additional factors to account for bioaccumulation, and the application of the ANZECC 2000 methodology from Australian and New Zealand Guidelines for Fresh and Marine Water Quality, National Water Quality Management Strategy (ANZECC & ARMCANZ 2000) . There is insufficient information to characterise the concentrations of fluorosurfactants that are present in site soils to which workers might be exposed. However, based on the auditor’s experience with other sites including sites where fire training has been carried out using significant quantities of AFFF, the risk to the health of workers on-site can be expected to be low, noting that the Refinery is an industrial workplace, and exposure will be limited.
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The presence of the constituents of AFFF (particularly fluorosurfactants PFOS and PFOA) has been measured in 10 off-site wells along the foreshore. The highest PFOS concentration measured in foreshore wells was 2.14 µg/L, and in the intertidal zone the concentrations can be expected to be lower and further diluted on discharge, and well below the ecological health SSTL of 72 µg/L established in the risk assessment. This supports the conclusion that the fluorosurfactants will not give rise to a direct adverse effect on the health of the shoreline ecosystems, and are unlikely to have affected the control site and the outcome of the ecological risk assessment. The fluorosurfactants are highly persistent and bioaccumulative, and it is possible that they could bioaccumulate higher in the food chain (eg in fish, and persons who might consume fish). The risk assessment has taken this into account, and has established a PFOS SSTL of 0.3 µg/L based on the human consumption of fish. The highest PFOS concentration reported was 2.14 µg/L in one of the 10 foreshore wells, which exceeded the SSTL. ERM has considered the significance of the measured levels and concludes that the contamination poses a low risk. The auditor has considered the ERM reasoning, and concurs with this finding. In this, the auditor notes the localised extent, likely further dilution, and that the fish species of interest are likely to be pelagic. The auditor has considered whether it would be warranted to carry out fish monitoring; however, the findings of such work are unlikely to be conclusive because if fluorosurfactants were to be found in fish, it would be difficult to distinguish whether these were related to the Refinery or some other source (noting that fluorosurfactants are ubiquitous and have been widely used).
The extent of monitoring for fluorosurfactants in groundwater is limited. It has not extended to on-site wells, and monitoring suggests that there could be an increasing trend in monitoring well MW273. However, the auditor considers that the risk associated with fluorosurfactants and the priority for further investigation is low, although monitoring for fluorosurfactants in foreshore wells should continue until there is confidence that the concentrations are consistent with the measurements to date and are decreasing.
Additional monitoring for AFFF compounds was undertaken in 2012 and 2013 in foreshore wells and reported in the 2014 SMP Annual Report. The 2014 SMP Annual Report reports that the data shows stable or decreasing concentrations. It is understood that further monitoring of AFFF has been undertaken and will be reported in the next SMP Annual Report.
The risk associated with AFFF is considered to remain low.
11.4 On-site health risk assessment Details of the indoor methane and carbon dioxide monitoring undertaken at the Refinery are included in Section 8.7.1 The results of the monitoring confirmed that risk to on-site workers at the Refinery is found to be low.
Details of the Permit to Work system at the Refinery are provided in Section 8.7.3. The results of the investigation undertaken found that risk to workers at the Refinery remains low.
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12. Conclusions and recommendations
12.1 Risk assessment
12.1.1 Risks to beneficial uses
A re-appraisal of the risks to the beneficial uses of land, groundwater and surface water has been undertaken. A number of clean up actions were implemented during the audit period and this has reduced the risk for some items. In particular, the risks to sub-surface workers in the foreshore which have reduced to “low” for risk from vapours in excavations and dermal contact with contaminated soil and groundwater in excavations. There is still some reporting on works and testing results (such as that related to the GITs) that is underway and has not been finalised. As this further work is completed, it can be expected that the risks will further reduce. The risks to beneficial uses are ranked as “medium” to “low”; none of the risks have been ranked as “high”. The “medium’ risks primarily relate to the presence of NAPL on the foreshore intertidal zone and particularly the risk that it presents to persons who might use the foreshore for recreational purposes. This risk will reduce over time as the remnant LNAPL degrades.
The remaining risks were ranked as “low”; this includes the risks to the health of workers at the Refinery; the risks to the health of persons and ecology at the Geelong Grammar School and associated land; and the risks to the ecology of Corio Bay. With respect to the ecology of the intertidal zone, it was concluded that it is most likely that hydrocarbon discharges are not significantly affecting the ecology of the zone, although there is the possibility that there is a localised impact.
The risk associated with AFFF is considered to remain low.
The results of indoor methane and carbon dioxide monitoring found that risk to on-site workers at the Refinery is low.
The results of an investigation into the Permit to Work system at the Refinery found that risk to workers at the Refinery arising from soil and groundwater contamination remains low.
12.1.2 Priorities for remedial response
A re-appraisal of the ranking for remedial response has been carried out. With the implementation of the On-site LNAPL MP (and Supplementary CUN) the priority for NAPL recovery from the on- site plumes has been assigned a low ranking.
Works have been carried out to upgrade the various boundary interception trenches and, while reporting confirming the effectiveness of these works is still in progress, it can be expected that the works will have achieved improved certainty of containment, reducing the risk that containment might not be effective. As this is still work in progress, at the time of this audit in most cases there have not been changes to the priority for boundary containment except for:
Plume 1 reduced to “low” due to groundwater monitoring and an absence of LNAPL identified in MW292;
Plume 3B increased to “medium” due to uncertainty around boundary containment in this area; and
Plume 7 reduced to “medium” due to extension of the SGIT to the west.
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Priority for NAPL reduction in off-site plumes has remain unchanged except for Plume 10 where priority has been reduced to “medium” due to the RID and LMP currently being implemented, and Plume 12 where the priority has reduced to “low” due to information on Terminals safety management processes being received.
12.2 Progress on actions to manage soil and groundwater contamination
12.2.1 Overview
The following sections outline the broad conclusions on the progress with respect to implementation of actions to protect receptors and restore beneficial uses under each of the four pillars used to manage soil and groundwater contamination on site and off site at the Refinery. Recommendations from this audit are listed at the end of the discussion on each of the four pillars in the preceding sections. Actions outlined in the CUP Implementation Schedule have largely been completed or are progressing, although tasks related to upgrading the GITs took longer than expected and reporting is still to be completed for the various GIT upgrades, and the foreshore GITs and LMP. It is recommended that the next audit be undertaken in two years (rather than the scheduled three years) to provide for a timely review of the final works and reporting. Further assessment is required to evaluate whether remediation of Plume 2 is required.
Following completion of this audit, the AMT will be revised by the auditor taking into account the recommendations from this audit report and the further work that is agreed between EPA and Viva Energy. It is expected that the revised AMT will provide the basis for the next audit.
12.2.2 Primary source management
The auditor has undertaken an assessment of the primary source management systems at the Refinery. The assessment found that systems are in place to minimise the risk that uncontrolled releases of product will occur; these systems include risk assessment, change management, infrastructure management, leak detection and identification of uncontrolled releases.
Regular updates on the tundish and drainage line replacement program and replacement of Field Sump 5 should be provided to the auditor.
12.2.3 On-site management
The implementation of most actions for each of the plumes has been progressing satisfactorily. A plan for on-site LNAPL management is in place; this has adopted the strategy of achieving effective containment, and assumes that recovery of on-site LNAPL is not required while the Refinery is in operation. Further assessment of LNAPL near the boundary at Plume 2 has been undertaken. Assessment of risk to on-site workers has been undertaken through investigation of the Permit to Work system and in-building methane and carbon dioxide sampling.
Plumes with a high priority for boundary containment include Plume 2, Plume 3B and Plume 3C.
12.2.4 Boundary containment
Works to upgrade the boundary containment trenches are a significant body of work and have been completed with reporting of this work currently being finalised. It expected that the appropriate metrics for assessing performance of the trenches will be agreed following trench testing, and an updated OM&M Manual will be provided to the auditor in 2014.
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12.2.5 Off-site management
Progress with respect to the management of off-site plumes is satisfactory. A significant body of work has been undertaken to develop a remediation and management strategy for the foreshore which is currently being implemented. An assessment of the risks associated with AFFF has been carried out; this concludes that the fluorosurfactants constituents of AFFF pose a low risk to human health and the environment, and will not have affected the conclusions of an earlier assessment of the risk posed by hydrocarbons on intertidal ecosystems. Further monitoring has been undertaken and is expected to be reported in the next SMP Annual Report.
12.3 Recommendations
Recommendations for further work are included in this report, and are collated in Table 21 with a priority for implementation assigned to each recommendation. The priority rankings are as follows: High priority: the recommendation should be addressed in the short term (eg mid 2015), it does not necessarily have a relationship to the significance of the issue or the risk related to the issue.
Medium priority: item should be addressed prior to the next audit (end September 2016).
Low priority: item can be addressed over a longer period of time or as applicable based on tasks underway at the Refinery.
Ongoing: item is ongoing or has a longer term component.
Table 21 Recommendations
Report Recommendation Priority Section
5.1 Continue with biennial audit reporting with the next audit report to be Medium prepared in 2016.
5.3 Provide a schedule of works up until the due date of the next audit report High including assessments of boundary containment, addressing audit recommendations and action items, and provision of reports to the auditor.
5.5.2 Continue to implement the foreshore Remediation Implementation Design High &10.3 and Landscape Management Plan.
5.6 & 9.1 The OM&M Manual should be revised (Item C.1.18 of the AMT) to include High goals and metrics for performance and ongoing operation of the containment systems, including requirements for drawdown and NAPL thickness.
7 Continue implementation of the tundish and drainage line replacement Medium program, and replacement of Field Sump 5.
8.3 Continue monitoring NAPL plumes and groundwater quality in accordance On-going with the GWMP (Item B1.1 of the AMT).
8.4 Continue to implement On-site LNAPL Management Plan and comply with Ongoing the Supplementary Notice.
8.6 Determine whether overflows from Field Sump 5 have been considered as Medium a possible source of groundwater contamination for inclusion in the SMP Annual Report, and include in the SMP if necessary.
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Report Recommendation Priority Section
8.7.2 Review information relating to soil vapour and on-site building monitoring High and confirm that the risk posed by volatile gases is acceptable (Item B.10.9 of AMT).
8.8 Determine the requirements for management or remediation of the source Medium of NAPL associated with Plume 2.
9.2 Prepare a plan to confirm the adequacy of containment along each Medium boundary of the Refinery, resolving specific issues related to particular locations noted in the Audit Reports including the boundary near Nerita Gardens (Item C.1.3.2 of AMT).
9.3 Confirm that the NGIT provides effective boundary containment. Medium
9.4 Confirm that the extension of the CGIT provides effective boundary Medium containment in the vicinity of the GIT Gap.
9.5 Confirm that the CGIT provides effective boundary containment. Medium
9.6 Confirm that the SGIT provides effective boundary containment. Medium
9.7 Improve the performance of the Separation and Measurement Unit. Medium
9.9 Demonstrate and maintain effective containment of NAPL along each On-going boundary of the Refinery (Item C.1.1 of AMT).
10.1 Undertake periodic reappraisal of risk posed by NAPL and dissolved phase On-going contamination to off-site areas, and requirements for response (Item D.1.1.1 of AMT).
10.2 At the annual meetings that form part of the ongoing liaison with GGS, On-going issues that arise regarding soil and groundwater contamination should be discussed and minuted.
10.4 Continue to monitor Plumes 12 and 13 and liaise with Terminals. On-going
10.5 Continue to liaise with relevant parties to determine progress on clean up On-going of Plume 14 that has migrated onto Refinery land from off site, and continue monitoring to confirm that the extent of the plume is not increasing.
10.7 Undertake further monitoring to confirm that concentrations of Low fluorosurfactants at the foreshore are stable or decreasing and not increasing (Item D.2.7 of AMT).
74 | GHD | Report for Viva Energy Refining Pty Ltd - Geelong Refinery, 31/17032/230593 Page 85 of 94
13. References
ANZECC & Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ), 2000: Australian and New Zealand Guidelines for Fresh and Marine Water Quality. National Water Quality Management Strategy.
EPA Victoria, 2007: Environmental Auditor Guidelines for the Preparation of Environmental Audit Reports on Risk to the Environment, EPA Publication 952.2.
EPA, 2011: Section 62A Clean Up Notice NO10056 to Shell Refining (Australia) Pty Ltd, 30 November 2011.EPA, 2013: Licence Shell Refining (Australia) Pty Ltd 46555 as amended 30 June 2013. ERM, 2009a: Targeted Gas Sampling Assessment at the Shell Geelong Refinery, Corio, Victoria ref: 0200341_L01_Final Draft.doc, 27 July 2009. ERM, 2009b: Operation, Maintenance and Monitoring Manual, September 2009. ERM, 2010: DRAFT Clean Up Plan, Shell Geelong Refinery, August 2010, (ref: 0111321CUP_Draft) ERM, 2011: Site Management Plan Report Shell Geelong Refinery, 80 Refinery Road, Corio, Victoria 30 September 2011.
ERM, 2012a: Draft 2012 Groundwater Monitoring Plan Shell Geelong Refinery, May 2012.
ERM, 2012b: Draft 2012 Site Management Plan, Shell Geelong Refinery, 1 June 2012, (ref: 0148419SMP_Draft).
ERM, 2012c: Conceptual Site Model Plume 2, 2 July 2012.
ERM, 2013a: 2013 Drilling and Well Decommissioning Factual Report Shell Geelong Refinery ref: 0186597_Draft, 14 March 2013.
ERM, 2013b: Shell Geelong Refinery - foreshore (Plumes 9, 10, 11A) - Site-Specific E2E Strategy Plan – Final, 18 April 2013.
ERM, 2013c: Shell Geelong Refinery - foreshore (Plume 11B) - Site-Specific E2E Strategy Plan – Final, 18 April 2013.
ERM, 2013d: Conceptual Site Model - Plumes 7 and 13, 23 April 2013.
ERM, 2013e: Foreshore Remediation Alternatives Analysis (RAA) Shell Geelong Refinery Shell Refining (Australia) Pty Ltd (ref: 0169835RAA_Final_v2), 23 April 2013.
ERM, 2013f: Conceptual Site Model Plume 6 ref: 0195533CSM_Plume 6_Final.pdf, 23 April 2013. ERM, 2013g: Final W5 Offsite/Onsite Investigation Factual Report Shell Geelong Refinery ref: 0173654_0174596_W5_Final, 30 May 2013. ERM, 2013h: Site Management Master Plan ref: 0200351SMMP_Final, 9 July 2013. ERM, 2013i: On-site Light Non-Aqueous Phase Liquid (LNAPL) Management Plan, 16 July 2013.
ERM, 2013j: MPVE Pilot Trial, 16 July 2013.
ERM, 2013k: 2013 Site Management Plan Annual Report ref: 0200341 SMP AR_Draft V2, 1 August 2013.
ERM, 2013l: Remediation Implementation Design Shell Refining (Australia) Pty Ltd ref: 0169835RID_Final_v2, 5 August 2013.
GHD | Report for Viva Energy Refining Pty Ltd - Geelong Refinery, 31/17032/230593 | 75 Page 86 of 94
ERM, 2013m: Final Draft Conceptual Site Model Plumes 8/8A/8B/8C and 12 ref: 0175223CSM_Plumes 8_12_FD_130903, 3 September 2013. ERM, 2013n: 2013 Groundwater Monitoring Plan Shell Geelong Refinery, 80 Refinery Road, Corio, Victoria (Final Draft_V2) ref: 0187858_2013_GWMP_Final Draft_v2.docx, 4 September 2013. ERM, 2013o: Methane and Carbon Dioxide Monitoring at the Shell Geelong Refinery ref: 0195487_L01.DOCX, 26 September 2013. ERM, 2013p: Effectiveness testing and optimisation plan - groundwater interception trench (GIT) upgrades ref: 0188711L01DB.DOCX, 1 October 2013.
ERM, 2013q: Final Draft Groundwater Interception Trench Extension Construction Report ref: 0186062R01_FD, 14 October 2013. ERM, 2013r: Proposed changes to schedule for LNAPL fingerprint analysis in the GWMP (Letter), 15 October 2013. ERM, 2013s: Letter Update - Foreshore Low-energy Light Non-Aqueous Phase Liquid (LNAPL) Recovery Works 2013, Shell Geelong Refinery, Corio, Vic, 12 December 2013.
ERM, 2014a: Final draft LNAPL Baildown Testing and Analysis Report, 14 January 2014.
ERM, 2014b: Draft SumpN Investigation, Maintenance and Closure Report, Shell Geelong Refinery, Corio, Vic, 14 February 2014.
ERM, 2014c: Scope and Overview Plume 2 2014, 17 February 2014.
ERM, 2014d: 2014 Plume 2 Drilling Summary Report, 24 June 2014.
ERM, 2014e: CSM Addendum, 24 June 2014.
ERM, 2014f: Q2(2013) - Q1(2014) Groundwater Monitoring Report, 27 June 2014.
ERM, 2014g: 2014 Site Management Plan - Annual Report, 27 June 2014.
ERM, 2014h: Indoor Methane and Carbon Dioxide Monitoring, June 2014
ERM, 2014i: Proposal for Well Installation, Decommissioning and Repairs at the Shell Geelong Refinery, 1 July 2014.
ERM, 2014j: Groundwater Monitoring Plan, 1 July 2014.
GHD, 2005a: Shell Geelong Refinery Statutory Environmental Audit Report (Heat Exchangers), August 2005. GHD, 2005b: Shell Geelong Refinery Statutory Environmental Audit Report (EMS Audit).
GHD, 2008a: Environmental Audit, Geelong Refinery Management System Report, March 2008.
GHD, 2008b: Shell Geelong Refinery, Environmental Audit Contaminated Land and Groundwater, December 2007 (revised and re-issued July 2008). GHD, 2008c: Report for Shell Geelong Refinery, Environmental Audit Contaminated Land and Groundwater, May 2008 (re-issued July 2008). GHD, 2009: Report for Shell Geelong Refinery, Environmental Audit Contaminated Land and Groundwater, July 2009.
GHD, 2010: Report for Shell Geelong Refinery, Environmental Audit Contaminated Land and Groundwater, October 2010.
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GHD, 2011: Shell Geelong Refinery 53V Audit – Auditor Response to proposed Strategy for Validation of On-site PSH Recovery (Ref:31/17032/203168) GHD, 2012a: Shell Geelong Refinery, Request for Advice from EPA regarding NAPL Clean Up on Foreshore
GHD, 2012b: Report for Shell Geelong Refinery, 53V Environmental Audit Report, September 2012 National Environment Protection Council (NEPC), 1999; National Environment Protection (Assessment of Site Contamination) Measure, 1999 as amended and in force on 16 May 2013 Parsons Brinckerhoff, (2003): Environmental Audit of Groundwater Management at the Geelong Refinery, July 2003.
SAI Global, 2004: Audit Report – Triennial Audit, Quality and Environmental, April 2004. Victorian Government, 1997: State Environment Protection Policy (Groundwaters of Victoria). Victorian Government Gazette No. S160, 17 December 1997. Victorian Government, 1997: State Environment Protection Policy(Waters of Victoris) Schedule F6 Waters of Port Phillip Bay, 1997.
Victorian Government, 2001: State environment protection policy (Air Quality Management), 2001.
Victorian Government, 2002: State Environment Protection Policy (Prevention and Management of Contamination of Land). Government Gazette No. S95, 4 June 2002.
Victorian Government, 2003: State Environment Protection Policy (Waters of Victoria). Victorian Government Gazette No. S107, 4 June 2003. V&C Environment Consultants Pty Ltd, 2005 : Environmental Audit of the Shell Refinery Jetty Report, July 2005.
GHD | Report for Viva Energy Refining Pty Ltd - Geelong Refinery, 31/17032/230593 | 77 Page 88 of 94
Figures
GHD | Report for Viva Energy Refining Pty Ltd - Geelong Refinery, 31/17032/230593 Page 89 of 94
Figure 1 Site location
Figure 2 Site layout plan
Figure 3 CUP action plan
GHD | Report for Viva Energy Refining Pty Ltd - Geelong Refinery, 31/17032/230593 Page 90 of 94 268,000 272,000
h
t
u t o C Heales Rd S le y d t Rennie St s R n
r First Av t Tillys Rd s Macgregor Ct u
e T Prosperity Dr r Cummins Rd o Frys Rd BacchusMarsh Rd F
Obriens Rd HOVELLS CREEK Mcmanus Rd Karlton Cl Farnb orough St Bell Rd Broderick Rd Selbourne Rd Grange Rd
Montview Rd Lansell Rd Browallia Dr l C Fairba ArmadaleOrrong St Rd n irn o Station Rd Stanhope St t Dr Nigella e A e
5,784,000 v 5,784,000 r Torresdale Rd t
S harland S R d Plantation Rd BiddlecombeAv r Clyde Rd Browning Dr C Harding St R h e M e m g Plantation Rd r i u l
n i o n Kosciusko Av gt r o d Howitt Av n S C b Princes Hwy School Rd t R r d
Railway Res Shell Pde Pembroke St o x School Rd R a
n Kalver St TeresaAv
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Goldsworthy Rd r
C t Maine Ct i o r OntarioAv t Princes Hwy Dr e Colora do D Station St Vermont Av
IndianaAv CORIO BAY PrincesCuthbertson Hwy Rd Cox Rd Wharf Rd Wren St Ibis Ct Sandra Av St Georges Rd ia Gr n St Georges Rd eRobin Av e Moa St d d Iris St P r Aster St The Mall a le g v G Greta St a A Rose Av E d Princes Hwy ir Baron St b Plume St l Jay St l
e Madden Av
B Dove St
Sparks Rd Walpole Pde NORLANE
y Kalinga St w Walchs Rd H Alkira Av Don Tallis St s nelly Av Foch St e c Beatty St e W n d i a r Coonil Cr a n it P Iona St Forster St a a ra Tennyson St y Rd l G Arunga r p r Av e Sea s b Breez E A e Pde e Myrtle h Brooks St NORTH SHORE Gr T t S Portland St North Shore Rd 5,780,000 MELBOURNE 5,780,000 n a The Esplanade NORTH SHORE Morg d WERRIBEE R y SITE LOCATION a BaldwinAv u BirdwoodAv Q COWIES CREEK rio Co ^_ GEELONG Cowie St
North Shore Rd
Edols St 268,000 272,000
LEGEND
Site Boundary Freeway Collector Railway Watercourse Channel Park
Highway Proposed River Drain/Channel/Other 2 Rail station Arterial Tracks Stream
1:30,000 at A4 Viva Energy Refining Pty Ltd Job Number 31-17032 0110 220 440 660 880 Geelong Refinery 53V Environmental Audit Revision A Date 04 Sep 2014 Metres Map Projection: Transverse Mercator Horizontal Datum: GDA 1994 Grid: GDA 1994 MGA Zone 55 o Site Location Plan Figure 1 180 Lonsdale Street Melbourne VIC 3000 Australia T 61 3 8687 8000 F 61 3 8687 8111 E [email protected] W www.ghd.com G:\31\17032\GIS\GIS_2014\Maps\Deliverables\3117032_001_Site_Location_A4P.mxd © 2014. Whilst every care has been taken to prepare this map, GHD (and The Department of Environment and Primary Industries (DEPI), and Viva Energy Refining Pty Ltd) make no representations or warranties about its accuracy, reliability, completeness or suitability for any particular purpose and cannot accept liability and responsibility of any kind (whether in contract, tort or otherwise) for any expenses, losses, damages and/or costs (including indirect or consequential damage) which are or may be incurred by any party as a result of the map being inaccurate, incomplete or unsuitable in any way and for any reason. Data source: Base Layer (Roads parks watercourses, locality inset etc.) - DEPI, VicMap, 2014. Site Boundary - GHD, 2014 Created by:ahorvath Page 91 of 94
Goodall Ct Prouse Ct Sharla r Weir Ct nd Rd D Streeton Cl n ir a b Booth Ct ir a t Welch Ct S F e g a Harding St t y
m r n Shell Pde k i ley A A v Washington St Plantation Rd c Coolidge St Buffer Zone M
Princes Hwy BiddlecombeAv Geelong Howitt Av Railway Res School Rd Grammar School Kennedy Lane Buangor St School Rd v Torbreck St Kosciusko Av A Hendy St Allen Rd n o Nerita Gardens d e c a M
Equestrian Centre Tower Rd CORIO
ffalo Av Bogong St u B Foreshore Rd
Purnell Rd Buffer Zone Refinery Rd
Refinery
Princes Hwy Princes Hwy
Harpur Rd
Refinery
Station St
CORIO BAY Northern Water Reclamation Plant Cuthbertson Rd Wharf Rd
Lowe St
Sandra Av Terminals
St Georges Rd Lowe St Southern Industrial Zone
Zinnia St The Mall Agra St Tulip St Greta St
Rose Av Baron St T h e
E Madden Av s Walpole Pde p lanade Cooper St
Seabeach Pde
Sparks Rd r C l i Walchs Rd n 2010 o o Image © 2014 CNES / Astrium C
LEGEND Audit Areas Northern Water Reclamation Plant Freeway Collector Channel 2 Rail station Stream Buffer Zone Refinery Highway Tracks Drain/Channel/Other Equestrian Centre Southern Industrial Zone Railway Arterial Geelong Grammar School Terminals Nerita Gardens
1:15,000 at A4 Viva Energy Refining Pty Ltd Job Number 31-17032 0 55 110 220 330 440 Geelong Refinery 53V Environmental Audit Revision A Date 04 Sep 2014 Metres Map Projection: Transverse Mercator Horizontal Datum: GDA 1994 Grid: GDA 1994 MGA Zone 55 o Refinery and Surrounds Figure 2 180 Lonsdale Street Melbourne VIC 3000 Australia T 61 3 8687 8000 F 61 3 8687 8111 E [email protected] W www.ghd.com G:\31\17032\GIS\GIS_2014\Maps\Deliverables\3117032_002_Audit_Areas_Rev1_A4P.mxd © 2014. Whilst every care has been taken to prepare this map, GHD (and The Department of Environment and Primary Industries (DEPI), and Viva Energy Refining Pty Ltd) make no representations or warranties about its accuracy, reliability, completeness or suitability for any particular purpose and cannot accept liability and responsibility of any kind (whether in contract, tort or otherwise) for any expenses, losses, damages and/or costs (including indirect or consequential damage) which are or may be incurred by any party as a result of the map being inaccurate, incomplete or unsuitable in any way and for any reason. Data source: Base Layer (Roads parks watercourses, locality inset etc.) - DEPI, VicMap, 2014. Aerial Imagery (27/01/2014) - Google: Google Earth Pro. 2014, Extracted 03/09/2014. Site Boundary - GHD, 2014 Created by:ahorvath Page 92 of 94
Text
Image © 2014 ERM
LEGEND
Paper Size A4 Viva Energy Refining Pty Ltd Job Number 31 / 17032 Revision 0 This Figure has been reproduced Geelong Refinery 53V Environmental Audit Date 08 Sep 2014 from ERM, '2012 Site Management Plan'. Env. Audit, Contaminated Land and Groundwater CUP Action Plan Figure 3 180 Lonsdale Street Melbourne VIC 3000 Australia T 61 3 8687 8000 F 61 3 8687 8111 E [email protected] W www.ghd.com G:\31\17032\GIS\GIS_2014\Maps\Deliverables\3117032_003_CU_Action_Plan_A4P.mxd © 2014. Whilst every care has been taken to prepare this map, GHD and Environmental Resources Management Australia Pty Ltd (ERM) make no representations or warranties about its accuracy, reliability, completeness or suitability for any particular purpose and cannot accept liability and responsibility of any kind (whether in contract, tort or otherwise) for any expenses, losses, damages and/or costs (including indirect or consequential damage) which are or may be incurred by any party as a result of the map being inaccurate, incomplete or unsuitable in any way and for any reason. Data source: ERM, 2012 Site Management Plan, Figure 3. (0148419 2012 SMP) 01/06/2012. Created by: jgreaves Page 93 of 94
GHD 180 Lonsdale Street Melbourne, Victoria 3000 T: (03) 8687 8000 F: (03) 8687 8111 E: [email protected]
© GHD 2014 This document is and shall remain the property of GHD. The document may only be used for the purpose for which it was commissioned and in accordance with the Terms of Engagement for the commission. Unauthorised use of this document in any form whatsoever is prohibited. G:\31\17032\Wp\230593.docx Document Status Rev Author Reviewer Approved for Issue No. Name Signature Name Signature Date 0 P Nadebaum P Egberts P Nadebaum 30/09/14 J Roolker
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