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WA1488 Panel Hearing Expert Evidence Statement Hydrogeology

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WA1488 Panel Hearing Expert Evidence Statement Hydrogeology Deep Creek WA1488 Colbert Creek 25 50 75 100 122 0 EXPERT EVIDENCE STATEMENT, GRANTVILLE QUARRY PLANNING PERMIT APPLICATION 120388-1 1381-1395 BASS HIGHWAY, GRANTVILLE HYDROGEOLOGY - JOHN LEONARD JOHN LEONARD CONSULTING SERVICES Groundwater and Environmental Consultants 003159 JOHN LEONARD CONSULTING SERVICES GROUNDWATER AND ENVIRONMENTAL CONSULTANTS JOHN LEONARD CONSULTING SERVICES Pty Ltd ACN082316890 28 Mernda Avenue Carnegie VIC 3163 Mobile: 0407 816 237 e-mail: [email protected] Author: John Leonard JLCS Ref. No.: GW-21/002. March 2021 Planning Permit Application 120388-1 i GW-21/003 Expert Evidence - Hydrogeology – John Leonard 003160 JOHN LEONARD CONSULTING SERVICES GROUNDWATER AND ENVIRONMENTAL CONSULTANTS TABLE OF CONTENTS 1.0 NAME AND ADDRESS 1 2.0 QUALIFICATIONS AND EXPERIENCE 1 3.0 INSTRUCTIONS 2 4.0 REPORT RELIED UPON AND ADOPTED 3 5.0 DETAILS AND QUALIFICATIONS OF ANY PERSON WHO CARRIED OUT ANY TESTS OR EXPERIMENTS UPON WHICH THE EXPERT HAS RELIED IN PREPARING THE STATEMENT 3 6.0 FURTHER WORK SINCE PREPARATION OF MY REPORT 5 7.0 HA REPORT SUMMARY AND CONCLUSIONS 5 8.0 DECLARATION 6 9.0 BACKGROUND 7 10.0 CONTEXT AND GROUNDWATER CHARACTERISTICS 7 11.0 THE PROPOSED FURTHER DEVELOPMENT AND SUPPORTING DOCUMENTATION, INCLUDING THE PROPOSALS TO INTERSECT GROUNDWATER AND EXTRACT SAND BELOW THE GROUNDWATER TABLE 12 12.0 WHETHER THE PROPOSED FURTHER DEVELOPMENT WILL CAUSE ANY UNREASONABLE GROUNDWATER IMPACTS 14 13.0 ANY ISSUES RAISED IN THE OBJECTIONS TO THE AMENDMENT APPLICATION THAT ARE WITHIN YOUR EXPERTISE. 19 14.0 THE NEED FOR ANY ADDITIONAL WORKS OR OTHER MEASURES TO MITIGATE ANY POTENTIAL GROUNDWATER IMPACTS. 24 15.0 THE ISSUES SET OUT IN PARAGRAPHS 6 AND 19 OF THE DIRECTIONS TO THE EXTENT WITHIN YOUR EXPERTISE 25 March 2021 Planning Permit Application 120388-1 i GW-21/003 Expert Evidence - Hydrogeology – John Leonard 003161 JOHN LEONARD CONSULTING SERVICES GROUNDWATER AND ENVIRONMENTAL CONSULTANTS 16.0 ANY OTHER GROUNDWATER MATTERS YOU CONSIDER RELEVANT TO THE ASSESSMENT OF THE PROPOSED FURTHER DEVELOPMENT 25 17.0 HA REPORT SUMMARY AND CONCLUSIONS 25 LIST OF FIGURES FIGURE 1 WA1488 and surrounds pre-quarrying Terrain Relief Model showing the incised Deep and Colbert creek FIGURE 2 WA1488 and Surrounds Pre-Quarrying Filled Topographic Contours FIGURE 3 Mapped Outcrop Geology, Grantville Area (modified after DPI, 2011) FIGURE 4 WA1488 Terrain Relief Models, A) July 2019, and WPV Proposed Final Sand Extraction Areas FIGURE 5 Daily Time-Drawdown Data Plots, Discharge = 11.65 L/sec FIGURE 6 Daily Time-Drawdown Data Plots, Deficit Rate = 12.22 L/sec FIGURE 7 Deep Creek “True 3D” View showing incised creek and both on-stream and off-stream pools FIGURE 8 Deep Creek Streambed Topographic Profile and Position of the Underlying Water Table LIST OF TABLES TABLE 1 Heavy Metal Concentrations in Filter Cake Leachate, Eurofins Report 742427- L Extract LIST OF PLATES PLATE 1 Deep Creek Streambed: A) 60 m Upstream from Bass Highway, and B) Upstream of Confluence with MW3840 Tributary Channel March 2021 Planning Permit Application 120388-1 ii GW-21/003 Expert Evidence - Hydrogeology – John Leonard 003162 JOHN LEONARD CONSULTING SERVICES GROUNDWATER AND ENVIRONMENTAL CONSULTANTS 1.0 NAME AND ADDRESS John Leonard 28 Mernda Avenue Carnegie VIC 3163. 2.0 QUALIFICATIONS AND EXPERIENCE 1. I am a recognised hydrogeological expert. My specific skills include geology/basin analysis, groundwater resource evaluation, production bore design, aquifer hydraulic testing, groundwater monitoring, and impact and risk assessments. A Statement documenting my qualifications, lecturing engagements, project experience and publication is attached as Attachment A. and summarised in the following Sections. 2.1 Qualification • Graduate Diploma in Computer Simulation, SIT. • Master of Applied Science (Hydrogeology/Engineering Geology), UNSW. • Graduate Diploma in Hydrogeology, SA Institute of Technology. • Diploma Applied Science (Geology), Ballarat School of Mines. 2.2 Employment Positions • Senior Principal, John Leonard Consulting Services • Principal Hydrogeologist, CH2M Hill • Principal Hydrogeologist, Gutteridge Haskins Davey (now GHD). • Manager, Groundwater Policy and Planning Branch, DWR, Victoria • Principal Hydrogeologist, Dames & Moore International • Manager, Basin Studies (subsurface mapping), Geological Survey of Victoria • Director, Victorian Government Drilling Unit • Officer in Charge, Groundwater Resources Section, Geological Survey of Victoria • Contract Geologist Exon/Esso • Contract Hydrogeologist EPA Victoria 2.3 Project Work 2. I have worked on about 500 projects mostly in Australia, but also in Asia and the Middle East including manager and principal researcher for three US Aid projects. • Groundwater resource investigation, evaluation and development. • Groundwater recharge. • Mining and Extractive Industry. • Civil/geotechnical engineering and Infrastructure. March 2021 Planning Permit Application 120388-1 1 GW-21/003 Expert Evidence - Hydrogeology – John Leonard 003163 JOHN LEONARD CONSULTING SERVICES GROUNDWATER AND ENVIRONMENTAL CONSULTANTS • Environmental impact assessment. • Urban Hydrogeology (land development and salinity assessment) projects. • Landfill and contaminated site projects (groundwater, surface water, gas). • Soil contamination investigation and assessment projects. 2.4 Lecturing Engagements 3. I presented groundwater courses at a number of Australian Universities and have lectured at Specialist Workshops and Schools. Topics included groundwater investigations and evaluation; groundwater contamination, groundwater flow and solute transport modelling; pumping test design and data interpretation; drilling and bore construction; and conducting hydrogeological assessments. 2.5 Reports and Publications 4. I have prepared 32 publications including two books on Victorian hydrogeology published by the former Department of Water Resources, chapters on “Groundwater” in the previous two editions of the Geology of Victoria, and a chapter in Introducing Victorian Geology. I was a co-author of the Hydrogeological Assessment (Groundwater Quality) report prepared for the Victoria EPA. An abridged version of this report was published by the EPA as part of their Best Practice Environment Management Guidelines series. I was also a member of the Expert Committee working with the EPA to prepare the (Victorian) Groundwater Sampling Guidelines. I have also prepared more than 450 consultant reports and 38 GSV open file reports. I was the sole author of most these publications and reports. 2.6 Committees 5. I have served on high-level government committees including the former Groundwater Advisory Committee (Victoria), South West Victoria Water Resources Management Task Force, Murray-Darling Basin Groundwater Modelling Committee, and Victorian Salinity Bureau Research and Investigation Committee. I was the inaugural Secretary of the Victorian Branch of the International Association of Hydrogeologists and am a former Vice-President. 3.0 INSTRUCTIONS 6. Received written instructions from Equipe Lawyers acting for Dandy Premix Quarries Pty Ltd (DPQ) on 4 February 2021. My instructions which are included in Attachment 2, were to conduct a view(s) of the Subject Land and the surrounding land and prepare an expert witness statement addressing the following matters and questions: 1. The site context of the Subject Land, in particular the groundwater characteristics of the Subject Land and surrounding land. 2. The Proposed Further Development and supporting documentation, including the proposals to intersect groundwater and extract sand below the groundwater table. 3. Whether the Proposed Further Development will cause any unreasonable March 2021 Planning Permit Application 120388-1 2 GW-21/003 Expert Evidence - Hydrogeology – John Leonard 003164 JOHN LEONARD CONSULTING SERVICES GROUNDWATER AND ENVIRONMENTAL CONSULTANTS groundwater impacts. 4. The need for any additional works or other measures to mitigate any potential groundwater impacts. 5. Any issues raised in the objections to the Amendment Application that are within your expertise. 6. The issues set out in Paragraphs 6 and 19 of the Directions (which our client must address in a Part A and a Part B submission) to the extent within your expertise. 7. Any other groundwater matters you consider relevant to the assessment of the Proposed Further Development. 4.0 REPORT RELIED UPON AND ADOPTED 7. In in preparing my Expert Witness Statement I relied primary on my 2019 assessments report entitled “WA1488, 1381 1395 Bass Highway, Grantville, Work Plan Variation, Phase 2 Development, Hydrogeological Assessment” prepared by John Leonard Consulting Services (JLCS) as presented in Hearing Book (HB) Tab 20. 8. I was the sole author of the 2019 Hydrogeological Assessment (HA) report. 9. I adopt my 2019 HA report as my evidence. 10. I summarised key components of my HA report in my Statement as background to my responses to the specified instructions from Equipe Lawyers. 11. My responses include assessments of information on filter cake chemistry and leachate chemistry (from column leaching tests) obtained subsequently to preparation of my 2019 HA report. 12. The additional assessments did not cause me to change my opinion that implementing the endorsed WA1488 variations would not cause unacceptable water table drawdown, would not reduce groundwater discharge into nearby creeks or into Western Port Bay, or adversely impact local groundwater quality. 5.0 DETAILS AND QUALIFICATIONS OF ANY PERSON
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