inquiry and advisory committee north east link …...preliminary matters and further information...

Inquiry and Advisory Committee

North East Link Project

Preliminary Matters and Further Information Request

20 June 2019

Preliminary Matters and Further Information Request

General Declaration:

This information is sought for clarification and is sought without prejudice to the final recommendations of the Inquiry and Advisory Committee (IAC). The North East Link Project (NELP) and other parties should not assume that the issues raised in this request for information are the only issues of interest to the IAC or that the IAC has particular concerns about these issues. The IAC reserves the right to seek further information as necessary throughout the course of the Public Hearing process. The issues raised in this report do not represent any, or the only, opinions of the IAC.

20 June 2019

Nick Wimbush, Chair

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Contents Page

1 Introduction 3

1.1 Background .............................................................................................................. 3

1.2 Purpose of this document ....................................................................................... 3

1.3 The IAC and Technical Advisers ............................................................................... 3

2 General issues ...........................................................................................................4

2.1 Inclusion of expert recommendations – all parts of Project ................................... 4

2.2 Legislation and policies............................................................................................ 4

3 Traffic and transport .................................................................................................5

3.1 Manningham Road intersection .............................................................................. 5

3.2 Traffic volumes ........................................................................................................ 5

3.3 Road Geometry ....................................................................................................... 5

3.4 Road Closures and Diversions ................................................................................. 6

3.5 Traffic Modelling ..................................................................................................... 6

4 Land use and infrastructure .......................................................................................7

4.1 Planning Scheme Amendment ................................................................................ 7

5 Visual impacts, urban design and landscape ..............................................................9

5.1 Urban Design Strategy (UDS) .................................................................................. 9

6 Social and community impacts ................................................................................ 11

6.1 Impacts on private recreation facilities and Crown land during construction and operation phases ...................................................................... 11

6.2 Changes to the provision of public open space .................................................... 11

6.3 Local business flow on impacts ............................................................................. 11

7 Business impacts ..................................................................................................... 13

7.1 Economic impacts .................................................................................................. 13

7.2 Bulleen Industrial Precinct .................................................................................... 13

7.3 Jobs deficit ............................................................................................................. 13

8 Noise and vibration ................................................................................................. 14

8.1 Construction noise – night time criteria ................................................................ 14

8.2 Construction noise at night - predictions .............................................................. 14

8.3 Construction vibration ........................................................................................... 15

8.4 Operational noise – barrier design ........................................................................ 15

8.5 Operational noise – Plenty River Bridge ............................................................... 15

8.6 Operational noise – flood walls ............................................................................. 16

8.7 Operational noise – fixed infrastructure noise limits ............................................ 16

9 Ecology .......................................................................................................... 17

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9.1 Native Vegetation removal ................................................................................... 17

9.2 Fauna ..................................................................................................................... 18

9.3 Native Vegetation offsets ...................................................................................... 18

9.4 Other projects ....................................................................................................... 19

10 Arboriculture .......................................................................................................... 20

10.1 Tree Canopy Replacement Plan ............................................................................ 20

10.2 Cumulative Impacts ............................................................................................... 20

11 Surface Water ......................................................................................................... 21

11.1 Water regime......................................................................................................... 21

11.2 Water Quality ........................................................................................................ 21

12 Historical and Aboriginal cultural heritage ............................................................... 22

12.1 Aboriginal cultural heritage ................................................................................... 22

13 Project Delivery Framework .................................................................................... 23

13.1 Environmental management framework .............................................................. 23

13.2 Structure and wording of Environmental Performance Requirements ................ 23

Appendix A: Air Emissions and Air Quality Information Request

Appendix B: Urban Design Information Request

Appendix C: Ground Movement, Groundwater and Contamination and Soil Information Requests

Glossary and abbreviations

Act Planning and Environment Act 1987

DELWP Department of Environment, Land, Water and Planning

IAC North East Link Inquiry and Advisory Committee Process

NELP North East Link Project

Proponent North East Link Project (a Division of the Major Transport Infrastructure Authority)

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1 Introduction

1.1 Background

The Minister for Planning has appointed an Inquiry under the Environment Effects Act 1978 and an Advisory Committee under the Planning and Environment Act 1987. The Joint Inquiry and Advisory Committee (IAC) will report on the North East Link Project (the Project) in accordance with the Terms of Reference dated 11 April 2019.

The IAC has undertaken a preliminary review of the Environment Effects Statement (EES) and supporting documents. This report provides notice to the North East Link Project (the Proponent) that there are a number of matters that the IAC is seeking clarification of, or further information on, as part of the public hearing process.

1.2 Purpose of this document

This report is provided to the Proponent on 20 June 2019 to enable it to review the information sought and to provide a preliminary response. The report will be formally tabled at the Directions Hearing on 21 June 2019.

This report contains requests for information from the Proponent, including points of clarification arising from the IAC and IAC’s technical advisers review of the EES material. It is an initial request based on a review of the material to date and should in no way be construed as expressing opinions or establishing the scope of the IAC’s considerations.

1.3 The IAC and Technical Advisers

This report contains issues and information requests in two forms. In the body of the report a number of issues are raised by the IAC. In the Appendices a number of issues are raised, and information requests made by the IAC’s technical advisers. These requests are made within a template provided by the IAC, but the content is entirely that of the technical advisers and is not endorsed by the IAC. The requests from the technical advisers are to further inform their advice to the IAC which will be sought by the IAC at different points in the inquiry process.

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2 General issues

2.1 Inclusion of expert recommendations – all parts of Project

(i) Reference

A number of Technical Reports contain specific expert recommendations. An example is a number of specific recommendations contained in Technical Report K (Heritage) in respect of identified heritage assets such as the conservation of elements of Eastern Freeway infrastructure between Hoddle Street and Bulleen Road. This ties in with Environmental Performance Requirements (EPRs) such as HH1 requiring the preparation of detailed design plans.

(ii) Request

1. Details of the format and wording of specific recommendations of technical experts in all specialist areas that are accepted, or not, by the Proponent and how these have informed the EPRs, or other delivery documents and mechanisms.

2. Following the circulation of expert evidence, the same exercise should be undertaken if there are new or additional expert recommendations made.

2.2 Legislation and policies

(i) Reference

Melbourne Water submission (Submission 800, page 4 and 7) refers to relevant legislation

and waterway strategies. There may also be other relevant legislation such as the new

Environment Protection Act 2017 that the IAC should consider in the assessment.

(ii) Request

3. An understanding of whether and how the Project has considered the recommendations of the Yarra Strategic Plan, the Yarra River Protection (Wilip-gin Birrarung murron) Act 2017 and the Healthy Waterways Strategy (2018) in its impact assessment.

4. Whether the Project needs to, or has, responded to the Environment Protection Act 2017, and if so how (for both construction and operation).

5. The status of any Victoria Transport Plan under the Transport Integration Act 2010 and how the Project responds to the Plan.

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3 Traffic and transport

3.1 Manningham Road intersection

(i) Reference

Various through EES. The Manningham Road interchange appears on initial review to generate significant social, business and ecological Project impacts.

(ii) Request

6. The Proponent articulate the design process and evolution for this interchange and whether not accommodating all traffic movements or no-interchange options were considered in the Project design.

3.2 Traffic volumes

(i) Reference

Technical Reports A – Traffic and Transport Technical Report contain large tables of traffic volume data (main body i.e. Tables 8-4, 9-4) and Appendix D Forecast traffic volumes.

(ii) Request

7. That existing and forecast traffic volumes for the various scenarios be provided in Excel format.

3.3 Road Geometry

(i) Reference

Map Book scale and typical cross sections require augmentation to determine the extent of works at several locations.

(ii) Request

8. Additional maps showing existing conditions including:

a) the existing and proposed road reservation

b) dimensions showing the extent of road widening.

9. Additional cross sections of Eastern Freeway (A3) at:

a) Eram Road between Heathfield Rise and Third Avenue, Box Hill North

b) Estelle Street at/near Colite Street, Bulleen

c) Mountain View Road, North Balwyn (section parallel with Eastern Freeway)

10. Provide three (3) A1 sets of updated Map Book.

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3.4 Road Closures and Diversions

(i) Reference

The Traffic Report Chapter 10.5 discusses impacts and potential remedial works for various road closures and diversions.

(ii) Request

11. A consolidated set of maps that give an overview of the changes to existing

connectivity to vehicular, pedestrian, public transport and other connections for both

the Project construction and operation phases.

3.5 Traffic Modelling

(i) Reference

Technical Report A – Appendix B – VLC transport modelling report Section 3.4 identifies that several major road projects have been excluded from the transport modelling for the future base cases, however there is no explanation as to why these projects were excluded.

(ii) Request:

12. Information to assist the IAC understand why these particular projects have been excluded.

13. Whilst the IAC understands an east west link between the Eastern Freeway and Citylink is not Government policy, submitters (eg City of Yarra Submission 386, page 3) have raised the issue. Clarification would be appreciated as to whether any proposed Eastern Freeway works would preclude a possible east west link connection in future.

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4 Land use and infrastructure

4.1 Planning Scheme Amendment

4.1.1 Mapping for GC98

(i) Reference

Attachment V-25 notes that:

the proposed Specific Controls Overlay (SCO) boundary largely follows the Project Boundary, except for some minor increases and decreases which are categorised into one of the following…

(ii) Request

14. Mapping indicating where and to what extent the SCO Schedule 1 boundary departs from the Project Boundary.

15. Details of public notice given to owners or occupiers of any properties that may be within the proposed SCO but outside the Project Boundary.

4.1.2 Terminology proposed in North East Link Project Incorporated Document, April 2019

(i) References

In Attachment V, Appendix B Draft Planning Scheme Amendment documents there is variation in the use of proposed terms such as “in accordance with” and “generally in accordance with”. There are also requirements to prepare and submit plans to the satisfaction of the Minister for Planning but sometimes there is no associated requirement for them to be “approved” by the Minister. There appears to be no definition of “the Project” or similar key terms for the purpose of Planning Scheme provisions.

(ii) Request

16. Confirmation whether the terminology used in the draft Amendment is intentional, why it has been selected and how various terms are to be defined for the purposes of the Planning Scheme.

17. Whether any amendments are proposed to the Incorporated Document or Design Development Overlay (DDO) provisions at this stage of the IAC proceeding, including in response to submissions.

4.1.3 Timing and method of public consultation

(i) References

Draft clause 4.7.4(c) of the Incorporated Document provides for public inspection on an identifiable Project website for 15 business days and in a local newspaper to provide an opportunity for comment before an Urban Design and Landscape Plan is submitted to the Minister for Planning for approval.

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(ii) Request

18. An explanation of how the parameters for public notice have been arrived at. More specifically, should other mechanisms for direct notice be built into the provisions where there is potential for direct impact to identified properties and the reference design has not specified details of mitigation works (eg the height or materials of noise walls)?

4.1.4 Preparatory buildings and works under the Incorporated Document

(i) Reference

Clause 4.9 of the Incorporated Document would permit specific categories of works including vegetation removal before key documents are approved.

(ii) Request

19. Confirmation whether such works are predicated on the prior approval of a Cultural Heritage Management Plan prepared under the Aboriginal Heritage Act 2006 in respect of the entirety of the Project area or whether a relevant exemption is expected to apply.

20. An explanation of why it is appropriate for non-reversible works to be permitted before key documents are approved, including vegetation removal, how the parameters for preparatory buildings and works will be documented and how it can be ensured they are to the minimum extent necessary.

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5 Visual impacts, urban design and landscape

5.1 Urban Design Strategy (UDS)

5.1.1 Reference documents and policies

(i) Reference

Chapter 2.1, page 8 of the UDS contains a list of legislation, policies and other guidance documents that assisted the formulation of the UDS.

(ii) Request

21. Provide electronic links to all listed guidelines and other documents at National and State level, and an indication as to whether any of these documents have been subsequently updated or superseded.

5.1.2 Terminology

(i) Reference

The UDS distinguishes between key design directions (Chapter 3), place-specific requirements (Chapters 4, 5 and 6) and element-based requirements and qualitative benchmarks (Chapter 7).

(ii) Request

22. An explanation about the extent to which “requirements” must be met as part of the delivery of the Project, and whether appropriate terminology has been used to reflect this. For example, how can the Proponent or successful contractor be required to ensure the provision of infrastructure that is intended to be delivered by others when no such commitment has been made? How can the Proponent or contractor “demonstrate efforts” to retain the existing significant River Red Gum near the Caltex site to the requisite degree under the current reference design?

5.1.3 Mapping of affected properties

(i) Reference

Table 10-1, page 184 onwards of Technical Report I (Social) lists properties that are expected to undergo visual change as a result of the Project.

(ii) Request

23. Confirmation of the extent of correlation between the properties referred to in that table and the properties for which photomontages or section drawings were prepared in Technical Report H (Landscape and Visual).

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5.1.4 Viewlines to proposed structures

(i) Reference

Certain viewlines to proposed structures have been depicted in photomontages in Figures 9-6 onwards.

(ii) Request

24. A selection of photomontages from ‘worst case’ vantage points where only illustrative cross sections have been provided to date and Technical Report H has assessed the visual impact at year 0 to be ‘medium’ or above.

25. Confirmation of whether ‘wire’ imaging is available to indicate the location and height of modelled infrastructure behind existing structures or revegetation for photomontages included in Technical Report H.

26. An indication of what printer output scale is most representative of human perception for the photomontages, for example A0 size paper.

5.1.5 Extent of visual impact scale

(i) Reference

The extent of visual impact is outlined in Chapter 3.5.3, page 13 Technical Report H (Landscape and Visual). In some instances, certain ratings are predicated on all four nominated inputs being present or ‘high’.

(ii) Request

27. Confirmation of the source of this rating methodology (such as a relevant guideline, manual or the like) and an analysis of how this methodology has been applied by relevant court, panel or tribunal decisions.

5.1.6 Overshadowing

(i) Reference

Technical Report E – Land use planning Appendix D – Overshadowing mapping does not

show property boundaries, and at some locations it is difficult to ascertain if shadow

encroaches into private property.

(ii) Request

28. Overshadowing mapping is updated to include property boundaries.

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6 Social and community impacts

6.1 Impacts on private recreation facilities and Crown land during construction and operation phases

(i) Reference

Technical Report I Social, includes mapping that depicts the effects of compulsory acquisition on key community facilities and some of these facilities are considered further in the Sport and Recreation Options Preliminary Assessment (Appendix F). Technical Report I refers to private school and recreation properties that may be affected but some of these do not appear to be the subject of detailed mapping or discussion in the Options Assessment.

(ii) Request

29. The Proponent provide a copy of detailed mapping for all private schools and private recreation facilities and State and Commonwealth Crown land including Simpson Barracks that are likely to be affected by the Project, documenting areas that would be impacted by construction and operational effects.

30. Details of options explored with private schools, private recreation facilities and Crown land managers to mitigate potential impacts of the Project.

6.2 Changes to the provision of public open space

(i) Reference

Table 9-4, page 167 of Technical Report I lists land acquisition and temporary occupation of open space and recreational areas and facilities.

(ii) Request

31. Mapping of key works proposed within all open space assets that would be affected by operational impacts of 20 per cent or more by area consistent with the level of detail expected for a reference design, to the extent that this has not already been provided for each relevant facility.

32. An analysis of the approach taken within the EES to assess qualitative shifts in the provision of public open space, beyond a differential in square meterage. For example, how does the quality and projected use of land bridges compare with other existing, more conventional open space facilities that may have their full use restricted by the Project? How does this respond to planning policy?

6.3 Local business flow on impacts

(i) Reference

The impact on local business is described in Technical Report F Business.

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(ii) Request

33. Provide advice on the presence and extent of social and community impact arising from the loss of access to local businesses; for example in terms of increasing vehicle trips away from the local area, reduction in social and community engagements around commercial transactions and general impact to social cohesion.

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7 Business impacts

7.1 Economic impacts

(i) Reference

Business impacts on local areas are considered in Technical Report F Business. It is not clear if local and regional economic impacts have been determined or calculated.

(ii) Request

34. Advise on whether the economic impacts on local and regional areas have been considered (for example loss to the local economy of local businesses, dislocation, expenditure leakage, employment availability in increased employment travel times) and if so, what quantum is expected.

7.2 Bulleen Industrial Precinct

(i) Reference

The importance of the Bulleen Industrial Precinct is acknowledged in the EES in detail in Technical Report F (eg cl 21.08 in Table 8-8) both for its existing use and development and since there is little opportunity for further development of such land in Manningham.

On page 34 of Technical Report F (Table 5-5) the EES advises:

NELP is actively working with the Council (Manningham) to progress its strategic assessment of available sites across the municipality and the potential for rezoning or redevelopment.

(ii) Request

35. An update on the status of these discussions and how they should be weighted and regarded by the IAC in terms of impact mitigation.

7.3 Jobs deficit

(i) Reference

Technical Reference F (page 37) already identifies that the municipalities (except Yarra City Council) in the Project area have a jobs deficit; people have to travel for work.

(ii) Request

36. Articulate the impact of the Project on the existing jobs deficit in the area coming from the loss or relocation of businesses; and is it a significant impact?

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8 Noise and vibration

8.1 Construction noise – night time criteria

(i) Reference

Technical Appendix C Surface noise and vibration, Section 4.8.2 Construction Criteria states the following:

“…The EPA Publication 480 requirement of ‘noise should not be above background noise levels inside any adjacent residence between 10 pm and 7 am’ is somewhat impractical as it depends on numerous factors such as the acoustic performance of each building construction, the level of internally generated noise, and the level and character of the external ambient noise environment. For the practical purposes of assessment, the EPA night-time criterion has been defined to be an external level of construction noise that does not exceed the average night-time background noise level.”

Table F-12 in Appendix F of Technical Appendix C provides a summary of the average background noise levels and an average noise level for particular catchment areas.

Appendix E of Technical Appendix C provides baseline noise monitoring data for selected sites in the Project area.

(ii) Request

37. Confirmation that noise from night time construction works (other than unavoidable works) is intended to meet the EPA 1254 requirement of inaudibility in a habitable room of a dwelling at any time within the night period

38. Clarification of the background noise level to be used for quantitative predictions to achieve the above requirement. This clarification is required as the use of the catchment area average provides a higher background level than the use of the measured average background for some dwellings. The use of the catchment area average background (and in some case the use of the dwelling average background) rather than an hourly background noise level may mean that construction noise will be audible at the quietest time of the night between 1-3am.

8.2 Construction noise at night - predictions

(i) Reference

Technical Appendix C Surface Noise and vibration, Section 8 Construction Impact Assessment provides details of the number of dwellings where the night time NMLs are likely to be exceeded.

(ii) Request

39. Confirmation as to whether the night time works assessed in Section 8 include any activities that would not be considered as “unavoidable works”.

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8.3 Construction vibration

(i) Reference

Section 4.2 of Technical Appendix D Tunnel Vibration describes criteria used for evaluating vibration effects on human comfort and provides Vibration Dose Values (VDV) for human comfort in varying types of buildings in Table 3.

Section 4.2 (page 20) states the following:

“…However the conversion between dosage and vibration level expressed in a velocity domain is affected by multiple factors and equivalent values should be confirmed through a comparison between the assumed key parameters and actual field observations.”

EPR NV8 states that VDV may be converted to Peak Particle Velocities (PPV) within a noise and vibration management plan.

(ii) Request

40. Indicative PPV values that correspond to the VDV shown in Table 4.3 and EPR NV8.

41. Confirmation that this methodology must be adopted rather than “may” be adopted as stated in the EPRs.

8.4 Operational noise – barrier design

(i) Reference

Appendix I of Technical Appendix C provides the indicative barrier design to meet the traffic noise objectives for the design year.

There are some areas where barriers are adjacent to open space and provide sufficient attenuation to maintain the existing amenity of these parks.

(ii) Request

42. Confirmation as to whether the indicative barrier design is considered as the minimum requirement for barrier heights and whether these heights would be included in the EPR.

8.5 Operational noise – Plenty River Bridge

(i) Reference

Section 9.5.1.5 of Technical Appendix C states that 4 metre high barriers on the Plenty River bridge provide acoustic benefit to dwellings on the southern side but then indicates that this bridge is outside the Project scope of works.

The IAC notes that the bridge is within the designated Project areas and the 4 metre high barriers have been included in the noise contour maps (Appendix J).

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(ii) Request

43. Confirmation as to whether the 4 metre high bridge barriers are included in the reference design.

8.6 Operational noise – flood walls

(i) Reference

Section 9.5.3.6 of Technical Appendix C states that traffic noise at the Carey Grammar oval, Marcellin College ovals and Trinity Grammar School Sporting Complex is likely to increase by up to 5 dBA but that proposed flood walls are likely to provide acoustic benefit and sufficient mitigation.

(ii) Request

44. Confirmation as to whether it is intended to design the flood walls to provide noise mitigation for these school grounds.

8.7 Operational noise – fixed infrastructure noise limits

(i) Reference

Section 10.5 of Technical Appendix C provides the SEPP N-1 limits for fixed infrastructure. Tables 10.9, 10.0 and 10.12 provide the zoning levels, background noise levels and calculated SEPP N-1 limits.

(ii) Request

45. Confirmation as to whether the background noise levels shown in the table are the corrected or uncorrected levels (Note 1 provides details of the correction for façade reflection and future background noise reduction).

46. Confirmation that the calculated noise limits are correct.

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9 Ecology

9.1 Native Vegetation removal

(i) Reference

Technical Appendix Q Ecology, (page iv) states in reference to Studley Park Gums “NELP has committed to undertaking further field surveys to better understand the prevalence of Studley Park Gums at Simpson Barracks and to estimate the number of individuals potentially impacted by the Project“.

(ii) Request

47. Has the further work been undertaken in regard to Studley Park Gums at Simpson Barracks?

48. Confirmation that the offset strategy includes native vegetation values assessed to be removed on Commonwealth land (page ix, Technical Appendix Q Ecology)?

(iii) Reference

A number of submissions mention the 300 year old River Red Gum located on Bridge Street on the corner of Manningham Road, Bulleen. Technical Appendix K Historical Heritage refers to the heritage controls for this tree at section 8.2.2 (page 121). It is not clear whether Technical Appendix Q Ecology assessed this tree.

(iv) Request

49. Has the River Red Gum been assessed for its ecological value?

50. Has the Proponent undertaken a thorough review of feasible alternatives that would alleviate the requirement to remove this 300 year old tree as it is unclear that this has been undertaken in the EES?

51. It would assist the IAC if the Proponent could point out the tree identification number of the River Red Gum located on the corner of Bridge Street and Manningham Road, Bulleen (known as the Caltex Tree) in Technical Appendix G Arboriculture to obtain an appreciation of its arboriculture value.

(v) Reference

Technical Appendix Q Ecology (page viii) states the Proponent is currently investigating potential recipient sites for Matted Flax-lily within the City of Whittlesea, City of Banyule, City of Darebin and/or in the eastern section of Simpson Barracks as part of the proposed Matted Flax-lily relocation plan.

(vi) Request

52. Has this feasibility work been advanced (i.e investigating potential recipient sites for Matted Flax-lily) and what are the outcomes?

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(vii) Reference

EES Main document volume 1 (page 4-11) refers to ‘planned effects’ and states the Project ‘would result in some planned events, being events with outcomes that are certain to occur (ie planned impacts such as land acquisition), as distinct from risk events where the chance of the event occurring, and its consequence is uncertain’. Technical Appendix Q Ecology (page viii) states ‘Planned risks include those that involve direct and indirect loss of vegetation and habitat...These risks are expected to result in the largest impacts of the project, with the total direct vegetation loss...expected to include up to 52.109 hectares of native vegetation....’. Further on page (viii) it states ‘none of the risk pathways relating to ecology are considered to be high risk’.

(viii) Request

53. Clarification as to why removal of native vegetation is considered ‘planned’ rather than for example ‘high’ risk when the EPRs (FF2, FF4) provide opportunities to further minimise impacts including removal of native vegetation which may suggest the impact is not certain?

9.2 Fauna

(i) Reference

Technical Appendix Q Ecology.

(ii) Request

54. Has the impact assessment for aquatic and terrestrial fauna considered the changes to Koonung Creek (diversion of 600 metres and the piping of approximately one kilometre) on such species known to occur in this creek?

(iii) Reference

Submission 46.

(iv) Request

55. Clarification of what works will occur on the south side of the Eastern Freeway adjacent to the Flying Fox Camp site in Yarra Bend Park and what mitigation will be put in place.

9.3 Native Vegetation offsets

(i) Reference

Technical Appendix Q Ecology, Appendix L. The EES states that the Proponent is currently consulting with DELWP and accredited offset brokers regarding offset requirements and the availability of offsets.

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(ii) Request

56. An update from the Proponent and/or Department of Environment, Land, Water and Planning (DELWP) on whether offsets for the removal of native vegetation (approximately 52 hectares) can be achieved and any proposed strategies for the Proponent to achieve the offset requirements prior to construction.

57. Clarification from the Proponent and/or DELWP regarding the statement made by the City of Banyule, Boroondara and Whitehorse Councils (submission 716 paragraph 2.93) that an existing native vegetation offset is to be removed for the Project and any implications for that removal.

58. Warringal Parklands and Banyule Flats are identified as being of state significance in their extent and quality and for their ability to support birdlife. Under the DELWP Guidelines they also represent areas of native vegetation (Technical Appendix Q Ecology page 137). Are these wetland areas included in the calculation of native vegetation loss, i.e. part of the 52 hectares of loss?

59. Are there any further obligations of offsets for the Project due to the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) Public Environment Report (PER) assessment?

9.4 Other projects

(i) Reference

EES Main report s1.2.1 states that the “Project would also support a range of complementary projects…These would be subject to separate approvals where applicable”.

(ii) Request

60. Clarification that these ‘other projects’ within the Project boundary such as the Bulleen Road sewer realignment have not been included in the impact assessment for the Project, including any potential native vegetation removal that may be required.

61. Clarification that any native vegetation to be removed within the ‘project boundary - minor works’ (for example Map Book sheet 7 of 42 showing the rail line) have been calculated in the native vegetation assessment for the Project.

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10 Arboriculture

10.1 Tree Canopy Replacement Plan

(i) Reference

Technical Appendix G Arboriculture page 56 states “While construction of widened and new road infrastructure limits replanting opportunities within the immediate project boundary (risk AR04), a hierarchical tree canopy replacement program could realistically achieve canopy replacement within the broader urban area...”. A number of submissions also raised the issue of the location for replanting for the trees being planted to replace the ones being removed as part of the Project.

Technical Appendix H Landscape and Visual assessment included numerous landscape treatment section plans and photomontages depicting new plantings next to noise walls for example as the treatment/mitigation.

(ii) Request

62. Clarification of whether replacement canopy trees will be located in the areas (where possible) that the impacts are to occur or any other progress of the Tree Canopy Replacement Plan (EPR AR3).

(iii) Reference

Technical Appendix G Arboriculture page 38 and 39 references this precinct as having an ESO2, ESO3 and SLO2 affecting it. The ESO2 ‘seeks to protect sites of biological significance which comprise some of the most intact and significant areas of indigenous vegetation in the City of Manningham...’, page 38.

(iv) Request

63. How are these overlays considered in the assessment of the values of these trees?

10.2 Cumulative Impacts

(i) Reference

Technical Appendix G Arboriculture page 59.

(ii) Request

64. Provide the IAC with a clearer understanding of the cumulative impacts of the three major Projects cited in the EES (Melbourne Metro Rail, West Gate Tunnel Project and NELP) on the removal of canopy tree cover in Melbourne’s urban forest. For example the three Projects remove X per cent of Melbourne’s urban forest tree canopy.

65. Provide the IAC with some indication of how long it will take to replace the loss of medium to large trees.

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11 Surface Water

11.1 Water regime

(i) Reference

EES Main report page 24-35 states that the existing flooding regime of Banyule Creek would be significantly altered.

(ii) Request

66. Clarification of what a ‘significantly altered regime’ would mean in terms of hydrological and ecological impact to the Banyule Creek.

(iii) Reference

Melbourne Water submission (Submission 800, page 10) states: ‘The Project is likely to have an impact on the groundwater levels at the Billabong and this has the potential to impact on the ability to achieve a watering regime that is close to the natural watering cycle of Bolin Bolin Billabong. At this stage, the impact of the Project on the Billabong is not well understood...’.

(iv) Request

67. Clarification of what the impacts from the Project are (if any) on the water regime and any potential impacts on the aquatic and terrestrial habitats associated with the potential water regime changes to the Bolin Bolin Billabong.

(v) Reference

Technical Appendix P Surface Water; City of Banyule, Boroondara and Whitehorse Council submission 716.

(vi) Request

68. The IAC seeks further information/understanding from the Proponent regarding the

potential downstream impacts (if any) from the Project due to

piping/undergrounding various sections of creeks and waterways; changes to water

regimes; and removal of vegetation (native and amenity plantings) from the Project.

11.2 Water Quality

(i) Reference

Submissions and Technical Appendix P Surface Water.

(ii) Request

69. A more thorough evaluation of the potential impacts of an increase of 700,000 square metres of additional paved area on water quality and catchment and ecological values of the surrounding waterways should be provided.

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12 Historical and Aboriginal cultural heritage

12.1 Aboriginal cultural heritage

(i) Reference

Technical Report L (Aboriginal Cultural Heritage), page 18 explains that a Cultural Heritage Management Plan (CHMP) is being prepared in parallel with the EES process. This would be implemented by proposed EPR AH1.

(ii) Request

70. Details of the extent of progress of the CHMP and what future steps and timing are likely to be involved.

71. Details of the location, timing and outcomes of further subsurface testing and whether this is likely to influence the content of Technical Report L or related expert witness reports for the Proponent, specifically, the impact assessment component.

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13 Project Delivery Framework

13.1 Environmental management framework

(i) Reference

EES Main report volume 4 Chapter 27 Environmental Management framework. A number of

large government projects have now been assessed, approved and implemented following

this EMF regime (Desalination project, Melbourne Metro Rail, West Gate Tunnel to name a

few).

(ii) Request

72. A summary from the Proponent, with advice from DELWP as to how learnings from project delivery of other recent major Projects such as Melbourne Metro and the West Gate Tunnel Project have been used to develop and improve this delivery framework; in particular, the effectiveness of the Environmental Performance Requirements.

73. Are there any suggestions for improvements to this framework?

13.2 Structure and wording of Environmental Performance Requirements

(i) Reference

EES Main report volume 4 Chapter 27 Environmental Management framework. Environment

Performance Requirements (EPRs) are a mix of quantitative (eg AQ3 where standards must

be met) and qualitative (eg B2 ‘to the extent practicable’ and ‘endeavour to’).

(ii) Request

74. Can the Proponent please provide an explanation of how qualitative EPRs will be effectively implemented and:

a) Who is responsible for approving performance against qualitative ‘standards’.

b) What decision making framework/criteria will be used for approvals against qualitative standards.

c) What mitigation is proposed when a qualitative ‘standard’ cannot be met? For example using B2, if the ‘extent practicable’ results in no or little minimisation of business disruption, what mitigation is available to business owners/customers?

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Appendix A: Air Emissions and Air Quality Information Request

Technical Advice – Air Emissions and Air Quality

Reference number: CW1

Advice from: Catherine Wilson

Date of response: 17 June 2019

Identification of critical issues

Issue Reference

• Identification of the air quality legislation and guidance framework to assess air quality impacts during construction and operation.

EES Chapter 10, Technical Report B, Air Quality, Chapter 4.

• Identification of the sensitive receptors in the vicinity of NEL. Technical Report B, Air Quality Section 6.2 and Appendix C.

• Methodology used to estimate background air quality and model the NEL’s ambient air quality impacts during the operation.

EES Chapter 10, Technical Report B, Air Quality, Chapters 5, 6, 9, 10 & 11, WAA Chapter 10.

• NELs air quality impacts during operation on the receiving environment including sensitive receptors and surface roads.

EES Chapter 10, Technical Report B, Air Quality, Chapters 10, 11 &12, WAA Chapter 10.

• Sensitivity testing of air quality impacts. Technical Report B, Air Quality, Chapters 10 & WAA 10.

• In tunnel air quality during operations. Technical Report B, Air Quality, Chapter 10, Section 10.4.2 & WAA pages 41 and 98 of 410.

• Identification of NEL construction impacts on ambient air quality. Technical Report B, Air Quality, Chapter 8 & WAA 10.3.

• Identification and assessment of air quality risks during construction and during operation of NEL with proposed mitigation measures and environmental performance criteria.

EES Chapter 10, Technical Report B, Air Quality, Chapter 7 & Appendix A.

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• Best Practice in tunnel ventilation pollution control technology and the use of acoustic barriers and vegetative barriers to reduce vehicle emission impacts.

Technical Report B, Air Quality, Chapter 13 & WAA Section 10.4.

• Pre and post air quality monitoring of local air quality, in-tunnel air quality and ventilation stack emissions.

EES Chapter 10, Technical Report B, Air Quality, Appendix A &

WAA section 10.5.

Requests for information from the proponent

Information required Reference

• Details about the modelling undertaken of In-tunnel air quality and the modelling results.

WAA page 98 of 410.

• Details on visibility criteria specified for in- tunnel air quality. Technical Report B, Air Quality, Chapter 10, Section 10.4.2 & WAA pages 41 of 410.

• Details on the treatment of emissions from vehicles using the ramps (including those ramps with signals), under worse case traffic conditions, and how this has been incorporated into the modelling and assessment.

Technical Report B Air Quality, Chapters 9 & 10.

• Details about how the operation of the emergency exhaust has been considered in the air quality assessment.

WAA Figure 2.

• Details on the selection and exclusion of pollutants for surface roads and combined impacts modelling (based discussions with EPA).

Technical Report B Air Quality, Section 5.4.

• The EES states that modelling was undertaken for particles, NO2, CO and a range of air toxics. Explain why the modelling results have not been presented for CO and, with the exception of benzene, the air toxics.

EES Chapter 10, page 33 & Technical Report B Air Quality, Appendix C.

Note: In the Technical Report B, Air Quality, Chapter 11, Surface Road Impacts, Section 11.6, pages 156- 235, the Analysis of Significant Changes sections incorrectly refers to mg/m3, the unit should be µg/m3.

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Appendix B: Urban Design Information Request

Technical Advice – Urban Design

Reference number: SA1

Advice from: Stephen Axford FAIA


This advice is in response to request:

From clause 3 of initiation letter of 14 May 2019:

Provide a brief written statement to the IAC (a template will be provided) by noon on Monday 17 June 2019 which contains, in dot point form, relevant to your expertise and within the scope of the IAC’s Terms of Reference:

a. Identification of critical issues; and b. Requests for information from the Proponent, including points of

clarification arising from your review of the EES material, which are necessary to inform your expert opinion on the key issues that you have identified.

Requests for information should be made in respect of key issues only and should be referable to the IAC’s Terms of Reference.

Identification of critical issues and requests for information from the proponent

The following issues and information to be requested are drawn from my review of the Environment Effects statement (EES) Chapter 7; Appendix H Landscape and visual and the Urban Design Strategy.

Indigenous and historic cultural values

Issue Reference

• The involvement of the Wurundjeri Woi-wurrung Cultural Heritage Aboriginal Corporation (the Corporation) in every phase of the project is an important opportunity to demonstrate respect for Indigenous culture and to express this culture at a variety of scales.

• I expect that there will be opportunities from the small to the large scale.

• At the small scale, opportunities such as interpretive signage along walking paths and in connections to important cultural assets could help educate the broader community about indigenous history, cultural artefacts and use of local flora and fauna.

• At a larger scale, there could be opportunities such as through artistic decoration of infrastructure elements such as sound walls or structural pillars to express indigenous culture.

• I believe the involvement of the Corporation is an important opportunity to develop a unique image and status for the road project at both national and international levels.

• A key issue then is to ensure that steps are in place to ensure the outcomes are respectful, authentic and communicate meaningful messages.

• I would expect that the Corporation will require technical support to enable them to engage with each phase of the project, including availability of well resolved visualisations, sketches, plans and elevations

Urban Design Strategy Foreword; 1.4 Urban Design Vision; Key Direction 3 page 17

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once detailed opportunities are identified. They may need specialist support to access technical data such as GIS mapping unless such information is to be translated into easily accessed formats.

• I would expect the Urban Design Strategy to identify opportunities for engagement at various scales, particularly where the road passes through areas of high significance to the Wurundjeri Woi-wurrung.

• I would expect the Urban Design Strategy to identify relevant examples where indigenous culture has been successfully incorporated into major infrastructure projects (possibly drawing upon examples from New Zealand or North America and Canada) where possible and to establish at least broad guidelines to maximise the opportunity for success.

Information requested Reference

• What technical support will be available to the Wurundjeri Woi-wurrung Cultural Heritage Aboriginal Corporation?

• What will be the involvement of the Wurundjeri Woi-wurrung Cultural Heritage Aboriginal Corporation with the Urban Design Advisory Panel?

• Have any specific opportunities or locations for expressing indigenous culture been identified?

• What are the details of the curatorial process described in Key Direction 3?

• Are there national or international examples that could assist in identifying opportunities for expressing indigenous and local community sense of place?

Detailed opportunities by location

Issue Reference • The Urban Design Strategy is positioned as a performance based brief

rather than a detailed design response. This is a recognised approach given the intention not to direct tenderers to specific solutions, and to encourage creativity and innovation.

• However, I believe it will be difficult for some stakeholders to engage with the Urban Design Strategy without at least an identification of the most likely opportunities and challenges.

• For example, the maps shown in the Urban Design Strategy do not indicate the proposed location of existing sound walls to be extended nor new sound walls to be proposed, but discusses these generally. To understand the likely opportunities and challenges a reader must cross reference to the Appendix H Technical Report – Landscape and visual. This does show the location of sound walls which are extensive.

• Appendix H also shows a limited number of photo-montage visualisations and identifies where the potential visual impact will be high.

• I believe there should at least be cross-references to Appendix H and preferably the maps in the Urban Design Strategy should be updated to indicate the proposed location of sound walls and other potentially visually intrusive infrastructure such as shared pathway bridges and associated access ramps.

• I believe it would assist the Urban Design Strategy if it were to engage with the visualisations provided within Appendix H and identify where there are opportunities to apply the urban design principles to achieve the project goals. Also see the comments on the Portal designs below.

Urban Design Strategy, Section 3, Corridor wide opportunities, pages 24-26-

and

place specific requirements in the following pages

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• Are the locations visualised within Appendix H considered sufficiently extensive by the Urban Design Advisory Panel?

• How were the viewpoints for the photo-montages selected?

• Should the Urban Design Strategy provide guidance to bidders about the extent of visual communication that will be required in order to communicate project proposals to the stakeholders and the broader community?

Urban Design Vision

Issue Reference

• The Urban Design vision is summarised on Page 4 of the Urban Design Strategy.

• This is quite reasonably set at a very high level and does not go to detail.

• However, I feel it does not communicate a design vision for the project, but rather focuses almost entirely on the defining urban design, explaining its importance and describing the role.

• I recognise that the overall vision is described in Section 3.2 Key design directions.

Urban Design Strategy, page 4


• Would it assist readers if the physical vision described in Section 3.2 was summarised within a paragraph or two within the summary at Page 4?

Role of visualisation

Issue Reference

• Given the performance-based approach of the Urban Design Strategy, it is likely that final design proposals will vary in many ways from the reference design. This could make engagement by stakeholders with the design proposals difficult.

• I have found that with the limited range of photo-montages and diagrams available, it is challenging to develop an overall picture of the physical impacts and opportunities of the project.

• I recognise that submission requirements for the tender phase may be dealt with elsewhere. However, I believe the Urban Design Strategy would be strengthened if it provided guidelines on the subject to ensure effective communication with stakeholders and the broader community.

Urban Design Strategy, General


• Has the Urban Design Advisory Panel considered how design proposals can effectively be communicated especially to non-technical stakeholders? Should the Urban Design Strategy address how proposals should be communicated, such as the use of 3D modelling, photo-montages, animations, real-time modelling, and guidance as to where different techniques may be appropriate?

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Opportunities to apply Detailed requirements and benchmarks

Issue Reference

• The Urban Design Strategy provides a series of examples of detailed design elements (both national and international) in Section 7.

• These examples are generally not linked to any specific locations or opportunities. There is limited analysis of the examples to explain the aspects of each that are considered relevant.

• I believe it would assist to provide a discussion of where examples might apply. For example, could a land bridge form be applied to the proposed pedestrian links at locations such as Watsonia (Map R4 page 38, Urban Design Strategy) and Macorna Street (Map R1, page 32 Urban Design Strategy).

• Land bridges are also an example of how location could be encouraged in principle. For example, they could be seen as particularly valuable where a crossing connects to existing open space networks, thus improving the amenity of the whole system. In this way they could be seen to off-set some of the amenity lost by the expanded footprint of the road corridor.

Urban Design Strategy, Section 7


• Can further analysis of the detailed requirements and benchmarks be provided to assist understanding the aspects that are most relevant and where they might apply?

Public Art

Issue Reference

• The involvement of public artwork and appropriately qualified artists is a recognised technique to develop meaningful design details, finishes and landmark elements.

• Public Art can be integrated with structural or landscape design, ideally in a collaborative process or could be curated standing artworks intended to mark a place or location.

Urban Design Strategy, e.g. page 105


• Could the examples that show integrated art be identified and discussed (for example, Figure 83 page 105, Urban Design Strategy)?

• Could examples of individual artwork as placemaking at various scales be provided?

• Could a commentary on public art be included in the Urban Design Strategy to address items such as appropriate collaborative processes, selection of artists, artists rights, etc?

Portal Designs

Issue Reference

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• The two portals and associated vent stacks serving the tunnel connection to the Eastern Freeway and the connection to the expanded Greensborough Road are locations where effective urban design will be critical.

• The opportunity is discussed in general in the Urban Design Strategy, despite the locations being known to a high degree of certainty.

• The visual impacts of the proposed ventilation shafts are analysed in Appendix H but it appears not the portals or road interchanges associated with them.

Urban Design Strategy, Page 88


• Has the visual impact of the road portals been assessed? Could the overall footprints of the proposed portals in the reference design be included in the Urban Design Strategy?

Consultation

Issue Reference

• Chapter 7 of the EES refers to the extensive consultation that has informed the Urban Design Strategy.

• I am concerned that the value of this consultation could be limited by the restricted range of plans and visualisations available.

EES, Chapter 7


• Did participants in stakeholder consultation have access to the photo-montage views provided in Appendix H or any other visual material from the reference design?

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Appendix C: Ground Movement, Groundwater and Contamination and Soil Information Requests

Technical Advice – Ground Movement

Reference number: CB1A

Advice from: Craig Barker





a. Identification of critical issues; and b. Requests for information from the Proponent, including points of




Issue Reference (by page number in Technical Report M Folder)

• Range of volume loss from Tunnel Boring Machine (TBM) tunnelling has been assumed to range from between 0.4 % to 0.8 %: o Lower Plenty Road to Banyule Flats (‘Reach 4’): 0.8 % volume loss; o Banyule Flats to Manningham Road Interchange (‘Reach 5’): 0.4 to 0.8

% volume loss; and o Avon Street to Rocklea Road (‘Reach 7’): 0.3 % volume loss.

• Primarily most of the tunnelling is targeted through Silurian siltstone (fractured soft rock).

• As a comparative guide, for the Melbourne Metropolitan Rail Tunnel (MMRT) project, estimated volume losses through Melbourne Formation siltstone (at generally similar depths of tunnelling) were as follows: o TBM in siltstone rock: 0.5 % volume loss. o Sequential Excavation Method (SEM) in siltstone rock : 0.5 % volume

loss. o Use of TBM with closed face in soft ground: 1 % volume loss.

The values as assumed seem comparable. The NELP EES suggests a volume loss using SEM of 0.3 % which may prove optimistic.

Page 27: Section 5.7.1

Aspects related to ground movement of liquefaction (often associated with soft ground and earthquake events), vibration settlements, thermal effects and reactive soil movements (expansive clays) all considered of lesser importance –

Page 21: Section 5.6.1

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not considered. • Reach 5: Banyule Homestead (Influence on Siltstone Bedding – Stability)

o One instance of slope stability assessed; o In-situ rock bedding at this location dipping into the slope at ~ 65°, with

planar jointing approximately orthogonal to bedding (dipping out of slope) forming a blocky rock mass.

o There is evidence the current slope angle is controlled by this jointing. o The observed slope face angle of 26° to 36° closely matches the jointing

that dips out of the face at ~25° to 30°.

o TBM influence was estimated from finite element analysis (FEA) to cause minimal strain impact under this area – not considered further.

Page 54, Section 8.2.5

• There are some issues with prediction inaccuracy and applicability of using the Gaussian Bell Curve Method (which has been applied for this Project to estimate both total settlements, the extent of settlement troughs and change in slope on ground) for the estimation of tunnelling settlement trough predictions when dealing with a fractured rock mass, particularly when movements and strains are more associated with discrete fractures or defects in the rock and you start to move away from ‘soft rock’ behaviour: o Volume of the settlement trough is taken as equal to the volume loss

associated with tunnelling; o Volume loss is defined as a ratio of the over-excavated material to the

theoretical excavation volume; o Trough width is taken as equivalent to one standard deviation of the

Gaussian Bell Curve shape for its positioning.

Its proposed with more detailed assessment to confirm the general risk assessment approach for ground movement prediction by conducting more detailed and complex numerical methods that better simulate the behaviour of fractures and faults/features in the rock. This future check modelling and monitoring of rock behaviour under stress change will need to be built into a suitable EPR.


• Anisotropy effects of fractured rock systems and its importance: Conductivity of the ground (fractured siltstone rock) to groundwater flow is often substantially higher in the horizontal direction than the vertical. In rock, groundwater will often preferentially flow through an interconnected fracture network leading to a widespread zone of influence that may prove difficult to predict (you can get a wider zone of influence than was expected).

Page 22

• The order of 5 mm is proposed as a predicted vertical movement was used as the threshold for further appraisal of buildings and structures.

Page 22

• First stage risk assessment process – if a ‘slight’ risk to damage or distress (buildings/aboveground infrastructure) or greater by: o Predicted 5 mm vertical total movement from the Project influence; o Predicted strain at 1:500 (0.2 %).

• For underground utilities slightly different appraisal system adopted based on relative stiffness of service to surrounding soil: o Consider is there is any ‘rigid’ pipe – joint rotation or joint pull-out risk;

or

o Are there critical bending and extensional strains expected on the

Page 22

Section 5.7.4

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service line if its acting more like a flexible member (allowable strains depend on the material type).

• Second stage risk assessment to buildings and structures considered: o Specifics of geometry and relative stiffness of the structure; o Elastic modelling (beam movement adopted on Gaussian subgrade

shape); o Tensile strain pushes out to ‘moderate’ risk as strain approaches 0.15 %

to 0.3 %, then onto Detailed Evaluation (Stage 3).

Any structures of heritage value or community significance went straight to Stage 2 Risk Appraisal.

Page 23

• Concept of ‘Confinement – Convergence Method (CCM)’ o For rock, ground movement effects may be determined using the CCM,

where the tunnelling excavation process is simulated in 2D by a ‘relaxation factor’ and the movements cease when the lining is ‘installed’ after an appropriate degree of rock stress relaxation has occurred;

o The degree of stress relaxation of the rock which can occur is the key parameter (depends largely on the delay required to install the final tunnel lining and to make meaningful contact with the rock and final liner (to take up load);

o The rock may also yield to some extent in this stress relaxation process, so estimating rock yield potential becomes important (use of the Geological Strength Index (GSI) after Hoek, 1999;

o Volume loss (VL) for a circular tunnel can be estimated based on the predicted radial convergence around the tunnel and tunnel starting diameter (VL % = 4 * (δ/D)*100).

Page 25

• With respect of retaining walls, given the stated typical types for the reference design, most of these walls are expected to have a high relative stiffness where variation in ground condition and style of anchoring or propping of the excavation then become the major influencers to ground movements. o For stiffer ground conditions (such as is the general case for this

Project) use the trough estimation process by Clough & O’Rourke (1990).

o Case of Bulleen Road North Portal – stiff clay alluvium involved (softer soil) – use of GABA empirical curve fitting method 2017 or CIRIA C760 report methods considered more appropriate.

Page 27

Page 28

• All residential properties will be subject to a condition survey (pre-works) which lie within the estimated zone of influence from the trough modelling.

Table 9-2

• Key assumption (considered to be conservative) when dealing with alluvial deposits – Yarra River (i.e. relatively unconsolidated) – thickness of the soft/compressible layer to be taken as the total estimated thickness of the alluvium layer, less its starting unsaturated thickness from the top of this alluvium layer.

Page 28

• Siltstone/sandstone inter-bedded is interpreted to be folded on a general north to north east trending axis, associated with faulting and some intruded dyke zones.

Page 32

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o Project drilling has shown that beneath the Yarra Valley sediments there are a several potentially thick, high persistent faults, comprising crushed rock, sand and clay derived from the ‘parent’ rock, which are interpreted to behave as a soft soil material (a reasonable assumption);

o No dykes (as yet) have been encountered with vertical drilling methods – their occurrence could complicate tunnelling methods;

o The siltstones are deeply weathered– often down to 30 m depth, but weathering and general rock strength can also be variable;

• Around Manningham Road, there are a series of interpreted east to west draining ancient alluvial ‘paleo-channels’, which were subsequently stranded by the continued down-cutting of the Yarra River. The in-fill material here is believed to be Brighton Group marine sandy clays. To the south of Manningham Road (near Ilma Court) there are also in-filled drainage channels (Miocene alluvium) close to the proposed tunnelling ‘crown’.

Page 32

• The alluvial aquifer and the underlying siltstone bedrock aquifer are expected to be inter-connected. Seasonal variability in groundwater contribution to the surface water features (creeks, rivers, wetlands) is not well understood where a groundwater monitoring program is underway.

Page 34

A total of 11 geotechnical/geological study ‘reaches’ have been nominated:

o Reach 1: M80 Ring Road to Watsonia Station (Surface Works) o Silurian bedrock ranging from highly weathered to fresh to slightly

weathered from 15 to 25 m bgs (thin residual clay soils overly); o Minimal ground movements are anticipated, just minor movements

from additional placed embankment loads with lane widening. o A former in-filled quarry site near M80 intersection with

Greensborough Highway (solid inert waste up to 7 m deep) placed around mid-1950’s;

o AK Lines Oval – former landfill site from 1950’s; and o Also part of the Maroondah Aqueduct / Dandenong West

Melbourne Ring Water Supply Main - (concrete lined steel pipeline, 2.16 m in diameter – built 1970s) under M80 Western Ring Road, near Chappell Drive (6 to 19 lanes with new build) – deemed a ‘slight risk’ for Preliminary Analysis (16 mm maximum vertical settlement predicted, where this pipeline should act in a flexible manner) – recommendation to model and monitor as further action. Currently EPRs: GM1/GM2 recommended.

o Reach 2: Watsonia Rail Station to Northern Portal (Open Cut) o Cut depth up to 13 m bgs. o Silurian bedrock ranging from extremely weathered to highly

weathered; o Nearby Hurstbridge Metro Rail Line (not considered at risk from

ground movement); o Passes through western boundary of Simpson Barracks (some

impacts to L-shaped Building (not at risk, but recommended to apply EPRs: GM1/GM2 and GM3) and related Outbuilding (deemed ‘slight risk’) due to proximity of proposed cutting and its construction type – masonry wall) - recommended to apply EPRs:

Page 35

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GM1/GM2 and GM3; o Elder Street Gas Main (near Watsonia Station), runs along

Greensborough Road – 450 mm diameter, high pressure, steel welded circular pipe set at 10 m bgs within a 60 mm diameter outer conduit, subject to 4 m deep trench excavation at Greensborough Road (18 mm maximum vertical settlement predicted). Recommendation to model and monitor applies for this: Current recommendation for EPRs: GM1/GM2.

o Reach 3: Northern Portal to Lower Plenty Road (Cut & Cover) o Cut depth up to 35 m bgs. o Silurian bedrock ranging from extremely weathered to highly

weathered; o Steeply dipping fault zone expected just north of Lower Plenty

Road; o Combined settlement effects from deep cut and cover and TBM

may prove significant (bedding plane strains and fault line); o Former small landfill at Borlase Reserve 1966-1972, fill to 5 m bgs; o > 5 mm vertical settlement zone can extend laterally from cut by up

to 45 m (most influence near northern portal). o Greensborough Road water main (0.6 m diameter concrete lined

welded steel pipe) at west side of excavation (max vertical pipe displacement of 7 mm, with no change in ground slope) – not at risk.

o Lower Plenty Road Water Main (required re-alignment of 3 x concrete lined steel welded pipes (largest diameter is 1.35 m) – up to 76 mm of maximum vertical movement at this area. Requires Stage 2 Assessment (not yet done). Current EPR recommendation: GM1/GM2 and GM4 (pipeline re-alignment).

o Reach 4: Lower Plenty Road to Banyule Flats (TBM) o Tunnelling depth up to 42 m bgs. o Silurian bedrock ranging from slightly weathered to fresh with

minor dykes and significant fault zones; o Zone of > 5 mm vertical influence extends out some 25 m from

tunnels centreline. o Many one to two storey residential premises above warranted

Stage 2 Assessment: ▪ ‘Lower Plenty Road 2 (LPR2)’: Low rise residential near

Lower Plenty Road Portal cut and cover & TBM interface (between 5 to 29 mm vertical structural movement – ‘slight’ damage rating – deploy EPRs: GM1/GM2/GM3);

▪ ‘Banyule Creek 1 (BC1)’: Low rise across TBM alignment includes Viewbank Aged Care (all around 10 to 12 mm vertical movement) - ‘negligible’ damage rating – but still deploy EPRs: GM1/GM2/GM3);

▪ ‘Banyule Creek 2 (BC2)’: Low rise residential cross TBM alignment, including a Kindergarten (all around 10 to 12 mm vertical movement) - ‘negligible’ damage rating – but still deploy EPRs: GM1/GM2/GM3);

o Banyule Creek Sewer passes above TBM alignment at Banyule Flats

/38

Pages 38/39

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(up to 36 mm max vertical movement predicted with northbound tunnel) – warranted a Stage 2 Assessment.

▪ 0.45 m diameter vitreous clay pipe with shallow founding (stiff/brittle construction) – pipe joint rotations and pull-out governs;

▪ Model predictions indicated that further assessment not warranted, but enact EPRs: GM1 and GM2.

o Reach 5: Banyule Flats – Banksia Park – The Yarra (TBM)

o TBMs to be driven from a temporary portal on Banksia Street; o MRI constructed by cut & cover; o Mainly through slightly weathered to fresh siltstone for TBM; o There are several faults present through this area; o Manningham Road – there is the possibility that the tunnel crown

could intersect the base of ancient alluvial sediments (requirement for open to closed face TBM operation could exacerbate settlements).

o Zone of > 5 mm vertical zone of influence (ZOI) extends out some 38 m from tunnels centreline.

o Sensitive receptors above include: ▪ Banyule Homestead (outside ZOI); ▪ Banyule Flats North Slope (siltstone with 65O rock bedding

dip into the slope – warranted FEA review – only minor impact predicted);

▪ Banyule Swamp (7 Ha pond near TBM alignment – up to 35 mm vertical movement predicted – requires Stage 2 Assessment on associated water outfall structure sensitivity) – Currently GM1/GM2/GM3/GM4 all recommended – links across to Ecological Risk Study;

▪ Heide Museum of Modern Art & related sculpture park (‘Crescent House’ (18 mm max vertical movement) and ‘Theoretical Matter’ (24 mm max vertical movement) – main sculptures at risk – both these went to Stage 2 Assessment). Outcome deploy EPRs: GM1/GM2/GM3 for both sculptures.

▪ ‘Helmet’ large steel framed sculpture (up to 93 mm max vertical movement) – significant risk – some mention of a possible relocation early in the Chapter. Detailed assessment recommendation to deploy EPRs: GM1/GM2/GM3/GM4 following conduct of detailed structural analysis around ground movement predictions.

▪ Journey’s End (outside the ZOI); ▪ House near Bridge Street (near Journey’s End) – requires

Stage 2 Assessment.

o Reach 6: Manningham Road Interchange - Bulleen (Cut & Cover) o Large interchange ‘box’ to be constructed to 22 m bgs; o Pleistocene alluvials (Manningham Road) over siltstone which is

moderately weathered to extremely weathered; o Soft soils at Yarra Flats; o ‘MRI Slope Stability – where Yarra River is within 35 m of closest cut

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and cover activity. This slope has a maximum slope angle of 20O and is 10 m high. Slope stability analysis suggested not an issue – EPR recommendation GM1 applies.

o MRI retention structures expected to result in groundwater mounding (up to 6 m height increase to east of MRI box structure) – could result in some increased ground heave with reactive clays (old alluvium) – EPR recommendation GM1 applies.

o Reach 7: Avon Street to Rockleigh Road (SEM Tunnels) o Extremely weathered to highly weathered siltstone; o Ima Court has infilled paleochannels – mining change difficulty; o Maximum depth is 35 m bgs (tunnels 14 m x 12.5 m cross sectional

area each); o Includes cavern mining for road ramps near Golden Way; o Initial ‘drained’ tunnel construction followed by full tanking via

secondary liner; o ZOI up to 25 m from tunnel centreline; o Bulleen Road Residential areas within; o Bulleen Residential (‘BR’) (associated with MRI and SEM tunnelling)

Initial ZOI estimates: up to 26 mm maximum vertical settlement – required Stage 2 Assessment – includes: St Andrews Crescent, Golden Way, Claremont Ave, Rocklea Road, Killara Mews – mainly low rise residential, but SEM tunnelling results in between 7 to 26 mm maximum vertical settlement (critical locations are on the east and west side of the tunnel alignment). Damage rating expectation is ‘very slight’ – but enact EPRs: GM1/GM2/GM3.

o Former in-filled clay brick quarry area (Yarraleen Reserve) deep foundations expected to support residents here – deemed not at risk.

o Reach 8: Rockleigh Road to Bulleen Oval (Cut & Cover) o Associated groundwater drawdowns are expected to cause more

noticeable settlements here; o Deep layer of alluvium (to 21 m bgs) – soft to stiff clays and loose to

medium dense sands; o Significant faulting across slightly weathered to fresh siltstone; o Bulleen Road West Sewer (will need to be relocated via trenching

and pipe-jacking) – under what contract controls (Early Works – will EPRs still apply – currently EPRs: GM1/GM2/GM3 required)?

o Generally, up to 80 m ZOI from alignment centreline, but Bulleen Road Sewer increases this zone out to 110 m;

o Bullen Oval has significant deposits of uncontrolled fill (with asbestos risk mixed in waste);

o Bolin Bolin Billabong and nearby Integrated Water Facility – not considered at risk.

o Veneto Club, 191 Bulleen Road, built 1960’s – 3-storey concrete framed building with large, front box-girder arched portico and nearby plinth sculpture – taken to Stage 2 Assessment due to community concerns (not considered at risk from analysis). Recommendation – deploy GM1/GM2/GM3.

o Trinity Grammar School & Marcelin College Playing Ovals – minor

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drainage risk perhaps from some minor settlement.

o Reach 9: Eastern Freeway – Bulleen Road to Freeway (Surface Works) o Traffic lane widening and viaduct ramp; o Swim Centre and Tennis Centre land to be acquired; o Alluvium over highly weathered siltstone; o Required relocation of East Yarra Sewer Main – planned shaft

excavations for pipe jacking. o Only sensitive receptor is Bulleen Road West Sewer (2.25 m

diameter reinforced concrete pipe asset of Melbourne Water): ▪ Sits on alluvial clay; ▪ Subject to increased loads from the surface ramps and nearby

settlement influence from the shat excavation to relocate the East Yarra Sewer Main (maximum ground displacement 27 mm vertical) – taken to Stage 2 Assessment;

▪ Assessment looked at rigid pipe model (joint rotations and pull-out risk) – outcome not at risk but deploy GW1/GM2/GM3.

o Reach 10: Eastern Freeway – West (Surface Works)

o Undisturbed alluvium transitions from underlying siltstone to Newer Volcanics basalt to west;

o Former landfill (Camberwell Municipal Landfill – 1966 to 1977) – Musca Reserve & Freeway Golf;

o Not many sensitive receptors here.

o Reach 11: Eastern Freeway – East (Surface Works) o Significant road widening is required; o Mainly siltstone geology, with minor alluvium at Koonung Creek

crossing under Eastern Freeway; o Former landfill near intersection of Doncaster Road & Freeway –

Banyule North (1970’s in-filled); o Koonung Creek Conduit (existing ‘BEBO arch’ construction – not to

be further assessed as it will be treated with a concrete cover slab to structurally bridge over) – but deploy EPRs: GM1/GM2/GM3 on arch as fail-safe;

o Kenneth Street Water Main, Bulleen (1.1 m diameter steel pipeline – owned by Melbourne Water) sits atop clay alluvium up to 18 m deep with a 3.2 m ground cover to works – additional assessment showed no significant risk (only to 7 mm maximum vertical settlement).

Page 44

Pages 44/45

o Alternative Design Options Being Considered From Reference Design

Some discussed alternative design options in the EES:

o Manningham Road Interchange: Involves lowering the alignment of the TBM tunnels and the MRI by a further 2 m:

o Will result in a 3 m increase in the predicted settlement trough width;

o Maximum vertical settlements may increase by a further 3 mm; and o Structural damage ratings should not alter to surrounding

Page 75, Section 8.5

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receptors.

o Northern TBM Launch: o Will not cause a large change to the excavated tunnel geometry.

o Banksia Park TBM Retrieval Shafts:

o Alternative proposes 2 x separate TBM retrieval shafts on the north side of Bridge Street at Banksia Park;

o These shafts are 25 m wide x 50 m long and will be between 30 to 34 m bgs;

o The shafts will be constructed before the MRI construction; o Designers considered consolidation effects with soft soils at this

area from dewatering operations with these shafts (dewatering to occur 9 months before MRI dewatering commences);

o Additional impact from this action takes up one additional residence within the ZOI (on Bridge Street) – assigned a ‘slight’ risk ranking.

o Subsequent Stage 2 Assessment on this timber framed/weatherboard residence showed up a ‘negligible’ risk ranking, but it was recommended to deploy EPRs: GM1/GM2/GM3.

o Appendix D1 – Numerical Validation - Trough Width Parameter Discussion

The outlined tunnel design approach when it comes to predicting settlement and strain response if to deploy the Gaussian Bell-Curve Model (empirical curve fitting method). For non-homogeneous rock (such as what is potentially the case for this project with the siltstones), ground movements may be driven more by specific displacements along discrete bedding, fracture lines or joint lines. If tunnel monitoring shows up a discrepancy such as this type of movement the approach to counter this is to add further tunnelling support at such areas to limit these more-specific movements.

Trough width parameter (i) is a ratio of the tunnel depth – generally (i) was taken as 0.5 * Zo (for clay type soils), where Zo is the depth to the tunnel crown from the ground surface. For sands the EES suggests a value of (i) of 0.3 *Zo and for fractured rocks the EES suggests a value of (i) of 0.7 *Zo.

When these suggested numbers are compared to what was submitted in the MMRT – EES they compare favourably – see MMRT suggestions below:

Soil (All Types) (i) = 0.4 *Zo

Rock (i) = 0.6 *Zo

Alluvials (i) = 0.3 *Zo

Appendix D1

o Reference to Influence of regional Rock Stress Fields on Tunnelling & Ground Movements

One key issue is that the EES information seems lacking around the investigation and understanding of regional rock stress fields for the Project.

o The current design information seems to be assuming that horizontal and vertical stresses are in a hydrostatic type of equilibrium / balance.

o There is no obvious calling off or reporting of the measurements of stress ratios estimated in the field for these basement rocks

Section 2.2 – Appendix D1

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(siltstones) from the Geotechnical Investigations.

o Varying stress ratio and rock bedding anisotropy will have an influence of predicted ground movement zones and magnitude of settlement/strain.

o Preliminary Comment Across Environmental Performance Requirements (EPRs) Generally these EPRs seem quite sound and well-constructed.

o ‘GM1’ relates to the Site Conceptual Model and understanding of the ground movement mechanism (Assessment);

o ‘GM2’ relates to measuring a ground movement ‘baseline’ and then conducting careful monitoring checks across the Project life into Operation (Plan for Movement Monitoring);

o ‘GM3’ relates to establishing a baseline of building and infrastructure asset condition before construction, followed post-construction surveys and consultation with the stakeholders of these assets;

o ‘GM4’ relates to rectifying damage to buildings and infrastructure. Its noted that the Councils are currently not listed in GM4 (where some assets may be listed as a heritage item by the Council).

General policing of the Ground Movement EPRs is a key question – where is the presence of an independent Auditor in the process, which may occur before any independent mediation is called up as a requirement?

Section 9 – Page 79


Information required Reference (by page number in Technical Report M Folder)

• Provide some more definition around the concept of ‘good workmanship’ in the context of this tunnel build.

Page 2, Section 1.2

• Have any ‘small utilities’ thus far been identified by NELP that warrant a particular assessment?

Page 16, Section 5.2

• Provide the output evidence of the FEA related to the Banyule Homestead slope stability appraisal.


• Confirm the value for ‘Symax’ for risk screening as part of the Stage 1 Risk Assessment. Is it 5 mm as indicated on Page 22, or 10 mm as indicated on Figure 5-3, Page 26.


• Provide some further detail on how the structural appraisal of the Banyule Creek Sewer was assessed.

Page 39/54

• In regard to the Helmet sculpture (Banksia Park) owned by Manningham Council, the early part of the EES Chapter suggests this sculpture will be relocated, yet the Detailed Assessment at the end of the Chapter provides EPR recommendations GM1/GM2/GM3/GM4 – please confirm the agreed plans for this.

Section 8.4.1

• The ‘Out Building’ at the Simpson Barracks appear to have a mis-match in its Page 1, Appendix A and

of 58

Information required Reference (by page number in Technical Report M Folder)

assigned risk ranking, when the conclusions of the Chapter are read (indicated as beyond a slight risk).

Page 81

• Provide the actual Geotechnical Investigation Reports for the Project Not Formally Referenced

• Provide the forming calculations that were the basis for Table 1 Appendix D1 – Numerical Validation

Technical Advice – Groundwater

Reference number: CB1B






c. Identification of critical issues; and d. Requests for information from the Proponent, including points of




Issue Reference (by page number in Technical Report N Folder 11-13)

• Groundwater pumping is listed here as groundwater control method, yet within Technical Appendix O, NELP indicate that groundwater extraction will not be occurring for the tunnel construction or operation (mis-match of intent shown).

• Why is groundwater re-injection not mentioned here as a potential control (particularly applicable for alluvial sediments on the Yarra Flood Plain, possibly not so suitable as an approach for bedrock siltstones/sandstones).

Page 36

• Undrained structures may only prove cost-effective provided the produced seepage waters can be suitably disposed of under a permitted action into the long-term (this is now a regular problem in Melbourne with the Water Authorities). In some Councils and for some Water Authorities a fully tanked permanent solution is required.

Page 37 – 2nd Paragraph

• During construction, the ground support method near the portals may Page 37 – Bullet 2

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partially limit groundwater seepage inflows (such as shotcrete liners or grouting).

• For TBM tunnels a Haack Rating of 3 is proposed (which is the same class of water proofing as has been proposed for the Melbourne Metropolitan Rail Tunnel (MMRT) from its EES. For areas of proposed open cut or cut and cover construction (associated with the MMRT East and West portals and associated decline structures) and station boxes at: Domain, Parkville and Arden, excavations at these areas were to be tanked to a final Haack rating of 2. For NELP all areas of open cut, cut and cover and cross passages are only to be rated Haack 3 (please justify why the difference in water proofing rating class applies between the projects on comparison).

• Haack 2 is often specified for road tunnels, where the risk of frost forming may prove to be a road traffic hazard. Has this risk been properly considered in specifying a Haack rating of 3 for the entire tunnel?

Page 38 – Table 5-4

• For those non-TBM sections of tunnels which are planned to be mined by cavern construction methods using staged road header mining or other similar methods (smaller cross-passages, control rooms and service ‘adits’), it is likely that there will be such an amount of short-term groundwater drawdown at these areas as they are constructed, that these areas should be assumed as being fully drained (that is, groundwater is drawn-down to an effective steady-state water table surface that is matched to the near base of the excavation). Has reference design numerical modelling assumed this is the case (NELP know where these cross passages will be spaced along the tunnel)?

• Once construction of these smaller cross/void structures is completed, they are then planned to be suitably tanked to a proposed Haack rating of 3, so that with tunnel operation, groundwater levels would tend to recover close to pre-construction groundwater levels. The MMRT project (in its EES), proposed to construct similar cross passages to Haack rating of 2. Please justify why these structures should not be more effectively water-proofed to a Haack rating of 2 (where people may be required to pass through these cross passages for servicing and emergency evacuation).


• Mention is made of using mitigation measures such as grouting of the tunnel line (either from within the tunnel or from the ground surface). The Committee should seek further information on how this grouting is to be achieved; including what magnitude of investigations have been, or will be undertaken to determine: o Where grouting or ground freezing may be necessary, to mitigate

against unacceptable groundwater inflows, and the types of grouts which might be used;

o The expected application pressures which will be acceptable to achieve effective grout placement and groundwater inflow mitigation;

o The identification of conditions which might give rise to undesirable grout excursions and plans to monitor/detect against this event from occurring; and

o The limiting grout pressures which may apply as a consequence of surrounding sensitive buildings and infrastructure.


• Provide some further, more detailed explanation of the rationale and Page 45

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methodology for making the lead-in 650 m run of ramp down to the North Portal (Lower Plenty Road) as a permanently-drained structure. Why has this section been designed not to be tanked as per the remaining portions of the tunnel?

• It would appear (from a lack of discussion on the topic) that there has been no attempt at modelling (i.e. a sensitivity analysis) of the effects of significant anisotropy of the bedrock/basement (Silurian siltstone) in plan-direction (applies to both north and south portions of the project).

• Whilst the modelling of a significant difference between assumed horizontal hydraulic conductivity vs vertical hydraulic conductivity has been modelled (order of 1,000 times less for vertical conductivity). The bedrock typically has a significant and consistent folding/faulting pattern when regional geology is considered. o Such plan anisotropy is expected to have a significant effect on the

distribution of aquifer drawdown on each side of the Project, where for planning purposes for structures/buildings/services, such potential effects should be accounted for; and

o Rock layering and bedding will also in a similar manner influence the values of assumed conductivity between horizontal and vertical (no attempt to understand these aspects has been put through the current groundwater model it would seem).

• There is a lack of discussion of plans for improved / targeted drilling to expose presently unobserved geological conditions, steep dipping fracture zones and structures likely to create anisotropic depressurisation patterns for the bedrock aquifer. Such plans need to work in with surface-based observations of geology and key features (surface inspections, rock and joint set/fault mapping, uses of historical geological plans, published reports, etc).

Table 6-3 (Page 63)

General

• For packer testing of the drill holes: Can NELP provide a summary of packer testing derived hydraulic conductivity for the siltstone rock vs depth to look for trends with depth to weathered zones – is there any noticeable trend in the data.

• For both rising head or falling head (‘slug’) tests and packer tests can NELP provide some form of reporting where the nearby influence of siltstone rock faulting or jointing can be compared – That is: o Do inferred conductivity measurements increase both in plan proximity

to and depth proximity to faults or defects in the rock;

o Does conductivity increase with depth as you move into fresher (less weathered) siltstone rock?

Page 27


• If the relocation of major utilities (such as the Bulleen Road Sewer) are to occur prior to major tunnelling works, how can the Committee be assured that suitable EPRs would be applied to this dewatering action if the said works are completed under an ‘Early Works’ separate contract where such EPRs may not apply (such a Contractual situation occurred with the MMRT – critical service re-locations were conducted outside of the main Contract).

• Will the impacts from micro-tunnelling actions (such as what is proposed for the Bulleen Road Sewer) be modelled with future stages?


• Please provide further information and justification as to why the influence of smaller creeks within the Project Area and Study Zone (such as Banyule

Pages 41 to 43

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Creek, Salt Creek) have not been modelled (even as a recharge zone if nothing else in the higher reaches)?

• Please provide the ‘LeapFrog’ Electronic Geological Model, so that the Hydrogeological SCM can be suitably viewed.


• Please provide further justification and proving as to why the Yarra Flood Plain Alluvium should only be modelled as one uniform layer.

Page 44

• Calibrating the model with respect to monitored standing groundwater levels (SWLs) across the EES-based network of 69 monitoring bores has only been conducted to the April 2018 Groundwater Monitoring Event (GME): o The April 2018 GME is related to a significant climate ‘dry’ period’

(drought level); o Due to the lack of Study Area historical water bore information,

calibration of the EES numerical model to higher rainfall periods and higher observed groundwater levels has not been undertaken (attempts to do so have involved historical water bores in other types of rock geology, located at significant distances from the Study Area;

o A comparison of predicted SWLs from the EES model to the April 2018 GME data often shows a SWL difference of up to between 3 m to 5 m (which seems significant) – The current model seems to be struggling to accurately model spatially on drawdowns through the geology;

o Calibration of the model in terms of transient observed response has only been attempted across the three locations of constant rate extraction aquifer pumping tests (all in siltstone) located at: ▪ Borlase Reserve, Yallambie – siltstone geology (See Table 2 –

Numerical Modelling Report); ▪ Kim Close; Bulleen - siltstone geology (See Table 2 – Numerical

Modelling Report); and ▪ Bulleen – siltstone geology (See Table 2 – Numerical Modelling

Report).

Pumping tests have all been targeting the siltstone response, where response through the lower alluvium is not well known.

o There is a current / significant calibration gap with respect to suitable transient (time) related response for the current numerical model; and

o Higher regional groundwater levels will result in higher groundwater seepage rates to the tunnels and greater predicted drawdown areas – yet there is no suitable model calibration to a higher regional groundwater scenario.

Page 45 – top of page

• Please provide through ‘NEL’ prefix bore-log and well construction records for the following aquifer pumping test locations; o Borlase Reserve: BH031, BH056, MB03, BH159, BH043, BH107, BH106,

BH057, BH100 and BH085; o Kim Close: BH059, MB02, BH158, BH140, BH137; and o Bulleen: BH128-D, BH128-S, MB01

• Within the EES, there is no summary site plan (with detail) for each of these above performed aquifer pump tests, which shows the accurate locations of monitoring response wells to the extraction well. The current Figure 5.3 (Page 28) is insufficient in its detail, to make any suitable independent

Page 45 - top of page & Appendix C – Page 31

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appraisal of these Aquifer pumping tests. • Use of the majority of geotechnical investigation bores that were completed

with a monitoring well construction typically involves a deeper well screen setting, which would tend to: o Provide some significant amount of bias with EC/TDS observations

across the alignment as being of higher value in the fractured siltstones and of lesser value as a groundwater resource; and

o Provide some bias to lessened groundwater contamination presence from urban activity.

Page 48 - Section 5.8

• The Committee should seek up-dated information on the results of further investigations related to groundwater and the Site Conceptual Model (SCM), especially to identify: o Stated risk assessment and or risk mitigation definition objectives which

they seek to resolve (lead-in discussion on key data-gaps and uncertainties);

o The consistency of the new investigation results with the conceptual hydrogeological model as portrayed in the EES for the reference design;

o Any new or unexpected conditions which have emerged from the additional investigations; and

o The degree to which the new results support and verify the findings of the hydrological modelling of the areas of influence likely to arise during Project construction.

• Describe the outcomes and key discussion points between NELP and Water Authority: Yarra Valley Water (in terms of sewer disposal options across both construction and operation)?

• Is TDS of the groundwater seen by YVW as a major issue for sewer disposal?


Page 110

• The MMRT project encountered significant effects from siltstone rock anisotropy (i.e. St Pauls aquifer pumping test) as reported in its EES. Whilst NELP have cross-referred to MMRT when quoting likely ranges of hydraulic conductivity for siltstone / Paleozoic basement, such effects as encountered with the Melbourne Formation siltstones have not been addressed in any detail in the NELP EES.

Page 63

• Banyule Creek is mainly ephemeral (but is a GDE), flowing after rainfall events. In its lower reaches nearer the alluvial floodplain, drawdowns are predicted near this feature under operation conditions (it has some deep pools present). o What about during the tunnel construction process (cut and cover and

then TBM past the Northern Portal, heading south) – what is the anticipated drawdown response and impact on this creek across construction.

o Figure 8-5 explain the apparent control effect associated with Banyule Creek on contour plot Northern Alignment Late 2024 95th percentile.

o Care needs to be made when comparing predicted water level response back to future uncertain Climate Change effects wrt drawdowns – what is the effect now?

Page 50 & 116

• In respect of fault zones, provide more detail on the background information searching and site inspections that went into efforts to locate and interpret

Page 56 / 57

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these typically north-south trending features:

o Drysdale Street / Lower Plenty Road o Bridge Street / Yarra River o Banksia Street through to Manningham Road o Bulleen Park

• Figures 6-1 and 6-2 do not show where the interpreted fault zones are in any detail.

• Lumping in the Tertiary Sands (Brighton Group) together with more recent Quaternary Alluvium for the numerical groundwater model is not recommended. It will depend on what depth you are into for the Brighton Group Sands, but the top portion often has up to 50 % clay present, and as you get deeper into the underlying ‘Grey Sands’ of the Brighton Group, values for hydraulic conductivity start to approach that which you expect with a more recent alluvial material – suggest these parameters be separated and assessed separately for the future model.

Page 63 & Table 6-3

• For the Palaeozoic basement rocks (siltstone) in terms of the potential range for hydraulic conductivity, it’s estimated at over six orders of magnitude from the EES. There has now been quite a lot of upgraded groundwater response monitoring and modelling from large scale pumping with the MMRT – why cannot this response information and upgraded information for Melbourne Formation siltstone be brought immediately into the NELP project through state government cooperation (between MMRA and NELP)? More accurate and useful information to make far better models is out there – it just needs to be accessed.

Table 6-3, Page 63

• Reporting a statistical mean (in this case both average and geometric mean) for measured groundwater pH is not of sound scientific practice. Best to talk about the ranges and if required, point to median result.

Table 6-9, Page 70

• In the past at areas close to this one (i.e. Kew in siltstones) commercial businesses have been documented from published Audit Reports to actually extract groundwater from the Silurian siltstones across summer periods when rainwater supplies run low (such as a Car Wash business). These pumping operations in the siltstones have been clearly documented as having a large impact of both groundwater drawdowns in the Silurian and the direction of groundwater flow. The fourth paragraph from the top of page – last sentence is incorrect – it can have and has proven to have a very large effect on the groundwater.


• The numerical model should have catered for the impact of Melbourne Water’s Yarra Main East (i.e. permeable trench backfill), where it sits below the estimated upper aquifer system (in siltstone) – follows along the alignment of the Yarra River and Plenty River, but sits within Bulleen Road (mainly siltstone geology) and Templestowe Road (perhaps alluvium more so along Templestowe Road, so possibly not modelling here is more justified) .

Page 79

• There has to be closer and more relevant/reliable groundwater standing water level information for the Silurian siltstones around the Melbourne area than what has been used when looking at long term response and drought response in Section 6.10.7.

Page 82

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o Kinglake bore is over 30 kms away – different catchment and climate; and

o Tarneit nested bore group is within a totally different geology (Quaternary basalt)

Even MMRT has some decent groundwater monitoring data for the Silurian across the last three years (which has been a significant drought), if nothing else. I suspect NELP have not really had a good look for a long-term Silurian water observation bore in the network (even if in the surrounding 5 to 10 km range).

Figure 6-11 clearly shows how sensitive the SWL response is for the siltstones (red) when compared to a basalt aquifer (black).

Page 83

• Figure 6-12: Legend colour scheme that discerns between ‘Not Known’ and ‘Commercial’ is a poor choice – how can you spot the difference visually? The presence of Parkland (Council) and private commercial water bores is expected to have a high influence, yet the information on this as per the EES is of poor quality.

Page 85

• Observed groundwater flows from the NELP aquifer pumping test for: o Borlase Reserve (0.5 L/sec) could suggest a reasonable groundwater

yield per hour to justify private extraction and use (1.8 kL per hour) where batching can be utilised (such as car washes, where TDS is not a sensitive driver); and

o Agreed that the other two pump tests produced quite low yields.

Page 86

• Private bores at: o Loyola College: WRK078524 drilled to 113 m bgs in 2015 (recent) – 125

mm diam water bore in siltstone; o WRK958500 – 25 m deep bore drilled in 2007 (Marcellin College Sports

Field).

These bores are within siltstone and are likely to have a significant effect on drawdown response. They need to be understood in terms of their physical setting and operation.

More generally, a detailed bore survey (both registered and unregistered (by letter drop, bore amnesty offer and door knock) is likely to yield better quality information on: o Water bore presence and groundwater yields; o Groundwater quality;

o Typical use.

• Section 6.16: There is still a limited understanding of the connectivity between both small creeks and major rivers (Yarra) and underlying groundwater, but for the general premise that groundwater feeds the lower reaches of the creeks and the Yarra.

Page 99

• Table 7-1: Residual risks as currently rated in this table seem too low for: o Risk GW02: Construction – seems too low given lack of quality data on

surrounding groundwater users in the region. o Risk GW04: Construction - Dislocation of delineated contaminated

groundwater plumes (there is also the risk of smearing existing contaminants vertically downwards, that can increase vapour risk levels

Page 104

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– see Contamination. o Risk GW05: Construction, based on current discussions and viewed

correspondence by the Reviewer with EPA, Melbourne Water and Yarra Valley Water this risk may be down-played for such a long duration construction project.

o Risk GW07: Operation – seems too low given lack of quality data on surrounding groundwater users in the region.

o Risk GW09: Operation - Dislocation of delineated contaminated groundwater plumes (there is also the risk of smearing existing contaminants vertically downwards, that can increase vapour risk levels – see Contamination.

o Risk GW11: Operation, based on current discussions and viewed correspondence by the Reviewer with EPA, Melbourne Water and Yarra Valley Water this risk may be down-played.

Page 110

• 3rd paragraph from top – this means nothing across the construction program, when the largest amount of surrounding aquifer drawdown is expected – This is a mis-leading statement. MMRT experience is currently showing this is a major problem in the Melbourne Formation siltstones.

Page 122

• We are dealing with a fractured rock aquifer system, which often has preferred flow pathways that are hard to identify, predict and model. The normal sorts of hydrogeology ‘rules’ and theories, that tend to be wheeled out when looking at a homogeneous / uniform aquifer system do not apply in this case. None of these statements are correct given the site geology and they are mis-leading giving the reader a false sense of security that groundwater contamination migration and movement won’t be an issue – its more likely that it will be from recent experience with MMRT.

Page 122 to 124

Table 8.5

Figure 8.9

• The use of aquifer re-injection methods within Silurian siltstone is likely to be problematic, particularly if the use of anti-clogging chemicals is proposed: o Well injection yields are limited; o Lack of Project area to go to and lack of space; o Anisotropy – hard to control;

o Permitting for such action takes a lot of time through EPA

Page 109

• Provide some further information across the licensing process with Southern Rural Water and proposed groundwater seepage harvesting across the construction stage.

Pages 18, 151

• Suggested use of chemical grouting of rock and soil as a mitigation measure for groundwater connectivity to protect the overlying ecosystems is probably just as damaging as the dewatering effects its trying to cure.

Page 118

• Relating to potential for ASS impact to groundwater from aquifer drawdown with cut and cover construction, there is still the risk of significant aquifer drawdown close to the tunnel wall, where up to a 5 m to 15 m drawdown can occur from modelling predictions with construction. Exposed acid forming material may come into contact with seepage water and become acid in such a situation.

Page 119

• Sustainability of some of the suggested mitigation strategies to protect deep pools at the Bolin Bolin Billabong. Suggested potential reduction in the

Page 151

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contributing base flow is up to 5.5 % construction, moving back to 3 % long term (Operations) – from modelling predictions.

• Banyule Swamp and Banyule Billabong - some small amount of leakage also predicted to this surface water feature.

: Numerical Model Report

• Long-term groundwater monitoring beyond the two-year period post-construction is currently not proposed. This time period seems quite low given the tight geology (fractured rock) involved.

Page 126

• Section 8.6.2 – The rigour of this suggested Climate Change review would have to be questioned given the two bores that were examined for long term groundwater level response.

Page 155

• The Committee should seek information on how and how quickly any inadequacies in achieving the Environmental Performance Requirements (EPRs) could be implemented during the Construction Phase, should needs arise despite applying the mitigation measures set out in the EES.

• Is it appropriate to assign the Model a Class 1 to 2 status when it has not been suitably calibrated to a suitable set of transient (time response) data – i.e., to historically measured standing groundwater levels?

Hugh Middlemiss Peer Review

• Mr. Middlemiss does not offer any detailed opinion as to the suitability of the groundwater model, when it comes to understanding and predicting the effects of major structure and rock faulting – does he agree with their general approach as deployed, in that context?

Hugh Middlemiss Peer Review

o Preliminary Comment Across Environmental Performance Requirements (EPRs)

o ‘GW1’ relates to informing the design and Construct team about the Site Conceptual Model (Assessment):

▪ Continue to review and improve the numerical model for the Study Area;

▪ Further field investigation to better calibrate the model; ▪ Considers both changes to groundwater level and quality; ▪ Help to develop more promising mitigation strategies; and ▪ Matching the numerical groundwater model to actual

construction techniques to be used. o ‘GW2’ relates to Groundwater Monitoring:

▪ Pre-construction baseline and construction influence; ▪ Return calibration to the numerical groundwater model; ▪ Assessing adequacy of design and construction

performance; ▪ Covers groundwater levels, flows and water quality; ▪ Links in with EPR FF6 – GDE Monitoring and other

identified beneficial uses for groundwater; ▪ Confirms the suitability/effectiveness of applied mitigation

measures; ▪ Post construction monitoring for at least 2 years, or until

an acceptable groundwater restoration is confirmed; ▪ EPA actively involved.

o ‘GW3’ relates to Design & Construction Measures to Mitigate: ▪ Short and long-term groundwater seepage

Page 160, Section 9

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disposal/management; ▪ Important aspect of mobilising contaminated

groundwaters – a proven risk for this type of project; ▪ Impacts wrt ASS/PASS; ▪ Impacts to waterways and GDEs and terrestrial ecosystems

(trees); ▪ Subsidence impacts; ▪ Applies to all aspects of the alignment construction; ▪ Manage, minimise, mitigate (Waste Management

Hierarchy); ▪ Water Authority Agreements/Licences – an

important/current issue. o ‘GW4’ relates to Groundwater Management Plan (covers both

construction and operation – to 2 years in) ▪ Consult with EPA; ▪ Link with numerical groundwater model; ▪ Establish guidance on chemical and material usage –

construction materials; ▪ Establish suitable guidance in respect of Managed Aquifer

Recharge (MAR) - 0 chemical quality and hydraulic influences;

▪ Long term tunnel material compatibility with groundwater; ▪ Maintaining long-term drainage infrastructure to suitability

of use (control of anti-clogging chemicals); ▪ Measure for, appraise and treat intercepted contaminated

groundwaters (construction); ▪ Controls for remedial grouting with construction (or

operation fixes); ▪ Confirming the status of surrounding operational water

bores in the agreed Study Zone; ▪ Link in with Southern Rural Water.

o ‘GW5’ relates to Managing Groundwater Across Operation ▪ Manage/Monitor/Re-use on groundwater seepage inflows; ▪ Licences and Guidelines to apply ▪ Emergency response plan for unexpected groundwater

inflows. o There are also clear linkages across to the following other discipline

EPRs: ▪ Ground Movement ‘GM1’ – Assessment; ▪ Surface Waters:

• ‘SW2’: Spill Containment;

• ‘SW3’: Approvals for Wastewater Discharges; and

• ‘SW11: WSUD’ ▪ Contaminated Land:

• ‘CL1’: Spoil Management Plan;

• ‘CL2’: Impacts from ASS;

• ‘CL3’ Impacts from Odour;

• ‘CL4’ Impacts from vapour & Ground Gases;

• ‘CL5’ Managing Chemicals, Fuels & Hazardous Materials

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▪ Flora & Fauna:

• ‘FF6’: GDE Monitoring & Mitigation Planning; ▪ SCC4:

• ‘SCC4’: Minimise & manage waste (other than spoil)

General policing of the Groundwater EPRs is a key question – where is the presence for the requirement of an independent Environmental Auditor in the process to assess and police the requirements? (you cannot rely on EPA or other State Government groups to do these as the task is a large one)? There is also the aspect of making the final contracting Joint Venture to even work under the guidance of an independent Auditor – For other Major Victorian Projects it seems to be in place on the West Gate Tunnel Project, but the requirement seems to have failed to be established on the MMRT Project (even though specifically called up by those EPRs).


Information required Reference (by page number in Technical Report N Folder 11-13)

• Provide a summary table of all useful NELP groundwater monitoring bores across the Study Area and set out where well screen settings are in terms of: o Well depth o Screen length o Sand pack length o Typical geology in which the well screen is set

o Typical SWL in terms of both depth and Australian Height Datum (AHD).

Page 48

• Provide the bore log and well construct for NEL-BH062A (former Bulleen Drive-in)

Page 71

• Provide the bore log and other records for NEL-BH022 (Near Simpson Barracks)

Page 122

• Provide the bore log and other records for NEL-BH191 and NEL-BH024 (Watsonia Station Car-park)

Page 71

• Provide the bore log and well construction detail for NEL-BH137 (Greenaway Street)

Page 147

• Provide the bore log and other records for NEL-BH009 (Manningham Road) Page 71

• Provide the bore logs and other records for NEL-BH061, 061A and 061B. Relates to potential hydraulic connection between siltstone and overlying alluvial beds.

Page 93

• Table 6-15 – provide the actual depth to SWL and the matched AHD level for the SWL for each bore location on this table. Would make it much more useful. Its acknowledged that accurate survey may not have been available at the time of the EES write-up (but it should be now).

Page 94

• Provide the time-based records of SWL for NEL-BH128/128A and NEL-Page 94

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Information required Reference (by page number in Technical Report N Folder 11-13)

BH004/004A – Table 6-15 is currently of limited value for the reader to make any independent interpretations (show the raw SWL data plots – logger data once level corrected).

• Provide the bore logs & well data for NEL-BH078 and NEL-BH080 (Banyule Swamp/Billabong).

Page 97

• Provide borelogs & well data for Coffey locations: BH1 and BH2/B2 Page 99

• Table 8-2 and text below it on Page 111, tends to suggest that these four construction stages shown in Table 8-2 will be staggered in construction timing – if not, then predicted groundwater inflows will be significantly higher than this (possibly 620+255+330+105+30 = 1,340 m3 per day on maximum inflow estimates across the alignment. Provide further explanation that the peak inflow is only estimated at 620 m3 per day.

Page 111

• Explain how the various water treatment groups: o Stormwater run-off; o Vehicle run-off o Groundwater seepage

o will be collected and separated in the tunnel conceptually.

Page 110

• For the numerical groundwater model was any allowance made for cross passages and ancillary adits/passages?

• Numerical Model – provide further explanation across the use of Veronoi cell length and width of 5 m x 5 m for the diaphragm wall components of the model

Page 4: Numerical Model

• Numerical Model – Figure 6 looks to show some mesh discretisation related to fault presence – please explain the methodology if this is the case.


• Explain the acronym – ‘HSU’ (hydraulically specific unit?)? Page 8: Numerical Model

• Provide some further explanation of how you modelled for aquifer heterogeneity via the use of Pilot Points – perhaps show a print-out across the slices of how key parameters varied based on these pilot points.


• Provide some explanation to Figure 15, where there is a greater assigned hydraulic conductivity away from the main water courses (based on your model calibration). Intuitively this does not make a lot of sense – would you not expect a higher conductivity following the water courses?

Figure 15: Numerical Model

Technical Advice – Contamination and soil

Reference number: CB1C



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c. Identification of critical issues; and d. Requests for information from the Proponent, including points of




Issue Reference (by page number in Technical Report O - Folder)

• Report does not consider soil contamination that may be related to future building demolition (i.e., asbestos) or the removal of infrastructure (such as fuel storage underground Storage Tanks (USTs)) – These two contamination contributors are often resultant major risks upon being disturbed.

Page 7 – base of page

• Cross linkage to the EPA Publication – Guidance Contaminated Soil Management and Re-use on major Infrastructure Projects) associated with Major Projects such as this comes through very late in this EES Chapter and should form a major part of the leading guidance, not just mentioned in passing towards the end of the document. Its however strongly mentioned in the Spoil Management Strategy.

Start of Document and Page 82

• Looks like NELL may have not desk-top mapped occurrence of Environmental Audit Overlays (EAOs) across the Project Extent, which should have been a key part of contaminated land risk identification. They say they were looked at on Page 11 – but no references were talked about/no maps shown.

Page 11, 14/15

• It’s easy to research current Section 53X Environmental Audits that whilst having been initiated for lands along the Project corridor, have not yet been finished or published (this is easily done through the Auditor Group or directly as a request to EPA). This appears to not have been done – which for a Major Project is likely to have implications by disrupting these Audits – particularly in relation to groundwater investigations, groundwater interpretation and long-term monitoring plans for groundwater.

Page 15

• Initial site inspections have only been conducted generally across publicly accessible lands only.

Page 15

• Use of surface methane (CH4) emissions and emissions for CH4 in subsurface pits will not necessarily provide a reliable indicator of CH4 or other ground gas risk for former landfill or filled sites.

• LFG monitoring bores into the subsurface have not been installed to target any of the past landfilled sites thus far – a better indicator of LFG migration risk through the subsurface.

Page 15, Page 69

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• Table 5-3: Where both Caltex and Viva Energy have both determined to pass on any of their land contamination information, these two areas should have been more targeted for preliminary investigations as they pose a significantly higher risk from historical storage of petroleum hydrocarbons.

Page 21

• Table 5-3: Department of Defence should have also been approached for discussions / information on USTs and the storage of petroleum hydrocarbons.

Page 21

• Landfill Gas (H2S): American Conference of Governmental Industrial Hygienists (ACGIH) recommendation is for an eight-hour time weighted average (TWA) exposure limit concentration of 1 ppm and a 15-minute short-term exposure limit (STEL) of 5 ppm. In 1995, NIOSH updated and published the IDLH (Immediately Dangerous to Life or Health) value to 100 ppm. EES Report underplays this risk by only mentioning health impacts to human eye upon exposure.

Page 42

• The tetrachloroethene (PCE) or ‘perc’ concentrations at the two shallow soil samples (NEL-ENV BH025_0.3-0.4: 0.09 mg/kg and NEL-ENV BH025_1.0-1,1: 0.06 mg/kg) east of the dry cleaners (Watsonia) is probably going to show up a more serious issue at depth and into groundwater near the same location.

Page 57

• Table 6-14: With respect to agriculture and irrigation (i.e., the beneficial use termed ‘irrigation’) both as a current use and future use is more likely to be a real beneficial use than not – this risk is down-played.

Page 61

• When discussing groundwater characterisation (i.e., TDS, dissolved metalloids), best to split discussion across alluvial sediments and basement/bedrock/Silurian.

Page 64

• Use of term ‘Maintenance of Ecosystem’ is now an out-of-date term that was related to the former Victorian State Environment Planning Policy (SEPP) across both groundwater and waters. Should be using term protection to Water Dependent Ecosystems (WDEs).

Page 64

• The current uncertainty in the occurrences of dissolved PFAS within groundwater samples from the Bulleen Industrial area or Bulleen Drive-in (a ubiquitous contaminant in urban groundwater and may prove difficult to baseline/delineate the source). The Yarra River is receiving water from this groundwater. Bores NEL-BH062A and NEL-ENV-BH009. This groundwater is expected to be influenced by construction dewatering – has any estimate been made on the potential lateral or vertical spreading of this contaminant through the aquifers?

Page 65

• What do NELP mean by the last sentence in paragraph 1: ‘However this contamination is not predicted to migrate off-site.’ If you don’t know where its sourced from and how far it’s gone, how can this sentence apply?

Page 66

• Current soil and rock sampling frequency (from the Preliminary Assessment) don’t meet the guidance requirements for sample numbers (to material in-situ volumes) – this is to be expected at this stage of assessment.

Page 69

• Section 7.6.2: EPA’s Industrial Waste Resource Guidelines (IWRG) documentation provides clear guidance of where such Fill Material can be placed at off-site areas. Often for large volumes of Fill Material EPA may

Page 83

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often place a further constraint on the ability of a large soil volume to be moved to a location, based on its geologic characteristics (i.e. like for like, you cannot just place a siltstone derived soil across a primarily basalt derived geology).

• Aspect of EPA limitations across ‘construction rubble’ needs further description and calling off to the EPA Publication 1624 on what defines ‘Industrial Fill’, where the transport of this material may be precluded.

Page 85

• Definition of the ‘Project Boundary’ becomes all important with respect to the rules and guidance for contamination soils and acid soil or rock movements from what is defined as ‘site’. This Technical Appendix currently does not place a focus of how ‘site’ will be formally defined (presumably through some type of Planning Scheme Amendment process – as to what happens with other Major Projects).

Pages 82/83

• With the likely chance to be encountering asbestos fragments or fibre in fill where it’s to be excavated, a decent program of site ‘background’ asbestos fibre in air/dust monitoring needs to be established and then followed-up across the excavation program to protect both construction workers and the surrounding/nearby receptors (this EES Chapter is silent on this important aspect to protect human health where there is no cross-referencing off to the Air Quality Technical Report either)

Page 87

• Appendix F – Borelogs o Borelog NEL-ENV-BH005 incorrectly shows ‘Fill’ depth extent to 1 m on

the graphic log, where the descriptive material demonstrates it can most likely extend to 2 m.

Appendix F

NEL-ENV-

• No groundwater sampling and analysis for dissolved methane is a concern along the alignment and particularly targeting the former closed landfills and filled areas is a concern, given the level of laboratory analysis that has been undertaken on all other chemicals in groundwater it should have been done to assist as a basic landfill gas risk screening tool.

Appendix J – Table 5

• Preliminary Comment Across Environmental Performance Requirements (EPRs)

o ‘CL1’ relates to the Spoil Management Plan Implementation: ▪ Plan preparation to applicable guidance; ▪ Linked with EPA as a Major Project; ▪ Roles/responsibilities; ▪ Detailed site assessments to come for improved in-situ soil

classification; ▪ Storage and handling of spoil; ▪ ASS/PASS; ▪ Hazardous materials (asbestos/PFAS); ▪ Identifying targeted contaminated site areas & managing

risks – working to National Environment Protection Measures (NEPM);

▪ Mitigating impacts; ▪ Handling PIW’s as encountered; ▪ Reporting chain

CL1 should also be clearly setting out preferred trucking routes for off-site

Page 117, Section 10

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spoil disposal.

o ‘CL2’ relates to Minimising Acid Sulfate Materials: ▪ Characterise: Soil/Rocks/Oozes; ▪ Stockpiling rules; ▪ Re-use sites elsewhere identified; ▪ Pre-emptive measures to limit oxygen exposure to

materials; ▪ Calls off EPA Publication 655.1

CL2 should consider calling off and referencing the incoming new National Code for re-use of Acid Sulfate Soil/Rock.

o ‘CL3’ relates to Minimising Odour Impacts During Soil Management: ▪ Odour management methods called up; ▪ Key risk areas – i.e., old landfills in the alignment; ▪ Monitoring & Mitigation measures.

CL4 should also be considering and calling up baseline odour surveys of identified/suspected problem areas (before complaints start coming in from surrounding areas). Should also contain a method of logging, investigating and closing out formal complaints on odour as received.

o ‘CL4’ relates to Minimising Risks/Impacts From Vapour & Ground Gas Movement/Intrusion:

▪ Requirements for correct assessment and monitoring; ▪ Requirements for management measures – this can often

prove to be a real risk when dealing with petroleum hydrocarbons, chlorinated hydrocarbons of landfill gases;

▪ Assess risks across human health and the environment; ▪ Assess explosive risk and worker protection; ▪ Monitoring and mitigating.

o ‘CL5’ relates to Managing Chemicals, Fuels & Hazardous Materials:

▪ Construction Environmental Management Plan; ▪ Operational Environmental Management Plan; ▪ Code and Standard compliance for chemical storage and

use; ▪ Risk of spills or chemical losses; ▪ Emergency response.

o ‘CL6’ relates to Minimising Contamination Risks During Operation:

▪ Operational Environmental Management Plan; ▪ Controls across materials, odours, vapour or other gases; ▪ Controls on any hazardous materials previously

encountered by the Project that may still be in place (i.e., former landfills or asbestos);

▪ Mitigating future impacts from sub-surface works in identified contamination risk areas;

▪ Contingency measures in place (odour, vapour, ground gas, etc).

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o There are also linkages across to the following other discipline EPRs:

▪ Groundwater

• ‘GW2’ – Plans for Monitoring;

• ‘GW3’ – Tunnel & Trench Design & Construction (manage/mitigate);

• ‘GW4’ – Implement the groundwater Management Plan;

• ‘GW5’ – Managing groundwater into Operation.

Key question – How/Who is going to police all of the above without an independent Environmental Auditor? – EPA cannot be relied to conduct such a task – they are resource constrained.


Information required Reference (by page number in Technical Report – O Folder)

• Simpson Barracks – Bore log and well construction log for BH022 shows the well screen sampling section is set down at considerable depth (range 16 m to 22 m), yet this same bore is showing up significant dissolved phase petroleum hydrocarbon contamination.

Page 53

• Parks Vic land at Bulleen – provide bore log for BH003 / BH005. Page 53

• Bulleen Industrial / Commercial area – provide bore logs for BH004 / BH010. Page 53

• Bulleen Drive-in – provide bore logs for BH007 / BH019 / BH020 / BH021. Page 53

• Watsonia – dry cleaners: Provide bore log for NEL-ENV BH025. Page 57

• Watsonia Road – Watsonia: Borelogs for BH029 and BH030 have not suitably penetrated/defined the depth of filling.

Appendix F - Borelogs

• Provide summary details of discussions to-date with Yarra Valley Water with respect to potential sewer disposal of waters containing PFAS.

Page 65

• Provide summary details of discussions to-date with EPA and Melbourne Water with respect to potential surface water disposal of waters containing PFAS.

Page 65

• EPA Publication 1684 also indicates that for surface emission monitoring using a laser spectrometer (or similar low-level methane in air detector), for a ‘final cap situation, no single surface based reading should exceed 200 ppm (as well as the mean value not exceeding 100 ppm as indicated in the EES.

Page 70

• For the former landfills, Musca Street Reserve – Balwyn Nth, Freeway Golf – Balwyn Nth and suspected filled site at corner of Doncaster Road and Eastern Freeway – Balwyn Nth, were all not check tested for surface LFG emissions (lack of site access permissions).

Page 69/70

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Information required Reference (by page number in Technical Report – O Folder)

• Bulleen Oval – one subsurface (electrical service) pit gave a methane reading at 16,000 ppm (or 1.6 %, which is starting to get up to a explosive risk level of 5 % v/v). Preferred methane pathways from the subsurface such as this need to be better appraised, together with the risk for lateral migration through the subsurface for LFG.

Page 70

• Spoil Assessment – IWRG Classing – They are still deficient of soil and rock sampling numbers in-situ, for IWRG classing and classing to EPA Publication 655.1 (at this stage of the Preliminary Assessment).

Page 77

• At this Preliminary Assessment stage, there has been no attempt to estimate the amount of putrescible waste, mixed in with ‘Fill Material’ or Prescribed Industrial Wastes (PIW) estimates as currently provided.

• This has some implications across future odour disturbance issues to both residential and commercial areas within approximately 0.5 km of the Project Corridor and how such odour issues may be planned for and addressed during construction.

Pages 78, 94

• Current ‘Category C’ volume estimates for Silurian (siltstone/mudstone) bedrock excavation (where the contributing volume for excavation spoil is significant) are mainly based around presence of fluoride in these materials, where it could be well-argued to EPA that such materials should be re-classified as ‘Fill Material’.

Page 78

• Disposal of ‘Fill Material’ is regulated through the inherent requirements within IWRG and EPA Publication 1624

Page 84

• Top-of-page: In-situ contamination can often be in a very dynamic state and range in response across its various potential physical phases (separate (i.e. NAPL)/adsorbed/dissolved/ and vapour). The statement at the top of the page may be mis-leading. A lot of this project is located within fractured rock – not soil.

Page 98

• Mid-Page: Define ‘active’ extraction. It is very likely that active extraction of groundwater will occur across the construction phase of this project, to facilitate construction.

Page 98

• The suggested produced volume of ‘Category C’ spoil at 667,264 bulked cubic meters (bcm) is a large contributor to the suggested current landfill market capacity limit of 960,000 bcm.

• The suggested produced volume of ‘Category B’ spoil at 52,000 bcm is also a large contributor to the suggested current landfill market capacity limit of 72,980 bcm.

• Whilst its acknowledged that these above volume estimates for NELP are likely to vary downwards in the end, why has there not been a more formal Impact Assessment of the take-up of such future landfill air space when it comes to the potential limiting of the ability to dispose of PIW materials from industrial sites in Victoria? With the other contributing Major Projects, why has there not been the establishment of a formal Technical Working Group for this project, given that it is likely to be a dominant contributor to future volumes, where clearly this will have some impact to the contaminated land industry within Victoria?

Page 114

inquiry and advisory committee north east link …...preliminary matters and further information...

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