long term environmental management plan · 2020. 5. 20. · zoic environmental pty limited (zoic)...

Long Term Environmental Management Plan

1270 Richmond Road, Marsden Park, NSW, 2765 Cyan Stone Clydesdale Estate 1 Pty Ltd 18 September 2019

18177 LTEMP

18177 LTEMP | Cyan Stone Clydesdale Estate 1 Pty Ltd i

Quality Management

Document Distribution

Issue/Revision Issue 1 Revision 1 Revision 2

Remarks DRAFT

Date 18 September 2019

Prepared by Matthew Rendell

Senior Environmental Scientist

Signature Draft

Prepared by Tyler Creese


Signature Draft

Reviewed by Diana Turner


Signature Draft

File reference 18177_LTEMP_Rev0.docx

Distribution Cyan Stone Clydesdale Estate 1 Pty Ltd

Zoic Electronic File

This report was prepared in accordance with the scope of services set out in the contract between Zoic Environmental Pty Ltd, ABN 23 154 745 525, and the client.

Zoic Environmental Pty Ltd ABN 23 154 745 525

Suite 1, Level 9 189 Kent Street, Sydney 2000

Phone: +61 2 9251 8070 www.zoic.com.au

18177 LTEMP | Cyan Stone Clydesdale Estate 1 Pty Ltd ii

Executive Summary

Zoic Environmental Pty Limited (Zoic) was commissioned by Cyan Stone Clydesdale Estate 1 Pty Ltd (trading as BHL group, the Client) to prepare a Long-Term Environmental Management Plan (LTEMP) to manage residual soil contamination present within two areas at 1270 Richmond Road, Marsden Park, NSW.

The objective of this LTEMP is to manage residual contamination retained within the nominated containment areas. The LTEMP is to ensure that required capping layers are maintained throughout the lifespan of its use as recreational open space, or until the land use is repurposed or significantly altered.

The LTEMP has been designed to ensure that future activities which could result in disturbance of contaminated soil retained beneath the site, thus resulting in a potentially unacceptable risk to human health or the environment, are precluded, minimised or controlled.

The LTEMP includes a description of:

• The nature and location of contamination remaining on site

• Mechanisms for the public notification and legal enforcement of the plan

• Roles and responsibilities for implementation

• Risks and controls for Maintenance and future Site activities

• Periodic review requirements to ensure that the LTEMP remains protective of human health and the environment.

This LTEMP will apply indefinitely or until such a time that a Site Audit Statement can be prepared by an NSW EPA accredited site auditor stating that an environmental management plan is not required for the site.

18177 LTEMP | Cyan Stone Clydesdale Estate 1 Pty Ltd iii

Table of Contents

1 Introduction ....................................................................................................................................................................... 1

2 Public notification and Legal enforceability....................................................................................................... 3

3 Summary of previous assessments ....................................................................................................................... 4

4 Responsibilities ............................................................................................................................................................... 6

5 Work Health and safety ............................................................................................................................................... 8

6 Risks and controls for maintenance and future site activities .................................................................. 9

7 Unexpected Finds ......................................................................................................................................................... 15

8 Periodic Review ............................................................................................................................................................. 16

9 Other Relevant Information ...................................................................................................................................... 17

Appendices

Appendix A Figures

Appendix B Positive Covenant

Appendix C Unexpected Finds Protocol

18177 LTEMP | Cyan Stone Clydesdale Estate 1 Pty Ltd 1

1 Introduction

Zoic Environmental Pty Limited (Zoic) was commissioned by Cyan Stone Clydesdale Estate 1 Pty Ltd (trading as BHL group, the Client) to prepare a Long-Term Environmental Management Plan (LTEMP) to manage residual soil contamination present within two areas at 1270 Richmond Road, Marsden Park, NSW. The location of the containment areas which this LTEMP applies is shown on Figures 1 to 3. For the purpose of this document, the two containment areas are referred to as ‘the site’.

This LTEMP will apply indefinitely or until such a time that a Site Audit Statement can be prepared by a NSW EPA accredited Site Auditor stating that an Environmental Management Plan is not required for the site.

1.1 Background

In late 2018/ 2019 Zoic conducted a Data Gap Investigation (DGI), prepared a Remedial Action Plan (RAP) and subsequent RAP addendum associated with the development area located at 1270 Richmond Road, Marsden Park NSW. The development area consisted of Precincts 1 to 3, the area to the north of Precinct 1 which included a proposed open space area and two cut zones to the west of Little Creek. Precincts 1 to 3 were designated for low density residential land use with other zones utilised for bulk earthworks in preparation of construction footprints or as infrastructure corridors to service the new land release. The location of the development area and Precincts is shown on Figure 2.Based upon previous site characterisation, asbestos containing material (occurring as both friable and bonded forms), heavy metals, benzo(a)pyrene and aesthetically unsuitable materials within stockpiles and fill material areas were identified at concentrations/quantities not suitable for the proposed land use.

In consideration of potential options for remediation, it was understood a portion of the development area was demarcated for recreational open space land use. This allowed for consolidation and isolation by retainment of contaminated materials identified within the site, and placement within a suitably designed containment area evaluated as the preferred option within the RAP.

Remediation activities consisted of excavation and relocation of contaminated soil to the containment areas in accordance with the RAP and RAP addendum (Zoic 2019b and 2019c). Validation reports (XXXXXX) documented verification of the works ensuring the development area (including the containment areas) as suitable for use.

This LTEMP outlines the requirements and procedures to be employed by the landowner to manage the residual contamination that remains beneath the containment areas throughout their use.

1.2 Site Identification

The site location is shown in Figures 1 and 2 Appendix A. The site identification and land use details include:


Table 1.1: Site Identification

Title Details

Street Address: 1270 Richmond Road, Marsden Park NSW 2765

Property Description: Portions of Lot 5 DP1248522

Current Site Ownership: Cyan Stone Clydesdale Estate 1 Pty Ltd

Cyan Stone Clydesdale Estate 2 Pty Ltd

Cyan Stone Clydesdale Estate 3 Pty Ltd

Cyan Stone Clydesdale Pty Ltd

Cyan Stone Clydesdale Development Pty Ltd

Cyan Stone Clydesdale Holdings Pty Ltd

Geographical Coordinates: -33.678915, 150.801850 (Western Containment Area)

-33.681415, 150.811131 (Eastern Containment Area)

Containment areas (the site) Approximately 5 ha

Local Government Area: Blacktown City Council

Zoning – Existing: RE1 – Public Recreation

1.3 Objectives

The objective of this LTEMP is to manage residual contamination retained within the defined containment areas, to ensure that capping layers are maintained throughout the lifespan of recreational open space use, or until the land use is repurposed or significantly altered.

The objective is facilitated by:

• Detailing the nature and extent of the contamination which is retained onsite following the remediation.

• Specifying procedures to assist the landowner in management of the retained contamination.


2 Public notification and Legal enforceability

It is understood the containment areas subject to this LTEMP are owned by the entities detailed in Table 1.1 of this letter, and hence are responsible for ongoing operation.

In addition, the LTEMP and the Site Audit Statement will require notification on the section 10.7 planning certificate for the site.

With regard to legal enforceability a positive covenant is to be registered on the title of the land under Section 88B of the Conveyancing Act 1919 which acts to binds owners and future owners to be responsible for implementation procedures detailed under this LTEMP. A copy of letter ……… is provided in Appendix B.


3 Summary of previous assessments

Information regarding previous assessments conducted in relation to contamination at the property are included in the following documents:

• Geotechnique Pty Ltd (February 2012), Land Capability, Salinity and Contamination Assessments Report - Proposed Residential Subdivision Development Marsden Park Precinct – North West Growth Centre Richmond Road, Marsden Park (Report No. 12576/1-AA).

• Geotechnique Pty Ltd (May 2016), Preliminary Contamination Assessment (PCA), Lot 2 in DP 260476, Richmond Road, Marsden Park (Report No 13552/1-AA).

• Zoic Environmental (April 2019a) Data Gap Investigation, 1270 Richmond Road, Marsden Park, NSW.

• Zoic Environmental (April 2019b) Remedial Action Plan, 1270 Richmond Road, Marsden Park, NSW.

• Zoic Environmental (September 2019c) Remedial Action Plan Addendum, 1270 Richmond Road, Marsden Park, NSW.

• Zoic Environmental (XX 2019c) Validation Report, 1270 Richmond Road, Marsden Park, NSW.

The findings of these assessments indicated the following chemicals of concern identified within soils at concentrations/quantities not suitable for the proposed residential land use:

• asbestos containing material (occurring as both friable and bonded forms),

• heavy metals,

• benzo(a)pyrene, and

• aesthetically unsuitable materials

The contaminated soils were located within remnant soil stockpiles and subsurface fill material located at several locations throughout the development area (As identified on Figures 9 through 11 from Zoic 2019a). In order to ensure the site was suitable for the proposed land use, the DSI concluded that remediation was necessary to address identified site contamination issues.

3.1 Summary of remediation works

To address the identified site contamination issues the following remediation works were conducted as documented within the Validation report (Zoic, XX 2019):

• Excavation and placement of impacted fill materials. The areas of fill material and stockpiles identified to warrant remediation were excavated and transported to the designated containment area as guided by the protocols stipulated in the RAP. Where temporary stockpiling was required appropriate control measures were employed for works with potentially contaminated materials. It is also noted ‘emu picking’ and segregation activities were conducted on selected remediation where appropriate.

• Consolidation and isolation within the containment area which consisted of the following:

- Site clearance and preparation including removal and clearance of existing vegetation in the area designated for placement.

- Placement and compaction of materials to support the overlying proposed recreational open space land use.


- Placement of a marker layer directly upon the contaminated soils to act as a visual barrier to signal the presence of potentially hazardous material below the marker layer

- Installation of the following cover layers a minimum 500mm in thickness

i. a compacted clay layer able to achieve to a permeability of 1x10-9 m/s.

ii. Above the compacted clay layer, a layer of clean fill (VENM or site won ENM)

- Immediately above the cover layers placement of second marker layer

It is noted that a minimum of 300mm of topsoil was placed above the second marker.

In accordance with the RAP, containment area cover layers must be maintained. Activities with potential to impact site capping must therefore be avoided, such as installation of structures, planting of deep-rooted trees, etc. Should such activity be required in the capped area, an appropriate strategy should be provided by a suitably qualified environmental consultant. It is understood that the site will be re-vegetated with pasture grasses.

Please refer to Figure 3 for a cross section of the installed containment area design.

3.2 Residual Contamination Extent

As a result of the investigation and remediation works summarised above, residual contamination has been consolidated and isolated within the containment area (to be used long term as recreational open space).

The identified COCs known to be present within the residual contamination include:

• asbestos containing material (occurring as both friable and bonded forms),

• heavy metals,

• benzo(a)pyrene, and

• aesthetically unsuitable materials

The extent of the residual contamination is presented on Figure 3.

During future maintenance or construction activities, which involve excavation below the existing site surface, it is possible that workers may come into contact with the potentially contaminated media detailed above.


4 Responsibilities

This section summarises the various parties who have been allocated a responsibility under this LTEMP. The responsibilities have been allocated according to the party best placed to manage the requirements.

The responsibilities may be delegated where appropriate but this must be done in writing and notified to all affected parties.

4.1 LTEMP Induction

All personnel proposing to conduct any task that involves disturbance of the containment area surfaces (i.e. excavation) must complete an environmental awareness induction prior to their commencement of works on the site. The awareness induction will include:

• Outline of the objective and purpose of the works; and

• Contents of the LTEMP and individuals responsibility.

All project staff and sub-contractors must adhere to this LTEMP. In addition to this, the sub-contractor (if present) must prepare their own task specific EMP, which will be adhered to for the duration of the works. If relevant, all personnel on the site also need to recognise the existence of the landowners Work Health & Safety and Environmental systems, to be implemented in conjunction with this LTEMP.

4.2 Responsibilities

All works carried out on the site must be conducted under the guidance of an appropriate site manager, identified by the landowner, who will be responsible for the implementation of the majority of procedures provided in the LTEMP. Where the specific procedures are technical or complex in nature, it may be appropriate to appoint qualified agents (i.e. environmental consultants) to fulfil the requirements or advise regarding appropriate implementation.

Table 4.2 below outlines the roles and responsibilities of the implementation of the LTEMP. The primary contact point for all communication (including incident reporting) associated with this LTEMP will be the identified site manager.

Table 4.2 Responsibilities

Party Responsibility of Party

Landowner

• Maintains ultimate responsibility for implementation of the LTEMP.

• Will review the effectiveness of the LTEMP on an annual basis and following any incident or other event that suggests the LTEMP is ineffective.

• Will record any review of the EMP undertaken and ensure that any improvements deemed necessary are implemented and communicated to relevant parties.

• Will ensure that sufficient resources are allocated to comply with the requirements of this EMP.

• Will ensure that potential future purchasers of the site are aware of the need to develop their own ongoing management measures to ensure that the integrity of the recreational open space surface is not compromised and that there is no unacceptable risk to site occupants.


Party Responsibility of Party

Site manager or designated party

• Communicate between the onsite Contractors / Maintenance Workers, etc. and the landowner, as required.

• Will ensure that Contractors / Maintenance Workers, etc. engaged to undertake any works on site are notified of the existence of the LTEMP, and inducted into the site as relevant.

• Will ensure that any issues that suggest that the LTEMP is ineffective are reported to the Environmental Coordinator.

• Report any incidents to the landowner.

• Act as contact point for any incident reporting.

Contractors, Maintenance Workers, etc.

• Will ensure the LTEMP content is passed onto relevant personnel/subcontractors.

• Will ensure that risks have been assessed and suitable control measures implemented where the site surface will be disturbed in compliance with the LTEMP.

• Will ensure that they are briefed on the presence of contaminated material below the site surface.

• Will ensure that they have received necessary site inductions.

• Will develop task specific EMP/ Construction Management Plan (CMP)/health and safety plan for any proposed intrusive work.

• Will promptly notify any concerns regarding the implementation of this EMP to the site manager.


5 Work Health and safety

5.1 Site Hazards

Potential hazards exist through dermal contact, ingestion or inhalation of soil, that may contain contamination (as detailed in Section 3.0 above). During future excavation activities, it is possible that workers may come into contact with contaminated media.

Personal protective equipment (PPE) may include disposable coveralls, gloves and suitably rated dust masks / respirators. Safety glasses may be required if there is a risk of soil contact with the eyes. It is noted that site-specific PPE may also be specified by the landowner or appointed Contractors / Maintenance Workers, etc. depending on their proposed activities.

It is essential that the site manager reviews a safe work method statement (SWMS) prepared by the Contractor / Maintenance Workers, etc. to ensure that the specific risks associated with the proposed works have been appropriately assessed before any intrusive activities are conducted on site.

5.2 Competence, Training and Awareness

Prior to commencing any work at the site, the landowner must ensure that all employees, Contractors, and Maintenance Workers have received the appropriate level of environmental training to achieve the standard of awareness and competence appropriate to their assigned activities.

For any proposed excavation works, the site manager will be on-site at a minimum during commencement and periodically to supervise and/or conduct the works. The site manager will engage with Contractors / Maintenance Workers, etc. by means of work health & safety (WHS) briefings before the start of site works to ensure all environmental and WHS controls are implemented and any new hazards are identified, assessed and controlled.

All persons involved in any works at the site will:

• Become fully briefed and aware of the work they are required to carry out;

• Possess the necessary qualifications, training and experience to carry out the work and appropriately manage any associated environmental and WHS risks; and

• Have appropriate verbal language and literacy skills.

5.3 Safe Works Practices

The requirement for the following safe work practices should be incorporated into SWMS for excavation works exceeding 0.3m depth below surveyed site levels (refer to Figure 3 Appendix A):

• All work areas must be appropriately fenced and signage displayed prior to commencement of any excavation works.

• Personnel and equipment decontamination areas must be established within the defined work area.

• The excavation and reinstatement process of contaminated materials must be managed and controlled by procedures developed by a NSW Licensed Asbestos Assessor in accordance with prevailing legislation and guidelines.


6 Risks and controls for maintenance and future site activities

With regard to environmental management of the site, the activities identified which need to be controlled include:

• Periodic inspection and maintenance to ensure the integrity of the cover layers for the recreational open space areas.

• Any subsurface works that have the potential to penetrate the upper 0.3m and expose contaminated soils.

Management measures to be employed to address future risks are presented in the following sections.

6.1 Periodic Inspection and Maintenance activities

An appropriate person appointed by the site manager / landowner, must inspect the integrity of the cover layers periodically on an annual basis and following weather events with potential to damage site capping (1:100yr rain events or severe storms) to ensure that the integrity of the surface/cover layers are maintained.

Any Capping Material that may be exposed as a result of site activities must be managed by the relevant procedures outlined in Section 6.3 and 6.4 below.

Where the integrity of the capping layers is potentially compromised, it must be reinstated at the earliest possible opportunity in accordance with procedures stipulated in 6.4. As an interim measure any areas of damaged topsoil should be cordoned of from public access until adequate reinstatement can be achieved.

6.2 Subsurface works

Works which intentionally disturb by penetration / excavation below the site surfacing (e.g. Topsoil) may pose a risk to Contractors / Maintenance Workers, etc. Future activities on the site must be assessed for their potential to penetrate the upper 0.3m of the site (as defined by the Survey Drawings presented in Appendix A). Any proposed works should be assessed by the site manager using the following flow chart:

Chart 6.1: Works Assessment Flow Chart

STEP 1: Establish if required works will penetrate the capping layer. (refer to Figure X for final construction levels)

NO

Works carried out in accordance with landowner procedures.

YES

STEP 2: Site manager to provide Contractor or relevant personnel with LTEMP to enable preparation of site specific SWMS and EMP/CMP by the Contractor.


STEP 3: Materials excavated during works are to be stockpiled seperately as per Section 6.3.2 below

STEP 4: Excavated materials are to be replaced below the capping layer (where possible), or assessed and disposed offsite in accordance with the Waste Classification Guidelines (NSW EPA, 2014)

STEP 5: Reinstatement of capping layers in accordance with section 6.4

STEP 6: Site manager to inspect works at completion for approval and records kept accordingly.

6.3 Subsurface management procedures

6.3.1 Air quality and Dust

Air quality and dust control measures should be applied when activities involving excavation and handling of soils have the potential to generate dust emissions. The objective of the controls is to minimise dust and hazardous airborne substances (including asbestos fibres) from the earthworks.

All operations of the site are to be conducted so that the concentrations of dust, other hazardous airborne substances satisfy those stipulated in legislation or NSW EPA published and endorsed guidelines. These include:

• NEPC (1998) National Environment Protection Measure for Ambient Air Quality

• Environmental criteria provided to NSW DEC (August 2005) Approved Methods for the Modelling and Assessment of Air Pollutants in NSW

Additionally, the following guidelines should be followed to manage asbestos related risks:

• SafeWork NSW guidelines.

• Safe Work Australia (2011) How to Safely Remove Asbestos Code of Practice.

• Safe Work Australia (2011) How to Manage and Control Asbestos in the Workplace.

• WA Department of Health (2009) Guidelines for Assessment, Remediation and Management of Asbestos-Contaminated Sites in Western Australia.

• EnHealth Council (2005) Management of Asbestos in the Non-Occupational Environment, Commonwealth of Australia: Canberra (http://enhealth.nphp.gov.au/council/pubs/pdf/asbestos.pdf).

Control Measures

• Evaluation of weather conditions (including changes in wind direction) prior to and during works.

http://enhealth.nphp.gov.au/council/pubs/pdf/asbestos.pdf


• Appointment of a competent person to coordinate and specify environmental control measures / air quality monitoring in accordance with existing legislation and guidelines with respect to asbestos.

• A contact officer responsible for handling enquiries and potential complaints should be designated.

• A sealant, temporary cover or encapsulation should be applied to degraded ACM or remnant asbestos building material in soil that cannot be immediately removed.

• Minimisation of vehicle movement on exposed ground/capping surfaces.

• If dust generation is excessive, employ water spray or cease works.

• Stockpile heights kept to a minimum, with stockpiles to be kept covered or moist.

• Ensure plant equipment emissions comply with air quality standards.

• Covering of all contaminated material being transported from site in accordance with NSW EPA requirements.

• Adoption of necessary personal protective equipment by personnel on the site.

• An appropriate person nominated by the landowner should visually monitor works areas for the presence of dust as works progress.

6.3.2 Contaminated material

Contaminated soil control measures should be applied during the removal of soil during excavation works to:

• Minimise the potential for contaminated soil to disperse onto ‘clean’ land or migration into surface drainage channels.

• Minimise contact between site workers and contaminated soil.

Control Measures

• An exclusion zone / work zone will be established around the works area. A barricade or mesh fence will be installed around the excavation and stockpile areas. It is noted as asbestos constituents a COC for contaminated soil onsite signs should be placed in accordance with AS 1319-1994 safety signs for the occupational environment for size, illumination, location and maintenance

• Contaminated soil must not be placed directly on uncontaminated areas. Contaminated soil should be placed onto sealed / prepared areas. Where contaminated soil needs to be placed into an uncontaminated area for stockpiling, the stockpile footprint will be scraped when the stockpile is removed. The area will then be validated via soil sampling for the contaminants of concern relevant to the stockpile and compared to NSW EPA approved guidelines for the on-going recreational open space land use. Alternatively, contaminated soils may be disposed of directly into trucks if suitable for disposal offsite or temporarily stockpiled in appropriately controlled (i.e. plastic lined and covered) locations if chemical characterisation is required.

• Decontamination Zone: at the completion of the work, all equipment used for excavation, storage and transfer of contaminated soil is to be cleaned within the site. Decontamination of equipment will comprise physical removal using scraping or brushing of all soil adhering to excavation machinery and implements on to the piles of soil which are scheduled for off-site disposal at a suitably licensed facility.


• Contaminated material will be removed from plant and equipment before relocating from each excavation area containing contaminated soils. Contact of the contaminated soils with the excavator tracks / wheel will be minimised.

• All contaminated soils will be transported along designated routes throughout the site. These routes will be clearly identified on a site plan and posted within the site.

• If soils require offsite disposal they should assessed and classified in accordance with NSW EPA (2014) Waste classification Guidelines Part 1: classifying waste

• Vehicles exiting the site will be washed or cleaned such that sediment deposition to local roads is minimised.

• Trucks leaving site will have their loads covered.

• Sediment controls such as silt screens or hay bales will be placed downgradient of all excavation and stockpile areas.

• There will be no discharge of contaminated water onto land or surface drains. Water in excavation must be controlled, analysed and disposed off site in an appropriate manner (i.e. Sydney Water Discharge Consent or suitably licensed waste facility).

• Refuel plant and equipment in a designated area away from landscaped areas, excavations or joins in the concrete pavement.

• Make “spill kits” available on site.

• No maintenance is proposed on-site. In the event of minor equipment failure, maintenance will be undertaken on an applicable hardstand surface. Where major maintenance is required, the plant equipment will be returned to the relevant company’s depot.

6.3.3 Asbestos notification and removal requirements

In the event a given activity where required by regulations and/or guidelines the contractor may be required to notify Safework NSW to obtain the necessary permits for the work to be undertaken (5 days notification required). Works deemed to constituent an asbestos removal may require preparation of an asbestos removal control plan in accordance with relevant guideline and Safework NSW requirements

6.3.4 Sediment control

Sediment migration has the potential to pollute creeks and waterways and increase the sediment load on stormwater management systems and infrastructure. Sediment Control measures should be applied to mitigate potential sediment generation and migration.

Control Measures

• Placement of sediment control measures such as silt fences, downgradient of the work area prior to works commencing.

• Where possible, stockpiles will be placed upslope of open excavations and away from stormwater inlets, ensuring any releases of sediment re-enter the excavation and are not transported offsite.

• Cease works if significant rain event occurs.

• Conduct works in a manner which minimises the potential for sediment and soil migration, whereby excavated material will be quickly reinstated and compacted if possible.

• Mitigation measures implemented in areas where sediment loaded runoff is likely to occur or if rainfall event is predicted.


• Clean-up of sediment.

• Additional stormwater control measures such as diversion devices to minimise contact of stormwater flows with stockpiled materials

6.3.5 Stockpile management

Stockpile management shall be handled in accordance with agreed procedures that meet statutory requirements. It is recommended due to the presence of asbestos stockpiling of contaminated material is avoided where possible. Proposed stockpile management procedures should include but not be limited to the following:

• Stockpiles of contaminated materials will be required to be covered with plastic to minimise liberation of asbestos, dust emission and limit runoff if remaining for more than 24 hours. Managing runoff can be achieved can be achieved by placing stockpiles in areas of secondary containment, with the footprint lined with plastic or the stockpile footprint scraped following removal

• “Impacted” and “non-impacted” stockpiles will need to be stockpiled separately.

• It is preferable that “impacted” material be loaded directly into trucks immediately after excavation for placement at the destination location. Wetting down of materials should be completed during placement to minimise any potential liberation of asbestos fibres.

• Stockpile height should be less than 3m.

• Stockpiles are to be kept away from the site boundary.

6.3.6 Emergency response

Environmental incidents on the site requiring an emergency response would relate to a spill of hazardous liquid or material on ‘clean’ soils on the site, or in the proximity of a stormwater discharge point. The objective of Emergency Response control measures is to minimise environmental impacts of all incidents on site.

Control Measures

For any spills, the following will be undertaken:

• Identify source of spill and stop when/if safe to do so.

• Identify area of spill and clear area of all personnel.

• Notify site manager or landowner of spill immediately.

• Construct earthen bunding using earth moving equipment available on the site to contain spill.

• Assess soils in vicinity of environmental incident for contamination and conduct remediation works where contamination has occurred.

All emergency responses to be followed up with incident reporting and review.

6.4 Reinstatement of capping layers

In the event where conditions of the site have been altered potentially resulting in increased exposure to contamination beneath the capping layers, corrective action must be undertaken to restore the area to its former state.

The responsibility for implementing corrective actions will rest with the site manager or their nominated representative.


With respect to works that may penetrate the open space surface, the party working on site who damages the cap (either intentionally or accidentally) will be responsible for its repair before they leave the site. The Site Manager/landowner could control potential damage to the site surface by specification (i.e. the addition of a clause relating to the repair of the site surface) and through monitoring of the work as it progresses and after it is complete.

Upon completion of the works, the capping layer (including marker layers must be reinstated as per specification as detailed in 3.1. Topsoil media will also require to be replaced 300mm above the second marker layer.

In the event imported VENM is to be used for reinstatement, source documentation for the VENM must be provided to the site manager including assessment by a suitably qualified Environmental Consultant that the material can be classified as VENM.

The findings of the reinstatement inspections must be thoroughly documented by the site manager.


7 Unexpected Finds

It is considered that the likelihood of encountering unexpected finds at the site is low given that the site has already undergone environmental assessment and validation works to confirm installation of 0.5m of cover layers and 0.3m of topsoil media respectively (refer Figure 3). However, the possibility of encountering unexpected finds cannot be excluded all together and therefore the following procedures need to be adhered to in the event an unexpected find is encountered at the site.

7.1 Unexpected Finds Protocol

The nature of any residual hazards which may be present at the site are generally detectable through visual or olfactory means, for example and shown in Appendix C:

• ACM in soils which have not been assessed/managed in accordance with NEPC (2013);

• construction / demolition waste (visible);

• ash and/or slag contaminated soils / fill materials (visible)

As a precautionary measure to ensure the protection of the workforce and surrounding community, should any of the abovementioned substances be identified (or any other unexpected potentially hazardous substance), the procedure in Appendix C is to be followed.


8 Periodic Review

The landowner will review the effectiveness of the LTEMP on an annual basis and following any incident or other event that suggests the LTEMP is ineffective. The landowner will record any review of the LTEMP undertaken and ensure that any improvements deemed necessary are implemented and communicated to relevant parties.

During the course of the works, if the scope changes, and/or environmental damage results from exposure to a hazard, then the adopted control measures will be assessed and revised accordingly.


9 Other Relevant Information

This Audit relates only to those matters relevant to the CLM Act 1997 and CLM Amendment Act 2008, which describes that “The general object of this Act is to establish a process for investigating and (where appropriate) remediating land that the EPA considers to be contaminated significantly enough to require regulation under Division 2 of Part 3”. The SAS and SAR do not seek to provide an opinion regarding other aspects of the environment not related to site contamination, to the suitability of the site in regard to the occupational health and safety legislation, or in regards to the suitability of the engineering design.

By definition, auditing involves the review and critique of Consultants’ work, including site histories, site surveys, subsurface investigations, chemical and physical analyses, risk assessments and modelling. Accordingly, the Auditor relies on the experience, expertise and integrity of the relevant organisations. The information sources referenced have been used to determine site history and local subsurface conditions. While the Auditor has used reasonable care to avoid reliance on data and information that is inaccurate or unsuitable, the Auditor is not able to verify the accuracy or completeness of all information and data made available.

Sampling and chemical analysis of environmental media is based on appropriate guidance documents made and approved by the relevant regulatory authorities. Conclusions arising from the review and assessment of environmental data are based on the sampling and analysis considered appropriate based on the regulatory requirements and site history, not on sampling and analysis of all media at all locations for all potential contaminants.

Environmental sampling and laboratory analyses were undertaken as part of the investigations reviewed by the Auditor, as described herein. Ground conditions between sampling locations may vary, and this should be considered when extrapolating between sampling points. Chemical analytes are based on the information detailed in the site history. Further chemicals or categories of chemicals may exist at the site which was not identified in the site history.

Changes to the subsurface conditions may occur subsequent to the investigations described herein, through natural processes or through the intentional or accidental addition of contaminants. The conclusions and recommendations reached in this site audit are based on the information provided at the time of the investigations.

18177 LTEMP | Cyan Stone Clydesdale Estate 1 Pty Ltd

Appendix A Figures

LondonderryLondonderryVineyardVineyard

Bligh ParkBligh Park

Windsor DownsWindsor Downs

Berkshire ParkBerkshire Park

RiverstoneRiverstone

Rouse HillRouse Hill

Marsden ParkMarsden Park

CranebrookCranebrook

SchofieldsSchofields

LlandiloLlandilo

Quakers HillQuakers Hill Parklea

Glenwood

ShalveyShalveyBidwillBidwill

Hassall GroveHassall Grove

Lethbridge ParkLethbridge Park Dean ParkDean ParkCambridge GardensCambridge Gardens

BlackettBlackett GlendenningGlendenning

EmertonEmerton

Werrington DownsWerrington DownsKings Langley

DharrukDharruk

Shanes ParkShanes Park

Ropes CrossingRopes Crossing

THE

NORTHER

N ROAD

THE

NORTHER

N ROAD

Windsor Downs Nature Reserve

Castlereagh Nature Reserve

Wianamatta Regional Park

Wianamatta Nature Reserve

Ric

kaby

s C

reek

Ric

kaby

s C

reek

St

Mary

s R

oad

St

Mary

s R

oad

Richmond Road

Richmond Road

Windsor Road

Windsor Road

Llandilo A

venue

Llandilo A

venue

Grange AvenueGrange Avenue

0 2km

Site Boundary

National Parks and Wildlife Estate

Parks and Reserves

Road

Rail

Watercourse/drainage line

LEGEND

Underground pipeline

High voltage electricity

Zoic do no warrant the accuracy or completeness of information in this publication and any person using or relying upon such information does

so on the basis that this company shall bear no responsibility or liability whatsoever for any errors, faults, defects or omissions in the information.

Date: 14/01/2019

Figure 1: Site Location

Site address: 1270 Rihmond Road, Marsden Park

Client: Boyuan Holding Limited

Job Number: 18177 Rev:

LEGEND

This product has been created to support the main report and is indicative only, and not suitable for other purposes. Image courtesy of Nearmaps.

Figure 1: Site Layout

Site Address: 1270 Richmond Road, Marsden Park NSW

Client: Boyuan Holdings Limited

Job Number: 19112 Date: September 2019

Approximate property boundary

0m 200m

Scale indicative only

NArea 1

Area Boundaries

Area 6

Area 6

Area 6

Development Area

Containment Areas – ‘Site’

Area 2

Area 3

Precinct 3Precinct 1

Precinct 2

Development Stage Borders

Cut Zone 1

Area 4

Cut Zone 2

Area 5

* Boundaries are approximate

Heritage Area


Figure 3 Surveyed cross section/figure


Appendix B Positive covenant


Appendix C Unexpected Finds Protocol

BE AWARE

UNEXPECTED HAZARDS MAY BE PRESENT

if you SEE or SMELL anything unusual

asbestos

odour

ash / slag

demolition waste

STOP WORK & contact the Site Foreman

do not restart working before the area has been investigated and cleared by an Environmental

Consultant

www.zoic.com.au

long term environmental management plan · 2020. 5. 20. · zoic environmental pty limited (zoic)...

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