asbestos soil management plan · 2019-10-19 · december 2014 j130046 amp corowa ps 1 1....

Noel Arnold & Associates (GreencapNAA)

ABN: 76 006 318 010

Level 1 / 677 High Street Kew East VIC 3102

Australia P: (03) 9890 8811 F: (03) 9890 8911

www.greencap.com.au

ASBESTOS SOIL MANAGEMENT PLAN Joss Facility Management Corowa Public School

December 2014 J130046

C106543 : RWG

December 2014

J130046 AMP Corowa PS ii

Asbestos Soil Management Plan

Joss Facility Management

Corowa Public School

Document Control

Document Quality Management Details

Report Name: Asbestos Soil Management Plan

Site Details: Corowa Public School

Project Number: J130046

Client Name: Joss Facility Management

Client Number: C106543

Signatures:

Prepared By:

Roger Gibbs

Senior Environmental Consultant

Authorised By:

Travis Shreeve

Regional Practice Manager - Environment

Issue Status

Issue No. Status Date Creator Reviewer

1 Final 16/12/2014 Roger Gibbs Travis Shreeve

Document Circulation

No of Copies Type Customer Name Position & Company

1 Electronic Sam Cossor District Supervisor – Joss Facility Management

December 2014

J130046 AMP Corowa PS 3

Statement of Limitations

This report has been prepared in accordance with the agreement between Joss Facility Management and GreencapNAA.

Within the limitations of the agreed upon scope of services, this work has been undertaken and performed in a professional manner, in accordance with generally accepted practices, using a degree of skill and care ordinarily exercised by members of its profession and consulting practice. No other warranty, expressed or implied, is made.

This report is solely for the use of Joss Facility Management and any reliance on this report by third parties shall be at such party's sole risk and may not contain sufficient information for purposes of other parties or for other uses. This report shall only be presented in full and may not be used to support any other objective than those set out in the report, except where written approval with comments are provided by GreencapNAA.

Sampling Risks

It is noted that professional judgment has been used to interpret the data obtained from site sampling and subsequent laboratory testing in order to characterise contamination that is present on site. Joss Facility Management accepts that even a comprehensive sampling and testing program, implemented with the appropriate equipment and experienced personnel under the direction of a trained professional who functions in accordance with a professional standard of care, may fail to detect certain conditions because they are hidden and therefore cannot be considered in development of a sub-surface exploration program.

The extent of soil sampling and analysis has been targeted towards areas where contamination is considered to be most likely, based on site history and visual assessment. The methods adopted are in accordance with recognised industry standards. This approach maximises the probability of identifying contaminants. However, it may not identify contamination that occurs in unexpected locations or from unexplained sources. Soil contamination can be expected to be non-homogenous across the stratified soils where present on site, and the concentrations of contaminants may vary significantly within areas where the contamination has occurred. For this reason the results should be regarded as indicative only.

Contaminant movement within the soil and within groundwater can follow paths of high permeability and it is possible that sampling will not have intersected these preferential pathways. In the case of groundwater, the flow can follow relatively narrow migration paths within minor aquifers. GreencapNAA is available to explain these risks

and risk reduction methods to Joss Facility Management, but in any event, the scope of services included with the

Proposal is that which Joss Facility Management agreed to or selected in light of his own risk preferences and other considerations.

Sampling of soil or groundwater may result in contamination of certain sub-surface areas, as when a probe or boring device moves through a contaminated area, linking it to an aquifer or other water body not previously contaminated. GreencapNAA has applied it best efforts to minimise and eliminate such cross contamination during the conduct of any sub-surface investigation. Because sub-surface sampling is a necessary aspect of the work which

GreencapNAA may perform on Joss Facility Management’s behalf, Joss Facility Management waives any claims against GreencapNAA and agrees to defend, indemnify and hold GreencapNAA harmless from any claims or liability for injury or loss which may arise as a result of alleged cross contamination caused by sampling.

Reliance on Information Provided by Others

Whilst the techniques used in the assessment are in accordance with recognised industry standards, the investigations also rely on information provided to GreencapNAA by third parties. Naturally, GreencapNAA cannot guarantee completeness or accuracy of any descriptions or conclusions based on information supplied to it during

site surveys, visits and interviews. The extent of risk Joss Facility Management wishes to accept is something which

Joss Facility Management should determine and accordingly, Joss Facility Management waives any claim against GreencapNAA and agrees to defend, indemnify and hold GreencapNAA harmless from any claim or liability for injury or loss allegedly arising from errors, omissions or inaccuracies in documents or other information provided to

GreencapNAA by Joss Facility Management.

Recommendations for Further Study

GreencapNAA’s preliminary findings which may result from this investigation/study may require verification through further analytical testing programs. The final decision to conduct additional investigative activities will be

dependent upon Joss Facility Management’s assessment of the business risks involved. Joss Facility Management

agrees to hold GreencapNAA harmless from any claim, losses or damages arising out of Joss Facility Management’s rejection of any additional work suggested by GreencapNAA as a result of the work performed hereunder.

December 2014


Asbestos Soil Management Plan

Joss Facility Management

Corowa Public School

Table of Contents

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

1.1 Background ................................................................................................................................. 1

1.2 Objectives .................................................................................................................................... 1

2 Definitions/Explanations ........................................................................................................................ 1

3 Proposed Works ..................................................................................................................................... 2

4 Legislation............................................................................................................................................... 2

5 General Requirements ........................................................................................................................... 3

6 Environmental Management Requirements .......................................................................................... 3

6.1 Occupational Health and Safety .................................................................................................. 4

6.2 Site Specific Training ................................................................................................................... 5

6.3 Tool Box Meetings ....................................................................................................................... 5

6.4 Personal Protective Equipment and Hygiene .............................................................................. 5

6.5 Isolation and Signage .................................................................................................................. 6

6.6 Monitoring, Inspection & Audits ................................................................................................. 6

6.7 Identification of On-site Services ................................................................................................ 7

6.8 Soil Management On-site (If Required) ...................................................................................... 7

6.8.1 Excavation and Stockpiling .............................................................................................. 8

6.8.2 Onsite Movement of Soil ................................................................................................. 8

6.8.3 Importation of Fill ............................................................................................................ 9

6.9 Offsite Disposal of Soils and/or Asbestos Waste ........................................................................ 9

6.10 Water Management .................................................................................................................... 9

6.10.1 Surface/Stormwater Management .................................................................................. 9

6.10.2 Wastewater Disposal ..................................................................................................... 10

6.11 Dust Suppression....................................................................................................................... 10

6.12 Background Air Monitoring ....................................................................................................... 10

6.13 Use of Heavy Equipment ........................................................................................................... 11

6.14 Noise Monitoring ...................................................................................................................... 11

6.15 Unexpected Contamination ...................................................................................................... 11

6.16 ASMP Review ............................................................................................................................ 12

6.17 Reporting ................................................................................................................................... 12

7 Ongoing Management .......................................................................................................................... 12

7.1 Clearance Certificate/Site Validation ........................................................................................ 12

7.1.1 Asbestos Register ........................................................................................................... 13

7.1.2 Memorandum on Title (MOT) ........................................................................................ 13

7.2 Surface Covering/Capping Layer ............................................................................................... 13

7.2.1 Imported Fill Material .................................................................................................... 14

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1. INTRODUCTION

GreencapNAA was engaged by Joss Facility Management (Joss) to develop an Asbestos Soil Management Plan (ASMP) for Corowa Public School, 244 Honour Avenue, Corowa, NSW, Victoria (the ‘site’).

GreencapNAAwere requested by Joss to develop the ASMP for proposed asbestos removal works at the site and to provide on-going management measures (if required) at the site following the works.

This document intends to outline environmental management requirements for the Site and detail a specification for works that are foreseen to be necessary to meet client requirements in terms of asbestos contaminated soil management at the Site.

It should be noted that Joss may be required to modify this plan as necessary in consultation with GreencapNAA to ensure that the ASMP is effectively implemented, prior to, during and following proposed abatement works at the site.

The following document is based on information reported during previous assessment undertaken at the Site by GreencapNAA and should be read in conjunction with GreencapNAA report: J128725 Corowa PS Site Inspection Report), prepared in September 2014.

1.1 Background

During the previous assessment undertaken by GreencapNAA at the site, the presence of asbestos containing materials (ACM) was observed at the site within the garden bed area to the south/east of Building L and the sub-floor area of Building L.

The presence of bonded ACM in the form of asbestos cement sheet debris was observed on the soil surface in the Building L subfloor area during the site inspection. The ACM cement sheet debris was considered likely to be associated with the historical use of ACM packers in the subfloor area.

The presence of bonded ACM in the form of asbestos cement sheet debris and potentially friable asbestos in the form of millboard debris were observed within the garden bed area located in the south western area of the school site.

The ACM observed was considered likely to be associated with the presence of building debris observed in this area of the site. GreencapNAA considered that the building debris (including ACM) was potentially surfacing from in-situ soils and that further ACM may be present in the subsurface in this area (potentially associated with the former use of the site as a landfill).

Given the presence of ACM observed on the surface of the site and the likely presence of ACM within subsurface soils, it was considered that further management of the soils would be required to manage the potential risk posed by the contamination to users of the site (e.g. employees and students).

Based on the ACM observed on the surface of the site GreencapNAA recommended that it be removed so far as reasonably practicable by a Class A licensed contractor. Following removal of the ACM (so far as reasonably practicable) and a visual inspection and associated documentation be provided by a licensed asbestos assessor to assess the removal.

Joss requested that GreencapNAA provide a fee proposal to prepare a management plan for the removal of ACM from the surface of the site and to provide hygiene services during proposed removal works.

In addition based on the potential for ACM to be present within sub-surface soils across the wider school site associated with the former landfill Joss requested that GreencapNAA undertake a preliminary site investigation (PSI) to assess the potential for wider ACM contamination in soil at the site.

1.2 Objectives

The objective of this ASMP is to assist Joss with regard to providing contractors with procedures relating to the management of contaminated soil during abatement works and for the ongoing management of the soil.

2 DEFINITIONS/EXPLANATIONS

Asbestos Containing Material (ACM) – Visible bonded cement sheet debris and compressed fibrous millboard type material.

Contractor/Operator – A Class “A” licensed removalist/operator of machinery or plant employed by Joss to conduct asbestos removal (or related) works at the Site.

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Environmental Consultant/Hygienist – A suitably qualified Environmental Consultant/Hygienist engaged by Joss. Based on the potential for friable ACM the nominated consultant should be a NSW WorkCover ‘Licensed Asbestos Assessor’.

Site Supervisor – Designated person employed/contracted by Joss to supervise works undertaken at the Site.

3 PROPOSED WORKS

It is the understanding of GreencapNAA that the following tasks/processes are proposed to be undertaken at the Site:

1) Vegetation clearance (shrubs and small trees); 2) Systematic walkover (chicken pick) of site surface to remove visible ACM so far as reasonably practicable

from the surface fill soils (top 10 cm) by a licensed asbestos removalist (based on the potential presence of friable asbestos we recommend that the works be undertaken by a Class A licensed contractor);

3) Following removal of the ACM (so far as reasonably practicable) a visual inspection and associated documentation should be provided by a licensed asbestos assessor to assess and detail the removal process undertaken.

4) Placement of geofabric and minimum 200 mm imported validated clean-fill capping layer; and 5) Landscaping of site.

The following sections provide for management requirements and control measures to be implemented during the above tasks. Should additional tasks be required to be undertaken as part of the proposed works additional management requirements may be required. Furthermore, depending on the extent of the contamination observed during the proposed asbestos abatement works at the site additional and/or amended management measures may be required.

Assuming no intrusive works (including maintenance works, soil excavation or any activity that has the potential to disturb the surface covering and/or underlying potentially contaminated soils) are proposed to be undertaken at the site, provisions for ongoing management including maintenance of the surface covering are provided in Section 7 of this document.

Should any works be proposed at the site that have the potential to disturb contaminated soils and/or the surface covering overlaying the soils reference should be made to this management plan including the environmental management requirements listed in Section 6.

4 LEGISLATION

The removal of asbestos and/or undertaking of asbestos related works (tasks 1, 2 (and 4/5 pending field observations during abatement works and/or if it involves the disturbance of soils below the capping layer) as listed in section 3) where the asbestos has been classified as ‘friable’ by a suitably qualified hygienist (competent person) must be undertaken by a Class A licensed asbestos removalist as per the NSW Work Health and Safety Regulation (2011) and relevant NSW WorkCover and Safe Work Australia guidance for the removal/management of asbestos in the workplace.

Based on the potential for friable asbestos (Class A removal work) it is a legal requirement that only a WorkCover Licensed ‘Asbestos Assessor’ may undertake air monitoring, risk assessments, and issue clearance certificates for removal works undertaken.

The Prohibition on asbestos under Clause 419 of the NSW Work Health and Safety Regulations (2011) must be adhered to in relation to the management of soil at the site, prior to any use, removal, re-use, transport or storage.

In addition to satisfying the requirements of relevant NSW State legislation for the management of asbestos contamination, this management plan has been developed in accordance with the guidance provided in the National Environmental Protection (Assessment of Site Contamination) Measure (NEPM 1999 as amended 2013). The management plan has been developed to assess potential scenarios for relevant land uses (refer to Section 3) where asbestos fibres may become airborne and pose a potential risk to human health.

In accordance with NEPM (1999 as amended 2013) guidance; “remediation options which minimise soil disturbance and therefore public risk are preferred. Management of asbestos in situ is encouraged, which may include covering the contamination with uncontaminated fill or other protective or warning layers”.

Should soils at the site be considered for off-site disposal in the future they should be classified in accordance with NSW EPA Guidelines: Waste Classification Guidelines Part 1: Classifying Waste (2014).

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5 GENERAL REQUIREMENTS

The site supervisor is required to meet all of the defined project specifications as outlined by this document. If there is any confusion or uncertainty regarding any of the specification details, further enquiry should be made to rectify uncertainty prior to commencement of on-site works.

Any variations or unforeseen complexities that may result in an increase in costs to the contractor are required to be communicated to Joss for approval, prior to the cost being incurred. If the cost is incurred prior to communication with Joss, the cost may not be approved and as such may ultimately be the responsibility of the contractor.

Please note the contractor is not required to undertake sampling or analysis or provide environmental consulting advice for the waste classification of soils at the site.

The implementation of this ASMP is the responsibility of Joss. Joss may assign or delegate this responsibility to sub-contractors’/representatives. However, Joss retains overall responsibility for implementation of this ASMP and any changes required should the understanding of site conditions change.

Compliance with the guidance within this ASMP should be followed by all persons involved in works or other activities at the site that may result in the disturbance and/or excavation of soil or surface covering at the site.

6 ENVIRONMENTAL MANAGEMENT REQUIREMENTS

The following management requirements have been identified for works involving contaminated soils as specified by this document:

Occupational Health and Safety;

Site Specific Training;

Tool Box Meetings;

Personal Protective Equipment and Hygiene;

Isolation and Signage;

Monitoring, Inspection & Audits;

Identification of On-site Services;

Soil Management On-site;

Offsite Disposal of Soils;

Water Management;

Dust Suppression;

Background Air Monitoring

Use of Heavy Equipment;

Noise Monitoring;

Unexpected Contamination;

SMP Review; and

Reporting.

Management controls detailed in this plan should be implemented in accordance with the hierarchy of risk control, as outlined in Figure 1.

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Figure 1 - The hierarchy of risk control (Safe Work Australia 2011, Code of practice - How to manage work health and safety risks)

One or more of each of the principles listed in Figure 1 has been adopted for each of the aforementioned requirements and it is considered effective practice for combinations of one or more of the above control principals to be invoked at the Site.

In addition to the information provided within this management plan, further information for the assessment/management of asbestos contamination in soil is provided within NSW WorkCover Publication Managing Asbestos in or on soil (March 2014).

6.1 Occupational Health and Safety

Responsible party: All Parties

Workers in Australian workplaces have specific health and safety obligations. While at work, a worker should:

Take reasonable care for his or her own health and safety; Take reasonable care that his or her acts or omissions do not adversely affect the health and safety of

other persons; Comply, so far as the worker is reasonably able, with any reasonable instruction that is given by the

person conducting a business or undertaking to allow the person to comply with the NSW Work Health and Safety Act (2011); and

Cooperate with any reasonable policy or procedure of the person conducting a business or undertaking relating to health or safety at the workplace that has been notified to workers.

The Prohibition1 on asbestos under Clause 419 of the NSW Work Health and Safety Regulations (2011) must be

adhered to in relation to the management of soil at the site, prior to any use, removal, re-use, transport or storage.

All contractors, staff, workers or attendees to the site are required to undertake a site induction process that alerts them to site-specific risks.

1 Prohibitions under the NSW Work Health and Safety Act (2011) and as detailed in Clause 419 of the Work

Health and Safety Regulation (2011).

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A site specific safety plan and induction process should be in place for all site workers providing site specific information and site requirements including:

Risks associated with contaminated soil at the site;

Identification of potentially contaminated soil at the site;

Job Safety Analyses (JSA) or safe work method statements (SWMS) for tasks to be completed at the site;

Environmental Management Requirements (as listed within this document);

Works Specification;

Site Responsibilities;

Emergency Procedures;

Site Contact Details;

Key Personnel; and

Key Site Safety Requirements.

6.2 Site Specific Training

Responsible party: Joss Facility Management or contractor/site supervisor

Training and awareness of people working with contaminated soils at the site and specific tasks to be undertaken is the key to successful implementation of this plan. Site workers should undertake induction training prior to beginning work on site.

The induction training should include, but not be limited to, the following information:

Induction, toolbox meeting and training requirements;

The existence and content of this document;

Review of SWMS;

The content and requirements of the Site Safety Plan (including JSAs and Safe Work Procedures);

Nature and location of contaminants at the site;

Responsibilities under this management plan;

Controls and work practices which are required on site;

Other training requirements specific to the site; and

Incident reporting.

6.3 Tool Box Meetings


Toolbox meetings should be held onsite to provide information/training, as well as to outline changes to site management which may be applicable based on works schedule. As a minimum, it is recommended that a Toolbox meeting be held daily, with the minutes documented and available for review.

Discussion items could include:

Environmental components of SWMS; Environmentally sensitive areas – contaminated soil, sediment, erosion control, dust and noise; Waste management; Health and Safety issues raised; Incidents which have occurred; Changes to project requirements; and Other relevant topics of conversation.

6.4 Personal Protective Equipment and Hygiene

Responsible party: All Parties

It is possible that prolonged exposure to the reported contaminated soils may pose a health risk to construction/maintenance workers. Short term exposure (weeks rather than years) to adults is not likely to pose a risk, however, the health risks from longer term exposure is uncertain. Management requirements therefore adopt a conservative approach to protect all workers from worst case exposure scenarios.

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People working where contaminated soils or dusts may be present need to be provided with gloves, protective clothing and sturdy footwear (e.g. safety boots). Provision of personal protective equipment (PPE) is a requirement for those operating in controlled areas of the Site.

These requirements should be considered relevant for construction workers involved in development (excavation) works and/or future maintenance works at the site that involve disturbance of the soils and for workers involved in the maintenance of any landscaped areas (i.e. gardeners).

The site supervisor/contractor should adopt the following controls:

Smoking, eating or drinking shall not be permitted in construction areas and should only be undertaken in designated areas (i.e. In the vicinity of lunch room/site sheds or off-site);

Bathroom amenities should be provided (where practicable) and workers should utilise the provided amenities to wash hands and face – prior to eating, drinking or smoking and at the end of the day;

Workers should wash/clean safety boots prior to leaving the site;

Workers should utilise personal protective equipment in accordance with site procedures including but not limited to:

Tyvek suits (coveralls) and P2 particulate half face respirators should be available on site and are to be used in the event that dust generating activities are being undertaken (i.e. excavation/disturbance of soils);

Overalls/Long pants and shirts;

Hard Hat;

Safety boots;

Gloves;

Eye protection; and

UV Protection.

Additionally, it is recommended that site workers have a change of clothes and leave work clothes at the site to prevent the spread of contaminated soil outside the work place.

6.5 Isolation and Signage

Responsible party: Joss Facility Management or contractor/ site supervisor

An effective method for reducing the potential for exposure to contaminated soils and ACM by uncontrolled parties (e.g. general public or site personnel not directly involved in the works) is to isolate the site and thus limit contact with the contaminated soil and ACM management area only to persons provided with a specific site induction and inducted under this ASMP.

In addition to the above given the sensitive nature of the site, GreencappNAA recommend that the timing of works be considered (i.e. are undertaken at times outside of regular school operating hours such as school holidays or weekends).

Appropriate signs to warn of a construction zone and of the restricted area are mandatory.

The site supervisor/contractor shall utilise the following controls to ensure the site is isolated and controlled:

Prior to and during the works, access to the Site should be restricted with adequate barriers erected and warning signage made visible. Signs should be in accordance with AS1319-1994 Safety Signs for the Occupational Environment. For example, ‘Warning Asbestos Hazard’ or ‘Hazardous Materials Area, Authorised Personnel only’. This should include providing adequate security for after hours by the use of lockable fences/gates;

The Site boundary/work zone should be maintained during proposed works at all times. Any contractor working within the work zone should be inducted in accordance with this ASMP and undertake the works subject to its requirements;

Contractors should not enter the designated work zone without the prescribed PPE and the site supervisor should be aware of the number of contractors entering the work zone;

Upon exiting the designated work zone contactors should undergo dry decontamination; and Additional barriers should be erected around all excavated areas across the Site.

6.6 Monitoring, Inspection & Audits


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Regular monitoring of activities (i.e. dust generation, soil movement, equipment etc.) should also be undertaken with risk mitigation measures implemented as required.

Inspections should be undertaken during site work activities to assess if the requirements of this SMP are being implemented. The inspections will also be completed to assess for environmental hazards and risk to sensitive receptors, which may require risk mitigation measures to be implemented. It is recommended that inspections be undertaken daily, weekly and monthly, with the results documented and maintained for review.

Regular audits of the appropriate records and required documents should also be conducted to ensure all compliance documentation is being documented and maintained for review.

6.7 Identification of On-site Services


To avoid the potential for damage to underground services at the site, prior to undertaking intrusive works (i.e. excavation works) at the site a dial before you dig (DBYD) request for underground services plans should be made.

Proposed excavation locations should be marked out and a survey of underground services and utilities be undertaken by a Telstra accredited subcontractor to assess for the presence of on-site services.

Should on-site underground services plans exist it is the responsibility of Joss and/or the site supervisor to make these plans available to the contractor where necessary and the responsibility of the contractor to carefully review all plans prior to undertaking earthmoving activities.

6.8 Soil Management On-site (If Required)


It should be noted that based on the presence of potentially friable ACM within soils at the site any works that have the potential to disturb the soils (i.e. excavation works) should only be undertaken by a Class A licensed contractor.

The requirements of the Prohibition on asbestos must be adhered to with regards to any works involving soils at the site. The prohibition would not apply to soils that a competent person has determined:

a) Does not contain any visible ACM or friable asbestos, or b) If friable asbestos is visible—does not contain more than trace levels of asbestos determined in

accordance with AS 4964:2004 (Method for the qualitative identification of asbestos in bulk samples).

Potential environmental impacts may be associated the following works involving soils at the site:

Excavation and stockpiling;

On-site movement of soil;

On-site retention of soil; and

Importation of fill.

To minimise potential environmental impacts all work should be conducted in accordance with relevant NSW EPA guidance and that provided within this plan. The following procedures should be carried out prior to, during and following the completion of any soil excavation and/or surface cover disturbance at the site.

Prior to Commencement:

Contractors and workers should be made aware of the presence of soil contamination and be familiar with the requirements of the ASMP; and

Site supervisor should prepare a site-specific Environmental and Health & Safety Plan covering their activities at the site, for any anticipated environmental and/or human health impacts, before any works can commence.

During Excavation Works:

Excavated soil should be stockpiled securely (i.e. the site should be fenced) and isolated on-site to prevent unauthorised access to the soils (refer Section 5.5);

Soil stockpiles should be managed in accordance with best practice NSW EPA Guidelines in order to prevent the loss of soil caused by wind (as dust) or stormwater run-off (as leachate or sediment), including protection of nearby stormwater drains, sumps and waterways; and

The source area of stockpiled soil should be noted on a plan for reference to ensure the movement of contaminated soil is tracked.

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Following Completion of Excavation Works:

Equipment used for excavation of potentially contaminated soil should undergo a process of decontamination prior to leaving the site.

6.8.1 Excavation and Stockpiling

Excavations of depths greater than 1.5 m below ground level can be considered to be confined spaces due to the risks of excavation collapse, possible vapour/gas build up and the difficulty of exiting the space.

Trenching and excavation works should be conducted in accordance with standard safety procedures including compliance with the requirements of the NSW Work Health & Safety Regulation (2011) and associated NSW WorkCover Authority and Safe Work Australia guidance.

With respect to the potential for encountering contaminated soils, the site supervisor shall utilise the following controls:

During excavation works potentially contaminated soils may be stockpiled on site, with reference to the stockpiling of the soils GreencapNAA recommend the following:

Minimise the number and size of stockpiles where practicable;

Movement of stockpiles should be tracked to prevent cross contamination of stockpiles;

Access to stockpiles should be controlled. Members of the public should not have any access to the stockpiles of either contaminated/excavated soils or clean fill;

Stockpiles are recommended to be stored on plastic sheeting and/or an impermeable surface and controls implemented to control the potential for dust generation and or/run-off (refer Sections 6.10 and 6.11 );

Excavated soils should be segregated and stockpiled with soils of similar soil types to avoid the potential for cross contamination. Should the potential for the excavation of 2 or more soil domains (i.e. fill and natural soils) it is recommended that the segregation process is undertaken with the direction of a suitably qualified environmental consultant who can assist with segregating the contaminated soil, with the aim of reducing the quantity of contaminated soil that requires further management and/or disposal off-site;

The locations of the stockpiles need to be carefully considered and the choice of location should take into account the following factors:

Distance to nearest drainage line (e.g. storm water) and potential for contaminated soils and/or leachate to leave the site;

Stockpiles are to be located away from the edge of trenches/excavations.

Protection from winds;

Room for storage of clean soil;

Ability to restrict access (i.e. no public access);

Vehicle access to be possible without disturbing nearby soils / grassed areas; and

General site access is not to be compromised by the location of stockpiled soil, excavations or plant equipment.

6.8.2 Onsite Movement of Soil

Movement of soil at the site should be tracked to ensure its origin, contamination status and fate is documented. Soil tracking forms are to be completed by the contractor and checked by the site supervisor.

The source and destination of soil moved around the site or off-site can be logged using references to development features, or a site grid across the site. The appearance of soils encountered during excavation should be noted and checked to confirm they are consistent with those materials noted in the site assessments. The soil appearance checks should be conducted by the site supervisor, or delegated to a suitably qualified environmental consultant.

Where any materials of unexpected appearance or odour (inconsistent with materials noted in the previous assessments) are encountered, they should be stockpiled separately for further assessment (refer Section 6.14).

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6.8.3 Importation of Fill

Fill soils imported to site for use as a capping layer and/or structural fill/backfilling should be accompanied by appropriate documentation to assure that they meet NSW EPA, NEPM (1999 as amended 2013) and site criteria (e.g. geotechnical) to ensure that contaminated soils are not imported to site.

6.9 Offsite Disposal of Soils and/or Asbestos Waste

Responsible party: Contractor/site supervisor and environmental consultant

GreencapNAA understand that soil is not currently proposed to be removed from site, however this management plan provides guidance for the future removal of soil.

Should soils be considered for off-site disposal in the future they should be classified in accordance with NSW EPA Guidelines: Waste Classification Guidelines Part 1: Classifying Waste (2014).

Asbestos is classified for disposal in NSW as a ‘Special Waste’ and should be disposed of in accordance with NSW WorkCover and NSW EPA requirements.

Generators of special waste do not need to make any further assessment of their waste if it falls within the definitions of special wastes below.

The only exception to this is where special waste is mixed with another waste (e.g. contaminated soils) in these circumstances; the waste must be classified, and managed as both of those classifications.

The contractor prior to movement of any soils contaminated with ACM should:

Should soils be considered for bulk excavation and/or disposal off-site, works should be undertaken in accordance with relevant NSW WorkCover guidance and the management requirements associated with this ASMP.

If soils at the site require disposal off-site, they should be classified in accordance with NSW EPA Guidelines and disposed to a landfill licensed to accept the category of waste.

Soils to be removed and disposed off-site in accordance with the guidance provided in NSW WorkCover Publication Managing Asbestos on or in soil (2014) including the following;

o Waste must be stored on the premises in an environmentally safe manner. o Non-friable asbestos material must be securely packaged at all times. o Friable asbestos material must be kept in a sealed container. o Asbestos-contaminated soil must be wetted down. o All asbestos waste must be transported in a covered, leak-proof vehicle. o Asbestos waste must be disposed of at a landfill site that can lawfully receive this waste. Always

contact the landfill beforehand to find out whether asbestos is accepted and any requirements for delivering asbestos to the landfill.

Liaise with the Environmental Consultant to assess classification details for stockpiled soil; Keep copies of asbestos waste disposal receipts for inspection by WorkCover, the EPA or the local council; Keep accurate records of volumes, types and destinations of contaminated soils; and Ensure landfill dockets and completed waste transport certificates are retained forwarded to all relevent

parties following disposal.

6.10 Water Management


6.10.1 Surface/Stormwater Management

Contaminated soil particles and/or ACM can leave the site during rain events or excessive water flow if soil particles/leachate is picked up by the water and carried into the local stormwater system. Stormwater is not treated prior to discharge into waterways, if contaminated stormwater enters a drainageline or stormwater drainage system, it will eventually discharge into an adjacent waterway and pollute it.

The type of sediment controls suitable for a particular situation depend on the nature of the site, in terms of such factors as rainfall patterns, soil type and topography. These factors need to be taken into account when selecting appropriate controls and ensuring that designs are adequate.

There are a number of ways of minimising sediment run-off, examples of control measures to be utilised are provided below.

The site supervisor shall utilise the following controls:

Keep soil disturbance to a minimum where practicable;

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Where practicable schedule excavation works for periods of the year when lower rainfall is expected;

Do not allow disturbed soils to be exposed to excessive volumes of water (e.g. from overland water flows or rainfall);

Cover and/or bund exposed soils to minimise the potential for run-off;

Locate stockpiles away from drainage points;

Use straw bales or silt fences to filter particulate run-off;

Ensure that stockpiles are fully removed and that minimum loose soil remains; and

Minimise truck and vehicle movements in areas where soil has recently been disturbed (so that minimal soil is carried off-site in truck tyres via tracking).

6.10.2 Wastewater Disposal

Where off-site disposal of wastewater is necessary (i.e. water within excavations following heavy rain or groundwater inflow), it should be undertaken in accordance with NSW EPA requirements.

Wastewater should not be discharged into stormwater or sewer drains without authorisation from the relevant authorities.

6.11 Dust Suppression

Responsible party: Joss Facility Management and contractor/site supervisor

Dust generation is a potential transport pathway for contaminated soils and asbestos fibres and should be suppressed where practicable.

The contractor shall utilise the following dust suppression controls:

Prevent the generation of dust in preference to applying dust suppression measures. Ensure in the project schedule that the area of cleared land is minimised during the drier months of the

year, when dust generation is at its greatest. Application of a fine water mist (where required) to exposed soil surfaces (including stockpiles) to keep

these soils moist. However, care should be taken not to use excessive amounts of water as this can result in an increased potential for storm water run-off contamination to occur (see Section 5.10);

Cover soil stockpiles located on the Site to minimise the potential for the generation of airborne dust from these stockpiles (e.g. with plastic sheeting);

Soil should be stockpiled on plastic sheeting and weighted down to aid dust suppression. Application of a physical barrier to airborne dust (e.g. shade cloth) on the work area fence if required; and Contractors operating construction equipment should be instructed to operate heavy machinery in a

manner that minimises the amount of dust generation, particularly when loading soil into trucks or on windy days.

It should be noted that, at the discretion of a suitably qualified environmental consultant, in the case of extreme weather conditions such as strong winds excavation works should not be undertaken.

6.12 Background Air Monitoring

Responsible party: Environmental consultant

Air monitoring stations should be established at locations surrounding the works area to monitor for free asbestos fibres. If any asbestos fibres are recorded above reporting or background limits then works shall cease at the site until further management requirements are developed and implemented to control the work area.

As a minimum it is recommended that background air monitoring be conducted at the four (4) designated boundaries of the work zone and/or boundaries of the site in proximity to populations of concern, as determined by the scope of works and specific site conditions assessed at the start of each day (e.g. weather conditions / wind direction)

Visual assessment of air quality will be undertaken. If it is considered that dust is being generated unnecessarily, then works will be halted until dust preventative measures can be implemented (as detailed in Section 6.11).

Air Monitoring should be undertaken by a WorkCover Licensed Asbestos Assessor with sampling and analysis conducted by a NATA accredited laboratory in accordance with the method as prescribed in Safe Work Australia Guidance Note: Membrane Filter Method for Estimating Airborne Asbestos Fibres [NOHSC: 3003(2005)].

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6.13 Use of Heavy Equipment


The use of heavy equipment such as bobcats and excavators and trucks can increase the potential for cross-contamination to occur.

The contractor shall utilise the following controls:

Minimise the effect of cross-contamination from tyres/equipment/boots to clean areas of the site and/or off-site;

Maintain gravel/hard-stand access roads so as to prevent regress of contaminated soils and prevent dust; Clean equipment regularly and thoroughly; During excavation works, efforts should be made to minimise dust generation by adopting dust

suppression methods (i.e. wetting down); Excavator operators should keep cabin doors closed and recirculate the internal air; Nominate areas of traffic management; and At the completion of works and/or prior to plant leaving the designated work zone it should be inspected

and deemed free of ACM so far as reasonably practicable. Transport of contaminated soils off-site should be minimised wherever practicable the contractor may

need to consider washing down trucks and/or a street sweeper should soils be observed to be transported off-site attached to vehicles.

Consideration of plant and traffic safety hazards posed to other workers in the vicinity of operating machinery who are using hearing protection should be factored into the toolbox meeting and appropriate safety controls formulated. This may include provision of visual warning aids (e.g. flashing lights) and control of machinery operation under direct confirmation that inspecting personnel are not in harm’s way as well as warning beepers on operating plant.

6.14 Noise Monitoring


Where possible noise generated by construction works should be managed to limit the impact on the surrounding community. Noisy works should only be undertaken during the normal working hours, which are generally Monday to Friday between 7:00 am and 6:00 and Saturday and public holidays between 9:00 and 3:00, but will be as designated in the planning/construction permit in accordance with local council requirements.

Noise should be managed according to EPA legislation and relevant Council requirements. This should include the following:

Deliveries should be scheduled so that disruption to local community is minimised and conducted within normal business hours;

Noisy equipment to be contained within the site; Site fence to be constructed; Noise monitoring should be conducted by a suitably qualified contractor on a quarterly basis; Complaints should be managed and dealt with efficiently; and If works are required to be performed out of normal business hours, additional measures should be

implemented for identification, management and reduction of noise, to reduce impact on surrounding community.

6.15 Unexpected Contamination

Responsible parties: Joss Facility Management, contractor/site supervisor, environmental consultant

In the event that significant unexpected contamination is identified (i.e. odorous or stained soil, the presence of underground storage tanks (USTs) and/or significant friable ACM) during the works, the following steps should be undertaken to manage the contamination:

Stop work;

Report suspected contamination to site supervisor;

Isolate area with a physical barrier;

Assume the area is contaminated until an assessment proves otherwise; and

Notify a suitably qualified environmental consultant to enable them to assess the contamination.

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As a result of the assessment, additional remedial works may be required or additional control measures implemented for the ongoing work.

6.16 ASMP Review

Responsible parties: Joss Facility Management, site supervisor

A mechanism for ensuring ASMP compliance and surveillance should be implemented by Joss. This may include the following components:

Appointment of a specific representative (e.g. project manager or site manager) who has responsibility for controlling works at the site (preferably experienced with working on contaminated land sites;

Maintaining a log of excavation work carried out, which includes confirmation that in each case, the contractor and their sub-contractors have met the requirements outlined in this ASMP;

Maintaining a log that records any breaches of the requirements of the ASMP and outlines action taken to prevent recurrence of the breach;

Site inspections by the contractor to confirm compliance with the requirements of the ASMP by site workers;

Ensuring no site workers enter the areas where contaminated soils may be encountered without being advised of the requirements of this plan; and

Retaining results of any atmospheric monitoring.

This ASMP was prepared based on information provided by Joss and may need to be updated pending the abatement works and/or findings of further assessment works or proposed works at the site.

The ASMP should be revised and reviewed by a competent person following changes to the current understanding of site contamination conditions, work requirements, legislation, or construction scope. The ASMP should be revised to reflect changes and provide adequate procedures for ensuring continued worker, public and environmental safety and compliance with regulatory requirements and industry best practice.

6.17 Reporting


The site supervisor should maintain documentation demonstrating that the requirements of this ASMP have been met.

Such documentation is likely to include:

Site survey levels; Soil tracking records; Location of potentially contaminated soils at the site following any change in site conditions; Volumes of soil removed from and/or imported to the site (please note that a copy of laboratory analyses

reports of wastes and transport certificate/s must be retained for a period of at least two years); Evidence that imported fill meets NSW EPA guidance and site criteria for on-site retention; Evidence that excavated fill was disposed of in accordance with NSW EPA/WorkCover guidelines; Records of regular workplace inspections by site representatives; Records of any workspace atmospheric dust/air monitoring; Records of inductions given to site workers; and Photographic records of works, including excavation of contaminated soils and installation of

barrier/marking layers.

7 ONGOING MANAGEMENT

7.1 Clearance Certificate/Site Validation

Responsible parties: Joss Facility Management, environmental consultant

Following asbestos removal works at the site prior to the construction of the proposed capping layer and/or further management measures, the surface should be inspected by a licensed asbestos assessor to assess that visible ACM has been removed from the surface (top 10 cm of soil) so far as reasonably practicable.

Following the provision of clearance documentation (and pending observations during the asbestos removal works), additional non-intrusive works proposed to be undertaken at the site including the construction of the proposed capping layer would not be considered asbestos related works and would not require a licensed contractor.

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A copy of the clearance certificate / validation report detailing the results of the clean-up measures undertaken at the site should be retained in conjunction with this ASMP.

There is potential that following abatement works at the site this management plan may require to be revised as detailed in Section 6.16.

7.1.1 Asbestos Register

Responsible parties: Joss Facility Management

Depending on the results of the asbestos removal works at the site, should the presence of sub-surface ACM be suspected in soils GreencapNAA recommend that the location and nature of the asbestos contamination be added to the existing asbestos register for the wider School site.

The existence of this management plan should be referenced within the entry in the asbestos register.

7.1.2 Memorandum on Title (MOT)

Responsible parties: Joss Facility Management

It is important to ensure that owners and future purchasers of a site are aware of the presence of asbestos so that they can apply appropriate precautions if/when there is potential that land is disturbed or redeveloped.

In NSW, the presence of buried asbestos at concentrations above the NEPM (1999 as amended 2013) health screening levels, should be noted on the Section 149 planning certificate issued under the Environmental Planning and Assessment Act 1979 or be captured on the land title.

Depending on the results of the removal works and/or further assessment there is potential that a MOT may be required.

7.2 Surface Covering/Capping Layer


The presence of bonded ACM in the form of asbestos cement sheet debris and potentially friable asbestos in the form of millboard debris were observed within surface soils at the site. The ACM observed was considered likely to be associated with the presence of building debris observed in this area of the site. GreencapNAA considered that the building debris (including ACM) was potentially surfacing from in-situ soils and that further ACM may be present in the subsurface in this area (potentially associated with the former use of the site as a landfill).

Pending the proposed asbestos removal works to be undertaken and/or as a result of further assessment works at the site further management of the soils may be required to manage the potential risks posed by the contamination to users of the site (e.g. employees, students and maintenance contractors).

In situ management primarily involves the isolation of the contaminated area with barriers and covers so that it cannot be readily disturbed and therefore will not generate airborne fibres.

Following the proposed abatement works (or future works at the site which may expose soils), potentially contaminated in-situ soils across the site should be covered with a capping layer to prevent future site users accessing the soil by implementing one or more of the following options:

Maintain a hardstand comprising concrete, asphalt or similar impermeable barriers; or Placement of geofabric membrane and 200 mm layer of imported validated clean fill material overlying

impacted soils in accessible outdoor areas not covered with hard-stand; GreencapNAA generally recommend that 200 mm of fill/top-soil be used as a cover on top of the

geofabric membrane as the cover can be gradually removed by wind, rain, animals digging and other methods that may expose the geofabric membrane and the underlying contaminated soil. However the thickness of fill could be reviewed provided management procedures are put in place for the regular inspection/maintenance of the surface covering;

As an additional control good grass cover should be maintained where practicable overlying the capping layer for the long term management of soil and to minimise dust generation on-site and assist with preventing erosion/human disturbance;

An ASMP is a recommended element whenever a covering barrier is employed. This provides additional assurance that the protective measures will be maintained and that potentially affected parties will be kept informed of potential risks;

GreencapNAA recommend ongoing assessment of the condition of the surface covering/capping layer be undertaken. Should the integrity of the surface covering/capping layer be impacted, further management controls may be required.

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7.2.1 Imported Fill Material

Responsible Parties: Joss Facility Management, contractor/site supervisor

GreencapNAA recommend that any fill soils imported to site for use as a capping layer are accompanied by appropriate documentation to assure that they meet general solid waste material (NSW EPA fill material criteria) and site criteria (e.g. geotechnical) to ensure that contaminated soils are not imported to Site (as detailed in Section 6.8.3).

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