environmental audit report - epa victoria · pty ltd to undertake an environmental audit for the...

INFORMATION REGARDING ENVIRONMENTAL AUDIT REPORTS August 2007

VICTORIA'S AUDIT SYSTEM An environmental audit system has operated in Victoria since 1989. The Environmenf Profecfion Acf 1970 (the Act) provides for the appointment by the Environment Protection Authority (EPA Victoria) of environmental auditors and the conduct of independent, high quality and rigorous environmental audits.

An environmental audit is an assessment of the condition of the environment, or the nature and extent of harm (or risk of harm) posed by an industrial process or activity, waste, substance or noise. Environmental audit reports are prepared by EPA- appointed environmental auditors who are highly qualified and skilled individuals.

Under the Act, the function of an environmental auditor is t o conduct environmental audits and prepare environmental audit reports. Where an environmental audit is conducted to determine the condition of a site or its suitability for certain uses, an environmental auditor may issue either a certificate or statement of environmental audit.

A certificate indicates that the auditor is of the opinion that the site is suitable for any beneficial use defined in the Act, whilst a statement indicates that there is some restriction on the use of the site.

Any individual or organisation may engage appointed environmental auditors, who generally operate within the environmental consulting sector, t o undertake environmental audits. The EPA administers the environmental audit system and ensures its ongoing integrity by assessing auditor applications and ensuring audits are independent and conducted with regard t o guidelines issued by EPA.

AUDIT FILES STRUCTURE Environmental audit reports are stored digitally by EPA in three parts: the audit report (part A), report appendices (part B) and, where applicable, the certificate or statement of environmental audit and an executive summary (part C). A report may be in colour and black-and-white formats. Generally, only black- and-white documents are text searchable.

Report executive summaries, findings and recommendations should be read and relied upon only in the context of the document as a whole, including any appendices and, where applicable, any certificate or statement of environmental audit.

AUDIT REPORT CURRENCY Audit reports are based on the conditions encountered and information reviewed at the time of preparation and do not represent any changes that may have occurred since the date of completion. As i t is not possible for an audit t o present all data that could be of interest t o all readers, consideration should be made to any appendices or referenced documentation for further information.

When information regarding the condition of a site changes from that at the time an audit report is issued, or where an administrative or computation error is identified, environmental audit reports, certificates and statements may be withdrawn or amended by an environmental auditor. Users are advised t o check EPA's website to ensure the currency of the audit document.

PDF SEARCHABILITY AND PRINTING EPA Victoria can only certify the accuracy and correctness of the audit report and appendices as presented in the hardcopy format. EPA is not responsible for any issues that arise due to problems with PDF files or printing.

Except where PDF normal format is specified, PDF files are scanned and optical character recognised by machine only. Accordingly, while the images are consistent with the scanned original, the searchable hidden text may contain uncorrected recognition errors that can reduce search reliability. Therefore, keyword searches undertaken within the document may not retrieve all references to the queried text.

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FURTHER I N FORMATION For more information on Victoria's environmental audit system, visit EPA's website or contact EPA's Environmental Audit Unit.

Web: www.epa.vic.clov.au/envaudit

Email: [email protected]

http://www.adobe.com

I( I I I( I I I I1 Ill I Ill1 41 544-1-C

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I1

- - ENVIRONMENTAL PROTECTION ACT 7970

SECTION 57AA

STATEMENT OF ENVIRONMENTAL AUDIT

I, Philip Mulvey of Environmental & Earth Sciences Pty Ltd, a person appointed by the Environment Protection Authority ("the Authority") under the Environment Protection Act 1970 ("the Act') as an environmental auditor for the purposes of the Act, having:

1 been requested by Eric Schwab of Schwab Constructions Pty Ltd to issue a statement of environmental audit in relation to the site located at 231 Mc Kinnon Road, Mc Kinnon, Victoria ("the site") owned / occupied by Schwab Constructions Pty Ltd;

2 had regard to, amongst other things, i. guidelines issued by the Authority for the purposes of Section 57AA of the Act; ii. the beneficial uses that may be made of the site; and iii. relevant State environment protection policieshndustrial waste management policies, namely: State Environment Protection Policy (1997) - Groundwaters of Victoria; State Environment Protection Policy (1 997) - Wuters of Port Phillip Buy; State Environment Protection Policy (1 98 1, amendments 1988) - The Air Environment; in making a total assessment of the nature and extent of any harm or detriment caused to, or the risk of any

possible harm or detriment which may be caused to, any beneficial use made of the site by any industrial processes or activity, waste or substance (including any chemical substance); and

3 completed an environmental audit report in accordance with Section 57AA(2) of the Act, a copy of which has been sent to the Authority.

HEREBY STATE that I am of the opinion that: 1. The site is suitable for the following beneficial uses subject to the conditions attached thereto: the site

and the soil are safe for high density residential use including use as a residential retirement develop men t.

The condition of the site is detrimental or potentially detrimental to any (one or more) beneficial uses of the site. Accordingly, I have not issued a Certificate of Environmental Audit for the site in its current condition, reasons of which are presented in the environmental audit report and are summarised as follows: sulfate levels in soil may corrode concrete. Lead levels in soil may in the north west of the site exceed criteria for single dwelling houses.

This statement forms part of environmental audit report (Environmental & Earth Sciences Pty Ltd Audit report of 231 Mc Kinnon Road, Mc Kinnon, VIC, Report Number 200022, June 2000). Further details regarding the condition of the site may be found in the environmental audit report.

Soil is the foundation of life [200022/statement No 0201

I

New Zealand PO Box 35853

Browns Bay Audtland NZ

Ph: 64 9 476 4483 Fax: 64 9 476 4485

Audit Report

231 McKinnon Road,

McKinnon Vic

Report No 200022

Report to Schwab Constructions Pty Ltd

June 2000

Environmental & Earth Sciences Pty Ltd

41544-1-A

Sydney PO Box 380

North Sydney NSW 2059

Ph: 61 2 9922 1777 Fax: 61 2 9922 1010

Melbourne PO Box 51 14

Garden City VIC 3207

Ph: 61 3 9646 8760 F ~ X : 61 3 9646 8758

ACN 002 347 971

4 July 2000

Schwab Constructions Pty Ltd 94 Union Street East Brighton VIC 3187

Environmental &

Earth Sciences Pty Ltd

Contamiiiarzt Soil Scierzce 0 Hydrogeology

Attention: Mr Eric Schwab

Dear Eric

Re: Audit report for site located 231 McKinnon Road, McKinnon, Victoria.

Please find attached the audit report for the site located 23 1 McKinnon Road, McKinnon, Victoria.

Should you have any queries regarding information presented in this report, please do not hesitate to contact the undersigned.

Yours sincerely Earth Sciences Pty Ltd

Rep2000/200022

Phone: (M) 9922 1777 Fax: (02) 9922 1010 ‘The Coal Loader” Balls Head Drive

Waverton NSW 2060 Po Box 380

North Sydney NSW 2059 Soil is the Foundation of Life

Phone: (03) 9646 8760 Fax: (03) 9646 8 7 9

378 Ross Street Port Melbourne VIC 3182

PO Box 1090 St Kilda VIC 3182

1.0 INTRODUCTION ............................................................................................................ 1 2.0 BASIS OF REVIEW ........................................................................................................ 2 3.0 SITE LOCATION DETAILS ........................................................................................... 4

3.1 Site definition ................................................................................................................ 4 3.2 Identification .................................................................................................................. 4 3.3 Site description .............................................................................................................. 4

. 3.4 Proposed development ................................................................................................... 6 4.0 SITE HISTORY - CONTAMINANTS OF CONCERN ................................................. 8

4.1 Site history ..................................................................................................................... 8 4.2 Potential contaminants of concern ................................................................................. 9

SOIL STRATIGRAPHY AND HYDROGEOLOGY .................................................... 10 5.1 Geology . Soil stratigraphy ......................................................................................... 10 5.2 Hydrogeology .............................................................................................................. 11

& CO PTY LTD ....................................................................................................................... 12 6.1 Investigation works and sampling collection .............................................................. 12 6.2 Field observations ........................................................................................................ 12 6.3 Laboratory analysis undertaken ................................................................................... 14 6.4 Site assessment cntena ................................................................................................ 14 6.5 Soil Laboratory Results ............................................................................................... 14 6.6 Quality Assurance / Quality Control ........................................................................... 15 6.7 Consultant’s conclusions ............................................................................................. 16 6.8 Auditor’s analysis ........................................................................................................ 16

UNDERTAKEN BY ATMA ENVIRONMENTAL PTY LTD ............................................... 18 Site Assessment Cntena .............................................................................................. 18 Underground Storage Tank ......................................................................................... 18 Boreholes across the site .............................................................................................. 20

7 -3.1 Drillings undertaken ............................................................................................. 20 7.3.2 Field Observations ................................................................................................ 20

5.0

6.0 OCTOBER 1997 - INVESTIGATION CONDUCTED BY BEVERIDGE WILLIAMS

. .

7.0 APRIL TO MAY 1999 - REMEDIATION AND INVESTIGATION WORKS

. . 7.1 7.2 7.3

7.3.3 Sampling methodology ......................................................................................... 20 Laboratory analysis undertaken ............................................................................ 22

7.3.5 Laboratory Results ................................................................................................ 22 Excavation of impacted materials in the vicinity of BH20 and BH2 1 ................. 24

7.3.4

7.3.6 7.4 Bioremediation of hydrocarbon impacted materials ................................................... 24

7.5 Consultant’s conclusions for this stage of works ........................................................ 25

CONDUCTED BY ATh4A ENVIRONMENTAL PTY LTD .................................................. 26 Additional works requested by the auditor .................................................................. 26 Complementary investigation works undertaken ........................................................ 26

8.2.1 Sampling methodology ......................................................................................... 26 8.2.2 Samples sent to laboratory for analysis ................................................................ 28 8.2.3 Laboratory results ................................................................................................. 28

Consultant’s conclusions for this stage of investigation ............................................. 28 9.0 VALIDATION WORKS UNDERTAKEN BY ATMA ENVIRONMENTAL PTY LTD ...... 29

9.1 Sampling protocol ....................................................................................................... 29 9.2 Field quality assurance and quality control ................................................................. 29 9.3 Laboratory quality assurance and quality control ........................................................ 30 9.4 Conclusion on QA/QC for soils analysis ..................................................................... 31

10.0 AUDITOR’S ANALYSIS FOR THE REMEDIATION AND INVESTIGATION WORKS UNDERTAKEN ........................................................................................................ 32 1 1 . 0 AUDITOR’S INSPECTION AND OPINION ................................................................ 34 12.0 LIMITATIONS ............................................................................................................... 35 1 3.0 ABBREVIATIONS ........................................................................................................ 36

8.0 11 MAY 2000 . ADDITIONAL SOIL AND GROUNDWATER SAMPLING

8.1 8.2

8.3 QUALITY ASSURANCE / QUALITY CONTROL FOR THE REMEDIATION AND

APPENDIX A: APPENDIX B:

APPENDIX C: APPENDIX D:

APPENDIX E:

APPENDIX F:

BEVERIDGE WILLIAMS AND CO PTY LTD’S BOREHOLE LOGS BEVERIDGE WILLIAMS AND CO PTY LTD’S ANALYTICAL AND QNQC LABORATORY TRANSCRIPTS ATMA ENVIRONMENTAL PTY LTD’S BOREHOLE LOGS ATMA ENVIRONMENTAL PTY LTD’S ANALYTICAL AND QNQC LABORATORY TRANSCRIPTS ATMA ENVIRONMENTAL PTY LTD’S LETTER DATED 11 MAY 2000 JOHN CLAYTON AND ASSOCIATES LETTER DATED 3 MAY 2000

Philip Mulvey, Victorian and NSW EPA accredited auditor of Environmental & Earth Sciences Pty Ltd was requested on 27 March 2000 by Eric Schwab of Schwab Constructions Pty Ltd to undertake an Environmental Audit for the property at 23 1 McKinnon Road, McKinnon, Victoria. On this basis a Statement of Environmental Audit has been issued, stating that the property is suitable for medium to high density residential use. Beveridge Williams & Co Pty Ltd undertook the preliminary investigation for this site, whereas Atma Environmental Pty Ltd undertook the environmental site investigation and remediation works, including groundwater investigation.

Rep2000Nictorid200022 1

This audit has been undertaken to comply with the Minister’s direction No.1 under Section 12(2)(a) of the Planning and Environmental Act 1987 and the Victorian EPA guidelines, in particular the Victorian EPA (1 992) - Guidelines for environmental auditors contaminated land, Issue of certificates of environmental audit WM 914 4 May 1992.

The following report and information was reviewed in conjunction with the current assessments:

- Atma Environmental Pty Ltd (25 May 1999) -Environmental Site Assessment and Remediation: 231 McKinnon Road, McKinnon, Victoria; and

- Atma Environmental Pty Ltd (1 1 May 2000) -Re: Contaminated Land Audit Issues.

A previous investigation was conducted at this site and a copy was inserted in the first above mentioned document:

- Beveridge Williams and Co Pty Ltd (October 1997) - Contamination assessment of232 McKinnon Road, McKinnon, reference 0 8 1 05.

All available information was compared to relevant guidelines for an investigation of this nature. Publications consulted included:

- Australian and New Zealand Environment and Conservation CounciVNational Health and Medical Research Council (1 992) -Australian and New Zealand guidelines for the assessment and management of contaminated sites;

- Australian Standard AS4482.1 (1997) - Guide to the sampling and investigation of potentially contaminated soil. Part I : Non-volatile and semi-volatile compounds;

- Dutch Ministry of Housing, Spatial Planning and the Environment (1 994) - Environmental quality objectives in the Netherlands;

- EPA Publication 448 (May 1995) - Classification of Wastes; - National Environmental Health F o m (1 998) - Health based soil investigation levels; - Victorian EPA (1992) - Guidelines for environmental auditors contaminated land, Issue

- Draft State Environment Protection Policy (1998) (Contaniinated Land) -Preventing

- State Environment Protection Policy (1997) - Groundwaters of Victoria; - State Environment Protection Policy (1 997) - Waters of Port Phillip Bay;

of certificates of environmental audit w1M 91/14 May 1992;

and Managing Contaminated Land, September 1998;

2

- Victorian EPA (1 998) - Groundwater and contaminated land auditing; - Cook, N and Hendershot, W H (1 996) - The problem of establishing ecologically-based

- Sauve, S, Cook, N, Hendershot, W H, and Mc Bride, M. (1996) -Linkingplant tissue concentrations and soil copper pools in urban contaminated soils -Environmental Pollution -Vol94. No 2, pp 153-157; and

soil quality criteria: the case of lead - Can. J. Soil Sci 76:335-342;

- Wang, W. (1992) - Use ofplants for the assessment of environmental Contaminants - reviews of environmental Contamination and toxicology - Vol 126 - Springer-Verlag New York Inc.

3

3.1 Site definition

The site is located at 23 1 McKinnon Road, McKinnon, Victoria (Figure 1) within the Glen Eira City Council. It is described as being part of Dendy’s Crown Special Survey, Parish of Moorabbin, County of Bourke.

3.2 Identification

Local government authority: Property identification:

Property address: Ownership:

Environmental Consultants:

Proposed use: Current Zoning: Proposed Zoning: Size:

Glen Eira City Council Dendy’s Crown Special Survey, Parish of Moorabbin, County of Bourke, Vol. 9442 Fol. 825 and Vol. 6377 Fol. 228. 23 1 McKinnon Road, McKinnon, Victoria Schwab Constructions Pty Ltd Contact person: Eric Schwab Atma Environmental Pty Ltd Beveridge Williams and Co Pty Ltd High density residential retirement development Commercial Residential Approximately 11 l m x 76m thus 8 436 m2 -

3.3 Site description

The site is rectangular in shape and approximately 1 1 lm (north-south) by 76m (east-west). The site is orientated in a north-south direction.

At the time of the auditor’s inspection (13 April 2000), the 3-storey retirement village building was complete, whereas the interior of this building was still under construction. There was one small brick building of approximately 80 m2 in area located on the south west comer, originating fi-om the site’s previous use.

4

Locality Plan

Title: . Locality Plan

231 McKinnon Road, McKinnon, Vie.

Client SCHWAB Construction P t y Ltd

1 Drawn: TJ Project Manager: sc Approved: Date: Apr.00

Fig . ....._____.

ACN 002 347 971

Environmental &

Earth Sciences

The site has a fall of approximately 3.3 metres fiom the south west comer down to the north west comer of the site. Soil which has been excavated for construction purposes has been removed or spread along the northern edge of the site, creating a steeper north eastern slope in the north eastern section of the property.

There are no surface water bodies present on the site. Storm water drains are located at the centre of the property, which direct into stormwater drains water on the periphery of the property. The closest surface water body is Elster creek / drain which is located approximately 2.25 kilometres to the west of the site. Elster Creek flows into Port Phillip Bay which is approximately 5.2 kilometres west of the site.

Adjacent land uses include residential housing to the north and west, a hotel to the east, and commercial properties to the south. A petrol station is located directly opposite the site south of McKinnon Road.

The main features of the site are presented in Figure 2.

In Atma Environmental Pty Ltd's environmental assessment report (May 1999), the field inspection reported no hazardous substances in connection with the site's previous usage (undeveloped area and vacant building). One 5 000 L underground petrol storage tank was located near the disused brick building. An associated bowser station (pump removed) was situated directly north of the tank. The site reconnaissance did not reveal the presence of any sumps, cisterns, cesspools, septic systems or above ground tanks on the property.

Atma Environmental Pty Ltd also identified in their environmental assessment report, two oiled stained areas in the centre of the site, reportedly as a the result of truck maintenance andor refuelling in several galvanised iron sheds (have been removed). Minor quantities of waste plasterboard were present on the surface.

3.4 Proposed development

The proposed use for this site is a high density, three storey residential retirement development. Details of the site include 139 serviced apartments, a central court yard, underground car park (with 45 car spaces), pool, lounge area, two lifts, craft room, day room and library. The site will also be hlly paved with garden beds.

6

oil staining,

* OmpM from Dwg. by Bevezidge W m & 0.

Dated 20/10/97- Pty Ltd. Ref No. 08105.

Bldg.

client Construction pty Ltd 2 Site Layout .aam TJ Fig.-.. __._

Tte:

Roiea )*anqpr: sc

M a c 231 McKinnon Road,

. ACN 002 347 971

Environmental &

Earth Sciences

/Gate \

McKinnon Road

Approdrnate scale

0 5 10 15 20 25m .

l- McKinnon, Vic. mer Apr.0

4.1 Site history

The site history is detailed in both the Atma Environmental Pty Ltd environmental investigation report and the Beveridge Williams & Co Pty Ltd’s preliminary report. Both consultants referred to historical land titles. Aerial photographs of years 1945, 1960, 1970 and 1987 were also examined by Beveridge Williams & Co Pty Ltd, and Atma Environmental Pty Ltd referred to the Sands and McDougall directory.

A review of the information supplied by Atma Environmental Pty Ltd and Beveridge Williams & Co Pty Ltd, indicated the following: - During 191 5, the Sands McDougall directory indicates that Ms Marion Lynch owned the

property to the west of Jasper Road; - Prior to 1926, the Sand McDougall directory indicates that the area was used for market

gardening; - From 1926 onwards, a historical land titles search indicates that Mulready & Co Pty Ltd

owned the site for commercial interests; - During 1930, the Sands McDougall Directory indicated that McKinnon Timber Co.,

sawmillers and joinery works, owned the site adjacent to Graham Ave; - During the 1940s to its present state, the Sands McDougall directory indicated that Liddy

Classic Fibrous Plaster Pty Ltd owned the property located at 227 McKinnon Road. This plaster factory was located in the section of 23 1 McKinnon Road, McKinnon; and

- Vacant land on the eastern side of the site was used as a plant nursery for approximately 15 years after the paster factory closed in 1980. The site was then cleared.

Aerial photographs during the 1940s also indicated that residential dwellings and the McKinnon Hotel were located on the eastern boundary of the site, residential properties to the north, east and west, with some vacant land to the south.

In 1960, additional buildings existed on the eastern portion of the site. The surrounding land uses remained the same, except for commercial developments to the south across McKinnon Road.

In 1970, additional buildings had been added to the site. Residential land was located to the north, east and west, with commercial properties established to the south of this site. The residential dwellings on the eastern boundary had been replaced with a hotel carpark.

The 1987 aerial photography indicates no change to the site or surrounding areas since 1970.

4.2 Potential contaminants of concern

Beveridge Williams and Co Pty Ltd did not identify any potential contaminants of concern in their preliminary report.

Based on the historical review and site reconnaissance in Atma Environmental Pty Ltd’s environmental assessment report, this site was considered to be potentially contaminated by the following contaminants: - Unknown chemicals present in fill material derived off site; - Petroleum hydrocarbons such as oils and petrol fiom vehicle maintenance / refuelling; and - Inorganic contaminants such as barium and sulphate fiom the plasterboard manufacturing.

Rep2000Nictoria/200022 9

5.1 Geology - Soil stratigraphy

Beveridge William and Co Pty Ltd state that according to the 1 :63360 Ringwood Sheet of the Geological survey of Victoria, the site is underlain by a thin veneer of Quaternary sand deposits (sand ridges and sand hills) which overly tertiary sands (Red Bluff Sands) of the Bnghton group. These are fine to coarse sands with minor poorly sorted gravels, and are poorly consolidated.

There is no comment of the regional geology at this site in the Atma Environmental Pty Ltd environmental assessment report.

In the Atma Environmental Pty Ltd assessment report, it is reported that the soil profile contain fill material to a thickness greater than 0.5 metres, with a majority of brown sandy loam with plaster and gravel, slightly moist. This is underlain by moist yellow/red/brown sandy clay, which is firm and has low plasticity to a maximum thickness of 2.2 metres. This material then overlays light brown/orange/light grey silty clayey sand (fine grained), with whitish streaks, mottled, dense and tending towards a sandy texture.

Based on the geological logs drawn by Beveridge Williams and Co Pty Ltd and Atma Environmental Pty Ltd (provided in Appendix A and B respectively), the current general profile across the site has been described as:

Depth below ground surface in metres Surface - 0.5

0.5 - 2.7 2.7 -

Soil composition Fill, greyhrowdwhite sandy loam with plaster, saw dust, gravel

Yellowhedhrown sandy clay, moist with low plasticity Light browdorangellight grey silty clayey sand with whitish streaks,

dense, fine grained, mottled

Rep2000Nictoria1200022 10

ACN 002 347 971

Environmental &

Earth Sciences

5.2 Hydrogeology

In Atma Environmental Pty Ltd’s environmental site assessment report, it is stated that the estimated depth to groundwater at the site is eight meters below ground level. The consultant also refers to the Department of Minerals and Energy “Groundwater Resources Victoria Map sheet” (1 982), which indicates that the aquifer lithology is likely to be sand and gravel sediments with 1000-3000 mg/L total dissolved solids (TDS) at less than 1OL/s yield. According to the State Environmental Protection Policy (SEPP) (1 997) - Groundwaters of Victoria, the groundwater in this region falls under segment B. Therefore the protected beneficial uses are maintenance of ecosystems; potable mineral water supply; agriculture, parks and gardens; stockwatering; industrial water use; primary contact recreation; and buildings and structures.

A site inspection conducted during the environmental site assessment by Atma Environmental Pty Ltd did not reveal the presence of any groundwater bores, springs or seeps. The pits previously containing the underground storage tank (UST) and hydrocarbon impacted soil were dry to a depth of 3 m.

Atma Environmental observe that there are no surface water receptors within a 1.6 km radius of the site, water supply in this area is reticulated (ie. no groundwater is supplied), and therefore conclude that any impacts fiom contamination at the site would be precluded by vadose zone adsorption.


A preliminary contamination assessment was undertaken on the site on the 8 and 9 October 1997 by Beveridge Williams & Co Pty Ltd.

6.1 Investigation works and sampling collection

Investigation works included seventeen test pits (numbered TPl to TP17) excavated using a backhoe, five hand augered holes (numbered BH18 to BH22) and collection of three surface samples (numbered 7 1,72 and 73). Boreholes BH18 to BH20 were located beneath the timber and concrete floors of the plaster factory. The surface samples were collected from hydrocarbons stained soil, beneath the above ground storage tank and the garage. These sampling locations are indicated in Figure 3 of this audit report, and the borelogs are given in Appendix A of this audit report.

6.2 Field observations

Beveridge Williams and Co Pty Ltd’s preliminary report described the soil profile as containing fill material ranging in thickness from 0.2m (TP12 and BH19) to 1.5m (TP8) below ground surface, and consisting of silty or clayey sand with gravel, red brick, coke, asphalt, white plaster or concrete fragments. A grey brown sand was found at a number of locations and was assessed as fill material or topsoil. Natural soil was encountered beneath this fill material to the termination depths of all test locations (maximum depth of 3.5 metres). The natural soil profile consisted of orange / red / brown silty clay of high plasticity.

No groundwater was encountered during this preliminary investigation.

The majority of soil samples collected during this preliminary investigation had no visual evidence of contamination. Several samples contained coke or asphalt material. PID readings up to 56.8 ppm were recorded in the vicinity of the underground storage tank and areas containing suspected oil spills.

12

Q, 3 C QI > q

'aient S C H W ~ Construction PtJr Ltd sawn: TJ 3 Fig . ___._._...

Investigation conducted in 013. mde: 1997 b Beveridge Wi l l iays & Co.

pty ~t2- Sampling Locations Roiea Ltarager: sc

~~ 231 McKinnon Road, McKinnon, Vic. Appoved: Date: Apr.00

E m 't cp

6

E7 TP14 TP6 H

8

B TP8 m

TP5 8

8 lP11

TP4 B

m W13

%17

73* H Tp12

e""'" I TP3 I

. ACN 002 347 971

Environmental &

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1 Gate\

McKinnor, Road

LEGEND :

Approximate scale . . . . . . 0 5 10 15 20 25m

* Compiled from Dwg. by Beveridge Williams & Co. P&y Ltd. Ref. No. 08105. Dated 20/10/97-

7P1 a - Test Pit location

Bn20+ - Borehole location

71# - Surface sample location

ACN 002 347 971

Environmental &

Earth Sciences

6.3 Laboratory analysis undertaken

For the preliminary report, Beveridge Williams and Co performed several analysis on a total of 21 soil samples including 6 composite samples. These composite samples comprised of the following samples: - Composite A - BH18 (0-0.3m) and BH19 (0.2-0.35m); - Composite B - BH18 (0.3-0.5m) and BH19 (0.35-0.45m); - Composite C - BH20 (0.15-0.4m), BH2 1 (0.15-0.4m) and BH22 (0.15-0.4m); - Composite D - TP6 (0.3-0.5m), TP7 (0.6-1 .O) and TP9 (0.6-0.8m); - Composite E - TP6 (0.5-0.8m), TP7 (1.2-1.4m), TP8 (1.5-1.7m), TP9 (0.8-1.0m); - Composite F - TP3 (0.4-0.6m), TP15 (0.5-0.7m), TP16 (0.3-0.5m) and BH18 (0.5-0.7m)

21 soil samples were analysed for heavy metals, 6 soil samples were analysed for total recoverable hydrocarbons (TRH), 2 for benzene, ethyl benzene, toluene and xylene (BTEX), 12 for polycyclic aromatic hydrocarbons (PAHs), and 3 organochlorine pesticides (OCPs). The laboratory transcripts for this investigation were supplied at the auditor request by Atma Environmental Pty Ltd.

6.4 Site assessment criteria

Beveridge Williams and Co Pty Ltd used the ANZECC (1992) -Australian guidelines for the assessment and management of contaminated sites to assess the impact of soil contamination of the surrounding environment.

Beveridge Williams and Co Pty Ltd also used the National Environmental Health Forum (1998) -Health based soil investigation levels - Column A (Residential) and Column D (Residential with minimal opportunities for soil access; includes high rise apartments and

pats) criteria to assess the site suitability for the proposed use.

Beveridge Williams and Co Pty Ltd used the Victorian EPA Publication 448 - Classification of Wastes (Table 2) to assess the method of soil disposal.

6.5 Soil Laboratory Results

A review of Beveridge Williams and Co Pty Ltd’s report indicated the absence of a summary

table of laboratory results. However a summary table of Beveridge Williams and Co Pty Ltd’s

14

results was presented Appendix E of Atma Environmental’s report (Table 1, page 2). The auditor requested the complete set of laboratory transcripts for Beveridge Williams and Co. The results expressed in the summary table, drafted by Atma Environmental whch undertook further investigation in a following stage of investigation, were checked with the original transcripts, which are presented in Appendix B of this audit report.

Some of the results of the summary table for Bevendge Williams and Co Pty Ltd’s preliminary report (table 1, page 2) have been transcribed incorrectly. These are outlined as follows: - For surface sample 71, the TPH fraction C,,-C,, is 20 000 mgkg not 2000 mg/kg; and - Samples COMP D, E and F were analysed for benzo(a)pyrene, however the results were

not presented in the summary table. All these samples contained non detectable concentrations of benzo(a)pyrene.

In Beveridge Williams and Co Pty Ltd’s preliminary report, some elevated concentrations of heavy metals were measured above the ANZECC sensitive environment threshold levels. These included composite samples containing arsenic (7.9-9.3 mgkg) and chromium (17 to 42 mgkg) and discrete samples containing copper (1 10 mgkg), lead (950 mg/kg) and zinc (290-590 mg/kg). These samples were located in the vicinity of the insitu silty clay material in the southern section of the site and the fill material in the northern and eastern sections of the site. All heavy metal concentrations were below the NEW Criteria - Level D (residential with minimal opportunities for soil access).

Elevated concentrations of TRH (fiaction X,) (21 110 - 64 900 mgkg) exceeded the Dutch Intervention Criteria for surface samples 71’72 and 73 in Beveridge Williams and Co Pty Ltd’s preliminary report. These samples were located in the fill material within the south and eastern sections of the site.

No BTEX, Polycyclic aromatic hydrocarbons (PAHs) and Organo-chlorine pesticides (OCPs) contamination were detected during this stage of investigation.

6.6 Quality Assurance / Quality Control

Beveridge Williams and Co did not conduct any QNQC procedures for their preliminary report, which is a significant deficiency in this report.

15

Internal quality assurance checks of soil samples were undertaken by WSL Consultants in the form of duplicate samples, matrix spike and recovery analysis to ensure that the analytical data produced by WSL Consultants was accurate. No split samples were collected for this report. Full laboratory transcripts were provided upon the request of the auditor by Atma Environmental Pty Ltd which undertook the following assessments.

6.7 Consultant’s conclusions

Beveridge Williams and Co Pty Ltd concluded the following: - no significant concentrations of pH, heavy metals (except for lead and zinc), Polycyclic

aromatic hydrocarbons (PAHs) and organochlorine pesticides (OCPs) were reported within the test locations at this site;

- elevated lead concentrations were found in TP8 and elevated lead and zinc concentrations were reported in TP11;

- concentrations of total recoverable hydrocarbons (TRH) - fraction >C,, were present at the site at prescribed waste levels. They were detected in surface samples taken in the vicinity of the oil spills associated with the above ground storage tank and garage. These soils will need to be disposed to a landfill;

concentrations were below the Environment Protection Authority (EPAV) clean criteria in samples taken at the southern end of the underground storage tank (UST); and

required.

- total recoverable hydrocarbons (TRH) and monocyclic aromatic hydrocarbons (MAH)

- removal of all underground storage tank (USTs) and backfilling of excavation will be

6.8 Auditor’s analysis

The use of the ANZECC (January 1992), Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites - Table 2 (Environmental soil quality guidelines) - Column B (Environmental Investigation): heavy metals (Criteria 2) for the assessment of the impact of the heavy metals on the environment is inappropriate for final determination of ecological risk and groundwater protection.

These criteria although widely adopted are based on total metal concentrations in the soil, which bears little relevance to protection of either groundwater or plant and soil fauna. Several recent studies (Cook & Hendershot, 1997 and Sauve et al, 1996) have recognised that the contaminants present in the soil solution, a measure of the portion available to biota is a more reliable indicator to the threat to the environment than total metal concentrations.

16

h

The limitations of using conservative total contaminant in the soil has also been recognised by the US Environment Protection Agency who is now developing a biomonitoring strategy in which phytotoxicity tests are recommended as an essential part, (Wang, W., (1992)). Understanding of the complex interactions which governs the availability of a specific contaminant however is poorly understood.

Beveridge Williams and Co Pty Ltd reported elevated concentrations of heavy metals including arsenic, chromium, copper, lead and zinc. These samples were located in the insitu silty clay material in the southern section of the site and the fill material in the northern and eastern sections of the site. In addition elevated TPH concentrations (fractions ClO-Cl4, CIS- C2*, C,, - C3J were determined in the surface samples located in the south eastern section of the site.

17

Atma Environmental Pty Ltd were engaged in March 1999 by Schwab Constructions to conduct remediation and validation works for this site. These works were undertaken in April and May 1999.

7.1 Site Assessment Criteria

Atma Environmental Pty Ltd used the ANZECC (1992) -Australian guidelines for the assessment and management of colitaminated sites to assess the impact of soil contamination of the surrounding environment.

Atma Environmental Pty Ltd used the Netherlands Ministery of Housing, Physical Planning and Environment (1994) -Environmental Quality Objectives in the Netherlands to assess the impact of soil contamination when the ANZECC (1992) levels are absent.

The National Environmental Health Forum (1 998) - Health based soil investigation levels - Column A (Residential) and Column D (Residential with minimal opportunities for soil access; includes high rise apartments andflats) criteria was also used to assess the site suitability for the proposed use.

The auditor utilised the State Environment Protection Policy (1997) - Vaters ofPort Phillip Bay and the ANZECC (1992) -Marine and Freshwater Quality Guidelines tqassess the impact of potential groundwater contamination of surrounding surface water bodies.

7.2 Underground Storage Tank

The first stage of remediation works was the removal of the underground storage tank (UST) on 7 April 1999, which was disposed of by Ball Construction Co Pty Ltd. A tank removij certificate is attached in Appendix G oEthe Atma Environmental's report. Validation soil samples were taken within the pit, which previously contained the UST. Five samples w Ire taken, including one from the base of the pit (XAFC/2.4), one from each wall (XAWN/1.'5, XAWE/l.S, XAWW/1.5, XAWS/l S). The sample locations are shown in Figure 4 of the Atma Environmental report and Figure 4 of this audit report.

:t

e

0.5m

1.0m

1.5m

2.0m

2.5m

3.0m

3.5Ili

4.0m

4.5m

5.Or1

- . 2,066 mg/kg

. 586

. 130

. . .

. 2,560

, 6,300

- 164

- t20

’

- < 20’

6H21 Sampling Detail

X 2 i N/O. 15

-3 T BH21

3,854 mglkg Excavated to i.0m

,%“ll %17

/ I W / O . i 5 ,

Excavated to 2 .7m -- - ---\ L 01 3 e f q %H10

U Ip s L

k H l 6

L 7m X 2 l S X

? i f 3

. BH8 SH2O D e t a i l Sampling

UST Sampling

D e t a i l X20N/1.5 L \ 4 m J Building

w 4. McKinnon Road

/XAWElr-5

XA WW1.5

XAWS/1.5

X20S/ j .5

Client SCHWAB Construction ptv Ltd

Fig ..._.__..._ Approximate scale -

0 5 10 15 20 25K1

These samples contained concentrations of lead, TPHs and BTEX which were either non detectable or below the ANZECC (B) level and NEW criteria - Level D. The tank backfill material was consequently removed from the site as clean fill. Hence, there was no residual contamination as a result of the UST.

7.3 Boreholes across the site

7.3.1 Drillings undertaken

Atma Environmental Pty Ltd hand-augered 21 boreholes numbered BH1 to BH 21. Boreholes BH1 to BH19 were located in a sampling grid pattern and drilled at depths ranging from 0.5 to 0.6 metres. Boreholes BH20 an BH21 were located in the immediate vicinity of the two oil stained areas and drilled at depths of 5.2 and 1.6 metres respectively. Sampling locations are illustrated in Figure 4 of this report, and a copy of these borelogs is given in Appendix C of this audit report.

7.3.2 Field Observations

Atma Environmental Pty Ltd environmental site assessment report identifies the soil profile as consisting of fill material to a thickness greater than 0.5 metres, containing a majority of slightly moist, brown sandy loam with plaster and gravel. This is underlain by moist yellow / red / brown sandy clay, which is firm and has low plasticity to a maximum thickness of 2.2 metres. This material then overlays light brown / orange / light grey silty clayey sand (fine grained), with whitish streaks, mottled, dense and tending towards a sandy texture.

Field headspace tests were also conducted for Atma Environmental Pty Ltd’s environmental site assessment, for soil samples using a catalytic element type organic vapour detector calibrated on methane. It is reported that most samples had readings of less than 60 ppm and that samples collected at BH20 and BH21 had elevated headspace readings as high as 800 units ppm. Therefore hydrocarbon contamination, indicated by the headspace results, occurred only at the areas of soil staining.

7.3.3 Sampling methodology

The sampling undertaken with depth interval and material sampled are summarised in Table 2.

Rep2000Nictond200022 20

Sample No. for Atma Environmental

110.1 110.5 210.1 210.5 310.1 310.5 410.1 410.5 510.1 510.5 610.1 610.5 710.1 710.5 810.1 810.5 910.1 910.5 1010.1 1010.5 1110.1 1110.5 1210.1 1210.5 1310.1 1310.5

Strata

Fill (clay) Fill (sand)

Fill (gravelhiturnen) Silty sand

Fill (gravel) Sandy clay

Fill (sandy loam) Fill (sandy loam) Fill (sandy loam) Fill (sandy loam) Fill (sandy loam)

Fill (sand) Fill (sandy loam) Fill (silty sand)

Fill (sand) Sandy clay Fill (sand) Sandy clay

Fill (sandy loam ) Sandy clay

Fill (sandy loam) Sandy clay Fill (sand) Fill (sand)

Fill (sandy loam) Sandy clay

Sample No. for Atma Environmental

1410.1 1410.5 1510.1 1510.5 1610.1 1610.5 17/0.1 1710.5 1810.1 1810.5 1910.1 1910.5 2010.5 2011 .o 2011.5 2013.0 2013.5 2014.0 2014.5 2015.0 21110.5 2111.0 2111.5 BGIO. 1 BGl0.5

Strata




Fill (sandy loam) Fill (sandy loam) Fill (sandy loam) Fill (sandy clay)

Fill (sand) Sandy clay Sandy clay Sandy clay Sandy clay

Silty clayey sand Silty clayey sand Silty clayey sand Silty clayey sand Silty clayey sand

Sandy clay Sandy clay Sandy clay


Note: all samples were collected on site except BGIO.l and BGl0.5 (offsite background samples)

The sampling methodology described in considered sufficient to avoid as much as possible cross contamination.

Rep2000Nictond200022 21

For the environmental assessment report, Atma Environmental Pty Ltd performed analysis on a total of 49 soil samples including 7 composite samples. These composite samples comprised of the following samples: - COMP 1 - 3/0.15,4/0.15,9/0.15 and 19/0.15; - COMP 2 - 13/0.15, 1410.15 and 15/0.15; - COMP 3 - 1/0.5, 2/0.5, 7/0.5, W0.5; - COMP 4 - 3/0.5,4/0.5, 9/0.5, 19/0.5; - COMP 5 - 5/0.5,6/0.5, 12/0.5, 1W0.5; - COMP 6 - 10/0.5, 11/0.5, 16/0.5, 17/0.7; and - COMP 7 - 13/0.5, 1410.5, 15/0.5.

Apart from the discrete soil samples collected across the site, validation samples were also collected from the two oil stained pits (Pit 20: X20N/1.5, X20W/1.5, X20SA.5, X20Eh.5, X20F/2.5 and Pit 21: X21N/0.15, X21F2/1.0, X21E/0.15, X21S/0.15, X21Fl2.7, X21W/0.15).

7.3.4 Laboratory analysis undertaken

Two composites soil samples (COMP 1 and COMP 2) were analysed for metals (Hg, Sp, As, Ba, Be, Cd, Cr, Co, Cu, Pb, Mo, Ni, Se, Sn), chlorinated hydrocarbons (CHCs), polycyclic aromatic hydrocarbons (PAHs), organo-chlorine pesticides (OCPs), total polychloro biphenyls (PCBs), total phenolics and cyanides. Five composite soil samples (COMP 3 to COMP 7) were analysed for a selection of metals (Sp, Be, Cd, Co, Mo, Se, Sn). Twelve discrete soil samples were analysed for lead and six discrete soil samples were analysed for barium. Twenty-two discrete soil samples were analysed for total petroleum hydrocarbons, and nine of these were analysed for BTEX. Six discrete soil samples were also analysed for sulphates.

7.3.5 Laboratory Results

The original laboratory transcripts are presented in Appendix E of the Atma Environmental Pty Ltd’s environmental site assessment report, and surnmarised in Table 1 of the same report. The results expressed in these tables were checked by the auditor and a copy of the original laboratory transcripts is presented in Appendix D of this audit report.


Some of the results in Table 1 (page been outlined as follows:

) have been transcribed incorrectly. These errors have

- COMP 2 contains concentrations of arsenic, copper and zinc at 2.5 m a g , 3.0 mgkg and

- Sample SPl has a TRH (fiaction c29-c36) concentration of 24 mgkg not <20mgkg; - Sample X20F/3.0 has a TRH concentration, fractions c&9, CIO-Cl4, and C15-C28, of

17mgkg respectively, not 2.4mgkg, 2.9 mgkg and 16 mgkg respectively;

82mg/kg, 3900 mgkg and 1300 mgkg respectively, not 78 mgkg, 3 700mgkg and 1 200 mg/kg respectively;

<20mgkg;

concentrations are as follows: Sample X21Fl2.7 contains <20mg/kg (C&g), 220 mgkg (CIo-C14), 590 mg/kg (CIS -

Sample X21F2A.0 contains non detectable concentrations of TRH fiactions; and - Sample ZF2/0.15 was missing from the summary table. BTEX concentrations were non

detectable, except for Xylene (0.09 mgkg) and TPH fractions were outlined as follows: (C&) non detectable, (Cio-Cl4) 160 mgkg, (Ci5CJ 310 mg/kg, (c29-c36) 180 mgkg.

- Sample X21 WI0.15 has a TRH (fraction c&6) concentration of 30 mgkg not

- Samples X21F/2.7 and X21F2/1 .O were missing from the summary table. Their TRH

‘28)7 63 mg/kg (c29-c36);

The investigation undertaken by Atma Environmental Pty Ltd revealed elevated total recoverable hydrocarbons (TRH) concentrations in boreholes 20 and 21. These samples were located in the southeastern section of the site, within the insitu sandy clay material (boreholes 20 and 21). Fractions Clo-Ci4, C15-C28, and c29-c36 for borehole BH21 at 0.5m depth exceeded the Dutch Intervention Criteria.

Concentrations of sulfate exceeded the ANZECC (B) level criteria in 4 out of the six soil samples analysed (boreholes BH3, BH5, BHlO and BH12). A contour map of the sulfate distribution is shown on Figure 3 of the Atma Environmental’s report. Elevated concentrations of sulfate increase fiom the south east to the north west of the site.

Concentrations of heavy metals and BTEX were detected across the site. These concentrations were below the ANZECC sensitive environment threshold levels for heavy metals and the NEW Criteria - Category D for metals and BTEX.

Chlorinated hydrocarbons (CHCs), polycyclic aromatic hydrocarbons (PAHs), organochlorine pesticides (OCPs), total polychloro biphenyls (PCBs), total phenolics and cyanides were non-detected in the two composite samples analysed.

. Rep2000Nictona/200022 23

One background sample (BG1) was collected by Atma Environmental Pty Ltd at the test bore located in the nature strip across Graham Avenue, opposite BH5. The consultant reported non-detectable concentrations of heavy metals except for barium, chromium, lead and zinc. These concentrations were below the ANZECC sensitive environment threshold levels and the NEHF criteria - Level D.

7.3.6 Excavation of impacted materials in the vicinity of BH20 and BH21

Excavation of hydrocarbon impacted soils was required in the two areas with hydrocarbon staining in the vicinity of BH20 and BH21 (southeastern section of the site). These soils were excavated respectively on 26 April and 23 April 1999. The extent of the excavation was controlled by visual indicators such as soil staining in the walls and the floor of the pit. The soils considered most contaminated were taken from the site to Sita-BFI Pty Ltd’s Lyndhurst landfill facility for disposal. The remaining soils from both pits were mixed and spread over landfarm areas along the southern perimeter of the site, to reduce the residual contaminant concentrations.

Further validation sampling was taken from both locations. In the vicinity of borehole BH20, nine soil samples were collected within the walls and floors of the pit (26 April 1999) and to a depth of 5.0 metres below ground surface, through the floor of the pit. This is shown in Figure 5 and 6 of Atma Environmental’s report and Figure 4 of this audit report. These samples were tested for TPH and BTEX. Sample taken at depth 3.0 metres was above the Dutch Intervention Criteria for TPH fractions (Cl0-CJ.

In the vicinity of borehole BH21, six validation samples were taken from the walls and floors of the pit. These samples were tested for TRHs and were below the Dutch Intervention Criteria.

7.4 Bioremediation of hydrocarbon impacted materials

The third stage included oxygenating the landfarm areas by bulking the soil prior to its distribution. This encouraged biodegradation and weathering, allowing the soil to decontaminate for a week. The soil was then sampled on 3 May 1999, whereby four samples were collected using a field headspace measurement to indicate the levels of TPH in the soil. The highest reading, sample ZF210.15, was submitted for analysis for TPH and BTEX. These

24

concentrations were below the Dutch Investigation Criteria. The auditor does not condone the practise of dilution as it appears to have happened here. Bioremediation of diesel impacted soil takes approximately three months, and bulking or dilution is not considered to be remediation.

7.5 Consultant’s conclusions for this stage of works

Atma Environmental Pty Ltd concluded the following for this stage of works: - Grid sampling was unable to confirm the findings of the previous consultant with respect

to lead contamination on the site; - Analysis of selected composite surface samples for a standard EPA screen indicates that

the site is unaffected by common organic contaminants (or metals including zinc);

likely due to the former plasterboard operations; - Sulfate impacted soil is above the ANZECC environmental investigation threshold levels,

- No contamination was found in the vicinity of the former underground storage tank; - Petroleum hydrocarbon contamination was detected in two oil stained areas. Remediation

measures were taken, however an estimated 5m3 of petroleum impacted soil remains at the base of the investigation. It is recommended that any remaining hydrocarbon contaminated soil is to be removed as part of bulk excavations during construction of the basement area;

- Concentrations of sulfate remaining on the site may affect concrete structures; and - Concentrations of contaminants at the site are within the health investigation levels for

residential settings, having minimal opportunities for soil access.

On this basis, the proposed development should be suitable for this site.

I


8.1 Additional works requested by the auditor

The auditor requested by letter dated 13 April 2000 that additional soil and groundwater sampling be undertaken as follows: - four to five samples were to be collected within the fill material at depth 0.5 metres along

- one groundwater needed to be installed at the southern section of the site close to the the northern fence of the site and analysed for lead; and

location of the former underground storage tank.

These works were undertaken by Atma Environmental Pty Ltd in April - May 2000.

8.2 Complementary investigation works undertaken

8.2.1 Sampling methodology

The results of the additional soil sampling campaign are reported in a letter report dated 11 May 2000. Four additional boreholes (BH-A, BH-B, BH-C, BH-D) were drilled along the northern boundary of the site and soil samples were collected at a depth of 0.5 metres below the ground surface.

As requested by the auditor, Atma Environmental Pty Ltd installed a groundwater monitoring well on the 30 April 2000 in the vicinity of the former UST. Six soil samples were also collected during the installation of the groundwater monitoring well (MW1). During drilling of MW1, Atma Environmental Pty Ltd used a catalytic element detector (CED) for measuring field headspace results. The volatile organic compound (VOC) readings ranged from 30 to 950 ppm. The groundwater monitoring well was installed to a depth of 9.1 metres below the ground surface. Water was first intercepted at 6.1 metres below ground surface within the sand aquifer. One groundwater sample was collected (MWl/W).

Soil sampling locations undertaken by Atma Environmental Pty Ltd for this investigation stage is illustrated in Figure 5 of this audit report.

26

ACN 002 347 971

Environmental &

Earth Sciences

Tide: Additional Investigation conducted by ATMA Environmental in May 2000

:, McKinnon, Vic.

Drain T

?iBH-D &-A %-B %-C

5 aaWn: TJ Roject

Approved: Date: Juri-Oi

, I Fig ._...__..._ Manager: sc

- Bldg .

- -

underground storage r I/ tank ' I

I Ld

MW-1

4 ti

Property Boundary 1

-'Gate '1

+ 1

McKinnon Road

0 Scale 25m Legend:

-$ - Borehole location ( 1/5/2000) - Groundwater monitoring well

( 1/5/2000)

Client Schwab Constructions

8.2.2 Samples sent to laboratory for analysis

During this stage of investigation, 4 soil samples were analysed for lead and 1 soil sample was analysed for BTEX. One water sample was also collected and analysed for BTEX, TRH and sulfate. The chain of custodies for this letter are presented at the end of this letter.

8.2.3 Laboratory results

For soils, Atma Environmental Pty Ltd report that concentrations of lead ranged from 9.9 mgkg to 470 mg/kg. Sample BH-NOS exceeded the ANZECC sensitive environment threshold levels. All samples were below the NEHF @) level criteria.

For groundwater, Atma Environmental Pty Ltd reported detectable concentrations of sulfate (280 m&). Concentrations of TRHs and BTEX were non detectable.

8.3 Consultant’s conclusions for this stage of investigation

Atma Environmental Pty Ltd’s made the following conclusions in a letter dated 11 May 2000: - Sulfate and hydrocarbon concentrations indicate no contamination of the aquifer below the

site; - Since the sources of contamination have been removed, on going monitoring should not

be necessary; - Any minor soil locked vapours are expected to dissipate over time; and - Lead concentrations are acceptable for the type of development being constructed.

28

9.1 Sampling protocol

Atma Pty Ltd s outlined their QNQC procedure in Appendix C of their environmental assessment report. All soil samples were collected and logged by an experienced environmental scientist. Sample collection was performed in accordance with ANZECC and NHMRC Guidelines for the Assessment and Management of Contaminated Sites, 1992. Relevant chain of custody documentation was presented in Appendix E of their environmental assessment report and the back of the letter dated 11 May 2000.

The sampling protocol described in Atma Environmental Pty Ltd reports is appropriate.

9.2 Field quality assurance and quality control

Decontamination procedures and sample preservation methods were camed out in accordance with section 7.5, 8.2 and 8.3 of AS4482.1. Copies of borelogs detailing the soil profile encountered during the site investigation undertaken by Atma Envkonmental Pty Ltd were presented in Appendix A of the consultant’s report and in the letter dated 11 May 2000. Groundwater monitoring well construction records were also included in the letter (1 1 May 2000). These borelogs presented are satisfactory for the purpose of this assessment.

A total of 65 soil samples were collected as part of Atma Environmental’ site assessment and letter (1 1 May 2000). In addition 3 duplicates and 2 split duplicate soil samples were analysed as part of the site assessment report and 1 duplicate as part of the consultant’s letter (1 1 May 2000). For the site assessment report, the duplicate samples were analysed by Gribbles Analytical Laboratories and the split samples were analysed by MGT consulting for quality control purposes. For the consultant’s letter (1 1 May 2000), the duplicate sample was analysed by MGT Consulting. The frequency of sample duplicates does not conform with the Australian Standard 4482.1( 1997) - Guide to the sampling and investigation ofpotentially contaminated soil, as an additional 2 split duplicate samples are required. Nevertheless the auditor is of the opinion that the decreased number of duplicates does not reduce the assurance in the data.

29

9.3 Laboratory quality assurance and quality control

For Atma Environmental Pty Ltd’s preliminary report internal quality assurance checks of soil samples were undertaken by Gribbles Analytical Laboratories in the form of duplicate samples, matrix spike and recovery analyses to ensure that the analytical data produced by Gribbles Analytical Laboratories were accurate. Two split duplicate samples were sent to a second NATA registered external analytical laboratory, MGT Consulting for analysis. A summary of the quality assurance testing is shown in pages 10 to 11 of the consultant’s report. Full laboratory transcripts are provided in Appendix E of the consultant’s report and D and E of this audit report.

For Atma Environmental Pty Ltd’s letter (1 1 May 2000) internal quality assurance checks of soil samples were undertaken by MGT Consulting in the form of sample duplicate, matrix spike and recovery analysis to ensure that the analytical data produced by MGT consulting were accurate. No split duplicates were analysed for this letter. Full laboratory transcripts are provided at the end of this letter.

For Atma Environmental Pty Ltd’s site assessment report, the calculation of the relative percent difference (RPD) between the duplicate samples is summarised on page 11 of the consultant’s report. The RPD values for the duplicate sample analysis could not be calculated for DUPL 1 (7 April 1999) as all results were non detectable, but importantly, produced the same results. For the remaining duplicate samples the RPD values ranged fiom 11 to 58% which is acceptable.

For Atma Environmental Pty Ltd’s letter (1 1 May 2000), the relative percent difference (RPD) between the duplicate sample is summarised on page 2 of the consultant’s letter. The RPD values for this duplicate was 10% which is acceptable.

For Atma Environmental Pty Ltd’s site assessment report, the consultant also calculated RPD values between the split duplicate samples, as summarised on page 11 of the consultant’s report. The RPD values for the split sample analysis ranged fiom 48% to 78% which shows a significant variation between the laboratories. This is acceptable given the error associated with sampling and sand heterogeneity.


Rinsate blank samples provide information regarding cross contamination of substances from the sampling equipment used. All analytes tested for the rinsate blank were below detection limits.

The quality assurance confirms that the data can be accepted as representative.

9.4 Conclusion on QNQC for soils analysis

The quality control procedures for soils, including sampling methodology, field duplicates and analysis undertaken by Gribbles Analytical Laboratories, MGT Consulting and WSL Pty Ltd means that the results can be seen as representative of site conditions.


The use of the ANZECC (January 1992), Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites - Table 2 (Environmental soil quality guidelines) - Column B (Environmental Investigation): heavy metals (Criteria 2) for the assessment of the impact of the heavy metals on the environment is inappropriate for final determination of ecological risk and groundwater protection.

These criteria although widely adopted are based on total metal concentrations in the soil, which bears little relevance to protection of either groundwater or plant and soil fauna. Several recent studies (Cook & Hendershot, 1997 and Sauve et al, 1996) have recognised that the contaminants present in the soil solution, a measure of the portion available to biota is a more reliable indicator to the threat to the environment than total metal concentrations.

I

The limitations of using conservative total contaminant in the soil has also been recognised by the US Environment Protection Agency who is now developing a biomonitoring strategy in which phytotoxicity tests are recommended as an essential part, (Wang, W., (1992)). Understanding of the complex interactions which governs the availability of a specific contaminant however is poorly understood.

Beveridge Williams and Co Pty Ltd reported elevated concentrations of heavy metals including arsenic, chromium, copper, lead and zinc. These samples were located in the insitu silty clay material in the southern section of the site and the fill material in the northern and eastern sections of the site. In addition, elevated TPH concentrations (fkactions C,o-C14, C,5- CZ8, C29-C36) were determined in the surface samples located in the southeastern section of the site.

Following Beveridge Williams and Co Pty Ltd’s preliminary report, Atma Environmental reported elevated concentrations of sulfate increasing in concentration from the south east of the site to the north west section of the site within the fill material. These elevated sulfate concentrations would have derived fiom previous plasterboard operations. At the auditor’s request, a letter fiom the consulting engineer, John Clayton and Associates, confirmed that the cement used for the development of this site was sulfate resistant (Appendix F).


Further remediation was conducted by Atma Environmental. This included the removal of UST on the 7 April 1999. Soil samples were subsequently taken around the floors and walls of the tank pit. Two pits were also excavated in the vicinity of the oil stained areas (BH20 and BH21) on 26 April 1999 and 23 April 1999 respectively. Samples were also taken in the floors and walls of these two pits. Soil sample laboratory results revealed elevated concentrations of TRHs (fiactions Clo- &) within BH20 to a maximum depth of 0.5 metres below ground surface, and for BH2 1 to a maximum depth of 3.0 metres below ground surface.

At the auditor’s request, plans of the proposed development were supplied. On the basis of these plans and correspondence with Eric Schwab, it has been confirmed that the site has been excavated to a maximum depth of 3 metres. Therefore the contaminated material identified in Beveridge and William and Co Pty Ltd’s preliminary report and Atma Environmental Pty Ltd’s environmental site assessment report has been removed.

The auditor also requested further sampling of the fill material in the northern boundary of the site. One of four samples collected (on 30 April 2000) was reported to be above the ANZECC sensitive environment threshold levels for lead. Landscape plans and site plans requested by the auditor confirm the majority of the site will be paved and garden beds will be installed on the site. Therefore this soil will be either covered with topsoil or removed fi-om the site. Lead at this level is not phytotoxic.

The auditor also requested the installation of a groundwater monitoring well in the vicinity of the former UST. One groundwater sample was collected fi-om this well. Petroleum hydrocarbons were not detected and sulfate levels though not discussed are consistent with likely background. Further groundwater monitoring is not considered necessary.


The auditor inspected the site on 13 April 2000 and noted that the 3 storey retirement village building was complete, whereas the interior of this building was still under construction. There was one small brick building of approximately 80 m2 in area located on the south west comer, originating from the site’s previous use.

Adjacent land uses include residential housing to the north and west, a hotel to the east, and commercial properties to the south. A petrol station is located directly opposite the site south of McKinnon Road.

After the site inspection, the auditor required additional sampling be carried out at the rear of the site for lead, a groundwater to be sampled in the vicinity of the UST and a letter from the site engineer confirming that sulfate resistant cement was used. These requirements were met.

The auditor does not condone the use of dilution as a remediation strategy.

The site is suitable for its existing use or other high density residential use.

34

The site has been investigated and validated on a grid basis. Though the auditor has inspected the site and viewed the report, the auditor is not responsible for opinions based on work that is later found to be false or misleading. The investigation and audit in no way imply that the site will be free from contamination after development but only that exposure of contamination to the environment or fiom activities on the site as a whole will not cause adverse impact on the beneficial users. After development has been undertaken, based on the liabilities associated with the consultant’s report and its limitations, contamination may remain on site. This audit may not be applicable if the site is subdivided, as this will alter statistics and potentially conclusions. This audit does not conclude that all material remaining on site if excavated will be classified as clean fill.

Rep2000ffictorid200022 35

ANZECC - Australian and New Zealand Conservation Council

BTEX - Benzene, Ethyl Benzene, Toluene and Xylene

BAP - Benzo(a)pyrene

CH - Chlorinated Hydrocarbons

EPA - Environmental Protection Authority

OCPs - Organochlorine Pesticides

MAH - Mono Aromatic Hydrocarbons

NATA - National Association of Testing Authorities

NEHF - National Environmental Health Forum

NHMRC - National Health and Medical Research Council

PAH - Polycyclic Aromatic Hydrocarbons

QNQC - Quality Assurance / Quality Control

RPD - Relative Percentage Difference

SEPP - State Environmental Protection Policy

TCLP - Toxicity Characteristic Leachate Procedure

TDS - Total Dissolved Solids

TPH - Total Petroleum Hydrocarbons

UCL - Upper Confidence Limit

36

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