generic safety, health and environmental management plan

Botany Groundwater Extraction Exclusion Area Generic Safety, Health and Environmental Management Plan

Issued: February 2020 Revision: 1


Revision: 1 Issue Date: November 2019 Page i of ii

CONTENTS 1. INTRODUCTION ....................................................................................... 1

1.1. SHEMP Purpose .................................................................................... 1

1.2. SHEMP Scope ....................................................................................... 1

2. SITE DESCRIPTION ................................................................................. 2

2.1. Overview of the Orica Botany Groundwater Cleanup Project ................... 3

2.2. Environmental Setting ........................................................................... 4

2.3. Historical Surrounding Land Use ............................................................ 5

3. REGULATORY REQUIREMENTS ............................................................ 6

3.1. Workplace Health and Safety ................................................................. 6

3.2. Environment......................................................................................... 6

4. MANAGEMENT FRAMEWORK ................................................................ 7

4.1. SH&E Roles and Responsibilities ............................................................ 7

4.2. Training and Competency ...................................................................... 7

4.3. Internal Communications ...................................................................... 8

4.4. Document Management ........................................................................ 8

4.5. Emergency Preparedness and Response ................................................. 8

5. SH&E RISK MANAGEMENT MEASURES ................................................ 8

5.1. Potentially Hazardous Substances .......................................................... 8

5.2. Safety Hazards and Control Measures .................................................. 10

5.3. Workplace Health Hazards and Control Measures ................................. 10

5.3.1. Personal Protective Equipment......................................................... 11

5.4. Environmental Hazards and Control Measures ...................................... 11

5.4.1. Soil, Groundwater and Surface Water Management .......................... 11

5.4.2. Emissions to Air ............................................................................... 12

5.4.3. Water Management ........................................................................ 13

5.4.4. Waste Management ........................................................................ 13

5.4.5. Acid Sulfate Soils Management ........................................................ 13

6. SHEMP REVIEW .................................................................................... 17

6.1.1. Assessment of Implementation ........................................................ 17

6.1.2. SHEMP Updates............................................................................... 17

7. REFERENCES ........................................................................................ 17


Revision: 1 Issue Date: November 2019 Page ii of ii

DOCUMENT CONTROL DOCUMENT TITLE Botany Groundwater Extraction Exclusion Area Generic Safety, Health and Environmental Management Plan DOCUMENT OWNER Lead – Legacy Projects C Wiley VERSION

Revision Date Author Reviewed Approver

0 8 November 2005 J Stening J Fairweather W Crowe

1 February 2020 J Stening J Fairweather J Fairweather


Revision: 1 Issue Date: November 2019 Page 1 of 17

1. INTRODUCTION

1.1. SHEMP Purpose The purpose of this Generic Safety, Health and Environmental Management Plan (SHEMP) is to provide owners/operators of properties within the Botany Groundwater Extraction Exclusion Area (GEEA) (referred to as Area 1 of the Botany Sands Groundwater Source by WaterNSW, which is part of NSW Department of Planning, Industry and Environment 1 ) to assist in the development of Safety, Health and Environmental (SH&E) management plans for works which may encounter Orica-related contamination in soil or groundwater. It is a generic document that needs to be customised to meet the needs and constraints of the specific works to be undertaken below the ground surface and of the property on which these works are to take place.

This Generic SHEMP is not a substitute for a Safe Work Method Statement or Job Safety Analysis, but may be used to supplement them.

This document has been prepared in compliance with, and incorporating elements of, Safety, Health, Environment and Physical Security Management System of Orica Australia Pty Ltd (Orica). Users of this document may adapt it to accommodate their own SH&E policies.

1.2. SHEMP Scope This Generic SHEMP relates to the soil and groundwater contamination associated with Orica’s former (legacy) and current operations and facilities located in the GEEA. It does not consider other former and current operations in the area, nor any associated contaminants.

The hazards and risks presented in this document are based on findings of investigations commissioned by Orica on Botany Industrial Park (BIP) and in selected surrounding areas. Those investigations have been generally limited to Orica-related compounds and may not be applicable to other substances which could be encountered. This document also does not consider site-specific conditions, be they geophysical or geochemical, above or below the ground surface.

The major features of this Generic SHEMP are:

• Description of location and the Orica Botany Groundwater Cleanup Project; • Regulatory requirements; • SH&E risk management framework; • SH&E risk management measures; and • SHEMP review process.

This document provides general guidance only. Orica accepts no responsibility for the use of any information contained in this document. This document is not a comprehensive guide to undertaking works below the ground surface in accordance with environmental and health and safety requirements. In each case, organisations and people undertaking works within the GEEA which may potentially encounter contaminants should ensure they satisfy themselves that all appropriate measures are

1 Refer to the WaterNSW website at https://www.industry.nsw.gov.au/water/allocations-availability/temporary-water-restrictions/botany-sands-gw

https://www.industry.nsw.gov.au/water/allocations-availability/temporary-water-restrictions/botany-sands-gw

https://www.industry.nsw.gov.au/water/allocations-availability/temporary-water-restrictions/botany-sands-gw



taken. It is recommended that all such works should be undertaken under the supervision or guidance of suitably qualified SH&E practitioners.

This document was prepared in April 2019 and is not continually updated. SH&E requirements are likely to change over time as will the state of knowledge about contamination within the GEEA. Any person using this document should ensure that current information and controls are considered.

2. SITE DESCRIPTION The Botany GEEA, which includes the BIP, is shown in Figure 1 below. It should be noted that the extent of the GEEA takes in areas that have been affected by contamination not related to Orica’s former or current operations and facilities.

The GEEA is an area identified by WaterNSW where the extraction of groundwater for domestic use is prohibited. It covers parts of Botany, Pagewood, Hillsdale, Matraville and Port Botany. The area is defined by infrastructure features including Bunnerong canal, Bumborah Point Road, Perry Street, Kelly Lane, Beauchamp Road, Rhodes Street, Smith Street, Fraser Avenue, Wentworth Avenue, Moore Street, Baker Street, Wentworth Avenue, Page Street, Banksia Street, Dudley Street, Holloway Street, Morgan Street, William Street, Pemberton Street, Botany Road, Edgehill Avenue and Hayden Place.

Figure 1. Groundwater Extraction Exclusion Area – Area 1 (source: WaterNSW, 20182)

All extraction of groundwater by residents for domestic purposes is prohibited in Area 1 and Area 2, shown on the map above, through a Temporary Water Restrictions Order

2 WaterNSW website https://www.industry.nsw.gov.au/__data/assets/image/0020/156080/Botany-Sands.png

https://www.industry.nsw.gov.au/__data/assets/image/0020/156080/Botany-Sands.png



under the Water Management Act 2000 (NSW)3, which replaces a similar order made in 2006. The restrictions apply to a whole land parcel, even if only part of the property is within the restricted area. Conditions are also in place for taking water for non-domestic uses and specified industrial water access licences.

2.1. Overview of the Orica Botany Groundwater Cleanup Project The environmental issues at what is now known as the BIP date back to the 1940s when manufacturing began at the site. Larger manufacturing plants producing a wider range of chemicals were introduced in the 1960s, when environmental awareness and standards were not the same as those of today, especially in understanding the impact of chemical use and storage on soil and groundwater quality.

During this time, chlorinated hydrocarbons (CHCs) were manufactured, handled and stored on site in tanks and drums. Some of these stored materials have leaked into the ground and groundwater. It is likely that contamination was also caused by accidental spills and general plant operations.

The main contaminant of concern to Orica in the groundwater is ethylene dichloride (EDC, also known as 1,2-dichloroethane or 1,2-DCA). All Orica-related contaminants encountered to date in the Botany soil and groundwater are listed in Table 1 in Section 5.1. These contaminants have been conveyed in the groundwater below the ground surface towards Penrhyn Estuary and Botany Bay.

The NSW Environment Protection Authority (NSW EPA) issued Orica with a Notice of Clean Up Action (NCUA) under the Protection of the Environment Operations Act in September 2003. The NCUA was replaced in November 2010 with a Voluntary Management Proposal (VMP) under the Contaminated Land Management Act. The VMP and its subsequent amended versions set out the framework and timeframe for Orica to contain, recover and treat the contamination.

Since 2005 Orica has operated a system of hydraulic containment to intercept the ongoing movement of CHC contamination in groundwater. Containment of the groundwater includes extraction from wells installed in three different locations within the GEEA:

• Primary Containment Area (PCA) – located adjacent to a section of McPherson Street, Banksmeadow;

• Secondary Containment Area (SCA) – located in median strip along a section of Foreshore Road; and

• BIP Containment Line – along and parallel to the northern half of the western boundary of the BIP.

The extracted groundwater is transferred by pipelines to the Groundwater Treatment Plant (GTP) located on BIP. The groundwater then undergoes several stages of treatment to remove the manmade and naturally-occurring substances in the water.

Treated water is reused for non-potable industrial use on the BIP and in an adjacent manufacturing facility. There is also provision to discharge the treated water to a stormwater canal and thence Brotherson Dock in Botany Bay should the amount of treated water exceeds the demand from the industrial users.

3 NSW Government Gazette No 23 of 23 February 2018 https://gazette.legislation.nsw.gov.au/so/download.w3p?id=Gazette_2018_2018-23.pdf

https://gazette.legislation.nsw.gov.au/so/download.w3p?id=Gazette_2018_2018-23.pdf



The Orica Botany Groundwater Cleanup Project (BGC Project) is described in more detail on the project website4.

2.2. Environmental Setting The GEEA lies within the Botany Basin – a natural topographical basin surrounding Botany Bay. The Botany Basin is formed in a shallow depression in the sandstone bedrock which has filled with coastal sand dunes and estuarine sediments. The ground elevations rise from less than 5 m AHD around the foreshore of Botany Bay and swampy areas to between 15 and 25 m AHD in the sand dunes, reaching a maximum elevation of 35 to 40 m AHD at the Basin edges.

Major topographical features of the model area include:

• An extensive low-lying area (less than 5 m AHD) to the southeast of the BIP, which was a former swamp (Veterans Swamp), has been largely reclaimed through drainage. Southlands is situated within this area.

• Dunes form the higher ground extending under most of the BIP and to the east, north and northwest of the site.

• Dunes form the ridge of higher ground under Stephen Road.

Natural drainage patterns have been extensively modified through industrial and commercial development. In the sand dune areas there are few natural water courses and most drainage is inferred to occur through infiltration into permeable sands. The major surface water features in the GEEA include:

• Surface drainage to the east via a series of lined or piped canals and drains through the Matraville area; and

• Near the BIP and towards Botany Bay, surface drainage of Banksmeadow and Matraville catchments via Floodvale Drain and Springvale Drain. Shallow groundwater ingress in some sections of the drains results in drain baseflow. Floodvale and Springvale Drains originate near Page Street and Heffron Road, respectively. Both drains are piped at their northern ends. Springvale Drain is an open channel at the BIP, and both drains are largely open channels between the BIP and Botany Road. Floodvale Drain is piped under Botany Golf Course and Foreshore Road, whilst Springvale Drain is piped through parts of Discovery Cove Industrial Estate and under Foreshore Road. Floodvale Drain and Springvale Drain enter Botany Bay via Penrhyn Estuary.

The geology of the Botany Basin is characterised by a sedimentary sequence overlying Hawkesbury Sandstone bedrock. The Botany Basin has been broadly simplified into the following stratigraphic units:

• Basal units consist of fluvial and marine sands, estuarine muds and peats at thicknesses of 0 m to 45 m overlying sandstone bedrock;

• Aeolian and littoral dune and beach sands that reach a maximum thickness of 30 m. Discontinuous lenses and bands of inter-dunal peat and clay are present. This unit is referred to as ‘Botany Sands’ and is most relevant to this SHEMP. Hard, iron-cemented sand layers locally referred to as “Waterloo Rock” are common in the upper portion of this unit; and

4 BGC Project website https://www.orica.com/Locations/Asia-Pacific/Australia/Botany/Botany-Transformation-Projects/Groundwater-Cleanup#.XcC5gOgza70

https://www.orica.com/Locations/Asia-Pacific/Australia/Botany/Botany-Transformation-Projects/Groundwater-Cleanup#.XcC5gOgza70

https://www.orica.com/Locations/Asia-Pacific/Australia/Botany/Botany-Transformation-Projects/Groundwater-Cleanup#.XcC5gOgza70



• The upper unit is represented by Holocene aeolian sands. These are most common in proximity to Botany Bay and exist close to present day land surface.

In the past century, filling and drainage of the low-lying and coastal areas in and around the Botany Bay area has increased the land surface area. This includes much of the area south of Botany Road in Banksmeadow and for development of Port Botany and Sydney Airport. Filling involved the ‘dray and scoop’ or ‘dredging and hydraulic placement’ of Botany Sands – including from Botany Bay – over these areas. Ash from the former Bunnerong Power Station has also been used as fill extensively in the area.

2.3. Historical Surrounding Land Use Industry was first established in the East Botany area near the turn of the 19th century. The first industries were mainly tanneries, fellmongers, wool scourers and a paper mill. Several major industries were established in the 1920s and 1930s, including Davis Gelatine, Kellogg’s and Johnson & Johnson. Many of the chemical industries, including ICI Australia and New Zealand (ICIANZ, subsequently ICIA and now Orica), were established in the 1940s.

During the period from 1956 to 1966, several bulk fuel depots located immediately to the north and west of BIP, and further chemical manufacturing facilities were established. Reclamation works for Port Botany commenced in the mid-1970s, with further expansion works from 2010-2014. Davis Gelatine, historically a major groundwater user in the area, ceased manufacturing operations in about 1991.

The Botany Sands contain a system of interconnected unconfined and semi-confined aquifers that are collectively referred to as the Botany Sands aquifer, which cover an area of about 18,300 hectares. Groundwater generally flows in a southwest direction from the main recharge areas in the north to discharge into a series of wetlands (Lachlan Lakes) and Botany Bay in the south. The water table elevations range from 35 m AHD at Centennial Park at the northern end of the basin to approximately 0 m AHD at Botany Bay. The typical depth to shallow groundwater in the GEEA ranges from 1 to 5 m below ground level (although may be deeper according to the surface topography).

The hydrostratigraphy of the Botany Sands aquifer within the GEEA is consistent with the lithological profile described above.

Within the GEEA, groundwater is typically characterised by slightly acidic, slightly reducing and mildly anaerobic conditions that are likely to favour nitrate, sulphate, manganese and iron reduction, and formation of organic acids (from the peat lenses). Uncontaminated groundwater away from Botany Bay is fresh, with low but variable concentrations of nutrients, major ions (though iron and sulphate are elevated) and organic carbon. Groundwater quality in the GEEA is affected by historical contamination and saline (sea water) intrusion from Botany Bay.

More information about the geophysical and geochemical conditions of the GEEA can be found in the Conceptual Site Model report (Orica, 2017) on the project website5.

5 Conceptual Site Model https://www.orica.com/Locations/Asia-Pacific/Australia/Botany/Botany-Transformation-Projects/Groundwater-Cleanup/publications-reports-and-reviews#csm

https://www.orica.com/Locations/Asia-Pacific/Australia/Botany/Botany-Transformation-Projects/Groundwater-Cleanup/publications-reports-and-reviews#csm





3. REGULATORY REQUIREMENTS The regulatory requirements listed below are not necessarily a complete or entirely applicable list relevant to works being or proposed to be undertaken on the subject site(s). Users of this generic document should refer to legislative and regulatory requirements relevant to their site(s) and the proposed works.

3.1. Workplace Health and Safety The principal workplace health and safety legislation includes:

• Work Health and Safety Act 2011 (NSW); and • Work Health and Safety Regulation 2017 (NSW).

In addition, in August 2019, SafeWork NSW adopted 23 model codes of practice that were updated by Safe Work Australia and released during 2018.

3.2. Environment The principal environmental legislation includes:

• Contaminated Land Management Act 1997 (NSW); • Contaminated Land Management Regulation 2013 (NSW); • Environmental Planning and Assessment Act 1979 (NSW); • Environmentally Hazardous Chemicals Act 1985 (NSW); • Environmentally Hazardous Chemicals Regulation 2017 (NSW); • Protection of the Environment Administration Act 1991 (NSW); • Protection of the Environment Operations Act 1997 (NSW); • Protection of the Environment Operations (Clean Air) Regulation 2010 (NSW); • Protection of the Environment Operations (General) Regulation 2009 (NSW); • Protection of the Environment Operations (Waste) Regulation 2014 (NSW); • Waste Avoidance and Resource Recovery Act 2001 (NSW); • Protection of the Environment Legislation Amendment Act 2011 (NSW); • Water Management Act 2000 (NSW); and • Environment Protection and Biodiversity Conservation Act 1999 (Cth).

Additional regulatory requirements may include:

• NSW EPA Compliance Policy; • Botany Bay Development Plan 2013; • Botany Bay Local Environmental Plan 2013; • Randwick Development Plan 2013; • Randwick Local Environmental Plan 2012; • Environment Protection Licence; • Notice of Clean Up Action; • Voluntary Management Plan; • Management Order; • Ongoing Maintenance Order; • Remediation Action Plan; • Specific Immobilisation Approval; • Trade Waste Service Agreement; • Pollution Incident Response Management Plan;



• Waste Classification Guidelines o Part 1: Classifying waste o Part 2: Immobilising waste o Part 4: Acid sulfate soils o Addendum to Part 1: Classifying Waste;

• Development Approval conditions; and • Development Approval Statement of Commitments.

4. MANAGEMENT FRAMEWORK SH&E risks should be evaluated, and appropriate controls identified and implemented to reduce the risk to a more acceptable level. The hierarchy of controls may include:

1. Elimination: cease using equipment, substances or procedures/processes causing the risk

2. Substitution: using alternative equipment, substances or processes that pose less risk

3. Isolation: separation of personnel and the environment from the source of the risk

4. Engineering Controls: making physical changes to equipment, processes or the work environment

5. Administrative Controls: adopting work procedures that minimise exposure to risk

6. Personal Protective Equipment (PPE): using equipment such as hearing or respiratory protection, goggles, gloves, etc. Use PPE only if other risk control methods are either impractical or insufficient on their own.

Management strategies for identified SH&E risks are discussed in Section 5.

4.1. SH&E Roles and Responsibilities SH&E roles and responsibilities should be detailed in the work-specific SHEMP. Contact details for those personnel should also be provided.

4.2. Training and Competency All personnel involved in the proposed works should be trained, suitably qualified or experienced to perform tasks associated with their roles.

People who enter site (employees, contractors and visitors) should be inducted and given an overview of site operations and SH&E risks. Training relevant to the SH&E management should be prepared and delivered to employees and contractors alike. The SH&E component of the training should include, but not necessarily be limited to:

• Physical hazards of the worksite(s) and work activities; • Substances handled; • Occupational health and hygiene hazards of the substances handled;



• Biological hazards; • Appropriate personal hygiene controls; • Personal and respiratory protective equipment; • Environmental hazards of the substances handled; • Pollution prevention (e.g., sediment control and spill management); • Dust and odour control; • Waste minimisation and management; • Noise and vibration control; • Soil and groundwater protection; • Stormwater management; • Protection of waterways; • Flora and fauna (protected, endangered, hazardous, etc.); • Traffic management; and • Incident reporting.

A record of personnel training should be kept.

4.3. Internal Communications Internal communication and reporting commitments should be considered. These may include toolbox talks and handover meetings.

4.4. Document Management

5.3.1 Records Management

Complete SH&E records relating to the works should be maintained on site. These may include:

• SH&E monitoring results; • Sampling records, including laboratory chain-of-custody documents and

reports; • Regulator interactions; • Environmental complaints; and • Incidents and Incident Reports, including corrective actions.

4.5. Emergency Preparedness and Response Depending on the nature and scale of the works, an Emergency Response Plan may need to be prepared to identify potential incidents, and competently manage responses to those incidents. Depending on the circumstances (e.g., if the works are being carried out under an Environment Protection Licence), a Pollution Incident Response Management Plan may also be required.

5. SH&E RISK MANAGEMENT MEASURES The following sections detail management strategies for potential SH&E risks.

5.1. Potentially Hazardous Substances Soil and groundwater in the GEEA may be affected by CHCs as mentioned in Section 2.1 and other contaminants. The principal Orica-related contaminants of concern that may be affecting properties within the GEEA are listed in the following table.



Table 1. Principal Orica-Related Contaminants

Name Alternative Name Abbreviation

Carbon tetrachloride Tetrachloromethane CTC

Chloroform Trichloromethane CFM

1,1,2,2-tetrachloroethane Sym tet 1,1,2,2-TeCA

1,1,1-trichloroethane Methyl chloroform 1,1,1-TCA

1,1,2-trichloroethane β-tri 1,1,2-TCA

1,2-dichloroethane Ethylene dichloride EDC (or 1,2-DCA)

Tetrachloroethene Perchloroethene, perchloroethylene PCE

Trichloroethene Trichloroethylene TCE

cis-1,2-dichloroethene - cis-1,2-DCE

trans-1,2-dichloroethene - trans-1,2-DCE

Chloroethene Vinyl chloride VC, VCM

Hexachlorobenzene - HCB

Hexachlorobutadiene - HCBD

Concentrations of Orica-related contaminants of concern are monitored by Orica on a routine basis under a VMP and will continue to be monitored for the duration of the VMP or any regulatory instrument which may replace it. Reports containing the results of the monitoring are submitted to NSW EPA and other regulatory authorities as required, and are published on the Orica BGC Project website6.

Included in each monitoring report are:

• Figure showing locations sampled during that event (generally Fig 3.1); and • Tables of analytical results (refer to tables for volatile CHCs and semi-volatile

CHCs to cover the principal Orica-related soil and groundwater contaminants).

In the biennial reports, figures showing inferred contours of the five main Orica-related contaminants (CTC, PCE, TCE, VC and EDC) are included. It should be noted that these figures show the inferred maximum concentrations of the relevant groundwater contaminant at any depth, and that concentrations between monitoring locations are inferred.

Orica’s monitoring results may be insufficient to develop an appropriate SHEMP for a particular location or particular works. Therefore, sampling and analysis of groundwater in the areas and depths of concern for any proposed intrusive works may be a prudent measure to assist in proper SH&E management.

It should also be noted that there may be other non-Orica related contaminants in shallow groundwater from other sources in the Botany industrial area (e.g., petroleum-related compounds, including benzene, toluene, ethyl benzene and xylenes). For this reason as well, sampling and analysis for all relevant contaminants in groundwater in the areas and depths of concern for proposed intrusive works is recommended.

6 Orica BGC Project monitoring reports https://www.orica.com/Locations/Australia--Pacific-and-Indonesia/Australia/Botany-Remediation-Projects/Projects/Groundwater-Cleanup/Publications--Reports---Reviews/progress-reports#.XcDDSegza70

https://www.orica.com/Locations/Australia--Pacific-and-Indonesia/Australia/Botany-Remediation-Projects/Projects/Groundwater-Cleanup/Publications--Reports---Reviews/progress-reports#.XcDDSegza70





Additional relevant contaminants may be determined by reference to information such as relevant operations and investigation records for the subject site(s), and possibly by consultation with NSW EPA and WaterNSW.

Furthermore, as described in Section 2.2, there are thin layers of naturally-occurring peaty material in the Botany Sands Aquifer. The natural breakdown of the peaty material can release organic substances including Volatile Fatty Acids such as acetic acid, butyric acid and propanoic acid.

A list of relevant hazardous substances and their associated hazards should be prepared for the work-specific SHEMP.

5.2. Safety Hazards and Control Measures Safety hazards will depend on the type and nature of the work. As a general rule, the following information should be prepared or obtained prior to commencing work:

• Description of the worksite and its conditions; • Identification and control of hazards, by one or more of the following methods:

o Hazard Studies; o Safe work methods statement (SWMS); o Safety Management Plan; o Job Safety Analysis (JSA);

• Location of underground services at and in the vicinity of the project site(s) (e.g. Dial Before You Dig, site drawings); and

• If electrical equipment is to be used, it should be tested for safety by electricians and tagged to indicate that the test has been completed.

Only appropriately licensed personnel should operate equipment that requires a licence to be operated (e.g., forklift truck, excavator). Licences should be checked to ensure that they are valid and current.

An exclusion area should be created around the work area(s). Only authorised personnel wearing appropriate personal protective equipment (see Section 5.3.1) should enter the exclusion area.

Excavations should be barricaded and/or covered when left unattended, particularly overnight.

Other precautions and procedural requirements may be relevant depending on the scale and complexity of the works, potential hazards and the specific SH&E requirements of the organisation and/or location.

5.3. Workplace Health Hazards and Control Measures The main occupational health risks are principally associated with direct physical skin contact with contaminated material by unprotected workers. Inhalation of hazardous substances may be a potential risk if groundwater and/or soil with significant concentrations of these substances is encountered. The CHCs listed in Table 1 above are volatile (i.e., will form a vapour), and the vapour is likely to be dense (heavier than air). Therefore, vapours may tend to accumulate and be more concentrated in low-lying areas, particularly excavated pits and trenches.

Risk minimisation actions will likely include a combination of these controls:



• Training: all personnel engaged in the proposed works should receive awareness training regarding the chemical and physical hazards associated with the project (refer to Section 4.2);

• Personal hygiene: all personnel entering the worksite should wash their hands upon leaving the worksite prior to smoking, eating or going to the toilet;

• Containment: access to the worksite should be restricted to only those personnel who have undergone the project induction training; and

• Personal protective equipment (PPE): appropriate PPE is to be worn at all times when in the work area (refer to Section 5.3.1).

5.3.1. Personal Protective Equipment Most sites and operations have specified minimum requirements for PPE.

In general, for work with potential exposure to soil and groundwater in the GEEA the following PPE is suggested: long-sleeved shirts and trousers or overalls, fully enclosed shoes or boots, safety glasses and gloves. Nitrile gloves are suggested if personnel come in contact with groundwater contaminated with CHCs.

It may be necessary for personnel to use supplementary PPE to protect against particular hazards, such as hearing protection for personnel working at or near high noise equipment, or respiratory protective equipment where vapour and dust might present a risk.

Personnel should take care when removing PPE and when showering to prevent particles (e.g. soil or rust) on their PPE or body from entering their eyes or mouth.

5.4. Environmental Hazards and Control Measures The main areas of environmental hazard are soil and groundwater, waste and acid sulphate soils. The control measures for these factors are presented below.

5.4.1. Soil, Groundwater and Surface Water Management Activities involving soil, groundwater and surface waters should be carried out in ways to minimise impact on the ground or receiving water bodies.

Sources

Potential sources of soil erosion are:

• Disturbance of unsealed surfaces through vehicular, equipment or repeated personnel movements;

• Uncontrolled water runoff; and • Soil compaction from vehicle and equipment movement and materials storage.

Potential sources of water pollution are:

• Rainfall runoff conveying sediment or other substances placed or spilt on the ground or otherwise disturbed; and

• Accidental discharge or spillage of substances, contaminated groundwater or construction water to the stormwater system or surface waters (either directly or by runoff across ground or paved surfaces).

Strategies



Soil and groundwater management strategies to prevent impacts on soil, groundwater or surface waters include:

• Excavation activities should be undertaken during dry weather if possible; • Keep soil disturbance to a minimum; • Where the soil surface is disturbed, it should be returned to original condition

(sealed, grassed or covered with pebbles/gravel) on completion of works; • Disturbed soil should be covered and/or contained; • All drilling slurries should be managed in accordance with proper waste

management (Section 5.4.4); • Stockpiles should be clear from drains, gutters and footpaths; • Dewatering fluids should be retained on site pending treatment (subject to

odour control – refer to Section 5.4.2) or, if they are not environmentally harmful, directed to soak-away pits or the sewer (if the discharge is compliant with the conditions of the site’s Trade Waste Service Agreement);

• Liquid and fuel storage and transfer points should be well bunded and located away from drainage and stormwater channels;

• Appropriate sediment controls (e.g., hay bales, silt fences, silt sausages, geotextile fabric, etc.) should be installed at the works boundary to protect all drainage channels in the vicinity of the works prior to the commencement of any excavations;

• Sand bags should be placed between stormwater channel(s) and the works site to intercept runoff from the worksite;

• Spill kits should be available on site; • Wheel wash facilities should be used as required to avoid transportation of

sediments on wheels onto roadways; and • Records of any waste or effluent sampling or disposal should be kept.

Further guidance may be found in Managing Urban Stormwater: Soils and Construction7 (Landcom, 2004).

Monitoring and compliance

The following minimum steps are suggested:

• All erosion and sediment controls should be inspected on a regular basis and after periods of rainfall;

• Adequacy of controls should be re-assessed after any spill or incident; and • Environmental monitoring and auditing procedures should be implemented.

5.4.2. Emissions to Air The contaminants of concern referred to in Section 5.1 have the potential to be harmful to people by inhalation. The naturally-occurring Volatile Fatty Acids – particularly butyric acid – also referred to in Section 5.1 can have a strong odour and have the potential to cause discomfort and possibly nausea for people inhaling them.

For personnel working in potential contact with the groundwater or the vapours emanating from the ground or groundwater, their exposure risks should be adequately managed

7 Managing Urban Stormwater - Soils and Construction https://www.environment.nsw.gov.au/research-and-publications/publications-search/managing-urban-stormwater-soils-and-construction-volume-1-4th-editon

https://www.environment.nsw.gov.au/research-and-publications/publications-search/managing-urban-stormwater-soils-and-construction-volume-1-4th-editon

https://www.environment.nsw.gov.au/research-and-publications/publications-search/managing-urban-stormwater-soils-and-construction-volume-1-4th-editon



planning to control access and duration, as well as use of appropriate personal protective equipment (Section 5.3.1).

Consideration should also be given to minimising odours that may be offensive to passers-by and other people in the vicinity of the works. Such measures may include exclusion zones, restricted working hours, keeping excavations and excavated materials covered as much as practicable, and holding extracted groundwater in closed containers.

5.4.3. Water Management Works carried out at depths lower than the groundwater table may require dewatering. Dewatering within the Botany Sands Aquifer generally requires continuous pumping of groundwater for a prolonged period. Where significant dewatering is required to allow construction to proceed, a licence from the Department of Planning, Industry and Environment - Water will be required.

Tailwater is the water produced through the extraction of groundwater during dewatering. To meet the requirements of the Protection of the Environment Operations Act, tailwater must be disposed of in a manner that doesn’t contaminate surface waters (e.g., discharge into a stormwater drain would not be permissible).

If the dewatering system is not carefully designed and managed it can lead to adverse impacts on the environment including:

• Inflow of contaminated groundwater resulting from excessive or prolonged pumping; • Discharge of contaminated water into stormwater systems and waterways; • Detrimental ‘downstream’ environmental impacts by potential chemical and physical

contamination; and • Impacts on local businesses or residents due to the appearance of the discharge or

the odours generated by the tailwater.

5.4.4. Waste Management Waste management should focus on maximising the reduction, recycling and reuse of waste material during project works. Waste reuse, recycling and disposal should comply with relevant guidelines. Site waste should be tested for contaminants and classified in accordance with the EPA’s Waste Classification Guidelines (see Section 3.2) prior to off-site disposal to ensure a suitable disposal route is used.

5.4.5. Acid Sulfate Soils Management Any works that involve the disturbance of soil below the groundwater table or the disturbance of sediments within the GEEA have the potential to disturb actual or potential acid sulfate soils, although the likelihood is low (refer to Figure 2 below). The soils can form sulfuric acid that can leach into the surrounding area acidifying neighbouring drains, wetlands, creeks, estuaries and bays, causing severe environmental damage. It can also impact on infrastructure by causing serious damage to steel and concrete structures such as the foundations of buildings.

The best way to manage acid sulfate soil is to determine where it might occur and avoid exposing affected soils to oxygen. Avoiding exposure of affected soils is not always possible, in which case an adaptive management approach should be



implemented. Recent research has greatly changed understanding of how to best manage acid sulfate soils8. National guidance documents have also been produced9.

Figure 2. Acid sulfate soil risk in GEEA (screenshot from Sharing and Enabling Environmental Data (SEED), 201910)

There are five classes of land when categorising risk from acid sulfate soils. Each class has corresponding acid sulfate soil risk management requirements, which are broadly managed by planning authorities using the development consent process. Development consent is required for the following classes of land11:

1. Any works. 2. Works below the natural ground surface. Works by which the watertable is likely

to be lowered. 3. Works more than 1 metre below the natural ground surface. Works by which the

watertable is likely to be lowered more than 1 metre below the natural ground surface.

4. Works more than 2 metres below the natural ground surface. Works by which the watertable is likely to be lowered more than 2 metres below the natural ground surface.

8 Department of Primary Industries guidance on acid sulfate soils https://www.dpi.nsw.gov.au/agriculture/soils/ass 9 Water Quality Australia guidance on acid sulfate soils https://www.waterquality.gov.au/issues/acid-sulfate-soils 10 NSW Department of Planning, Industry and Environment acid sulfate soil risk map https://geo.seed.nsw.gov.au/Public_Viewer/index.html?viewer=Public_Viewer&locale=en-AU&runWorkflow=AppendLayerCatalog&CatalogLayer=SEED_Catalog.106 11 Botany LEP 2013 https://www.legislation.nsw.gov.au/#/view/EPI/2013/313/part6/cl6.1

https://www.dpi.nsw.gov.au/agriculture/soils/ass

https://www.waterquality.gov.au/issues/acid-sulfate-soils

https://geo.seed.nsw.gov.au/Public_Viewer/index.html?viewer=Public_Viewer&locale=en-AU&runWorkflow=AppendLayerCatalog&CatalogLayer=SEED_Catalog.106

https://geo.seed.nsw.gov.au/Public_Viewer/index.html?viewer=Public_Viewer&locale=en-AU&runWorkflow=AppendLayerCatalog&CatalogLayer=SEED_Catalog.106

https://www.legislation.nsw.gov.au/#/view/EPI/2013/313/part6/cl6.1



5. Works within 500 metres of adjacent Class 1, 2, 3 or 4 land that is below 5 metres Australian Height Datum and by which the watertable is likely to be lowered below 1 metre Australian Height Datum on adjacent Class 1, 2, 3 or 4 land.

Development consent must not be granted for the carrying out of works unless an acid sulfate soils management plan has been prepared for the proposed works in accordance with the Acid Sulfate Soils Manual12 (NSW ASSMAC, 1998). Figures 3 and 4 are the acid sulfate soil maps relevant to the GEEA taken from the Botany Bay and Randwick Local Environmental Plans (LEPs), respectively.

Figure 3. Acid sulfate soil risk map Sheet ASS_005 (Botany Bay LEP, 201313)

12 Acid Sulfate Soils Manual https://www.epa.nsw.gov.au/~/media/EPA/Corporate%20Site/resources/epa/Acid-sulfate-Manual-1998.ashx 13 Botany Bay LEP Sheet ASS_005 https://www.legislation.nsw.gov.au/maps/0d51b97e-2dba-e76d-f32e-8e40e5c71903/1100_COM_ASS_005_010_20130224.pdf

https://www.epa.nsw.gov.au/%7E/media/EPA/Corporate%20Site/resources/epa/Acid-sulfate-Manual-1998.ashx

https://www.epa.nsw.gov.au/%7E/media/EPA/Corporate%20Site/resources/epa/Acid-sulfate-Manual-1998.ashx

https://www.legislation.nsw.gov.au/maps/0d51b97e-2dba-e76d-f32e-8e40e5c71903/1100_COM_ASS_005_010_20130224.pdf

https://www.legislation.nsw.gov.au/maps/0d51b97e-2dba-e76d-f32e-8e40e5c71903/1100_COM_ASS_005_010_20130224.pdf



Figure 4. Acid sulfate soil risk map Sheet ASS_004 (Randwick LEP, 201214)

Strategies

Identifying ASS

Site personnel involved in drilling or excavation should be trained in the consequences of disturbing ASS and in recognising the indicators of ASS in the field. These include, but are not necessarily limited to:

• Red brown iron stains in the soil; • Yellow jarositic mottles in the soil; • Sulphide odours; and • Evidence of physical attack of concrete.

A field pH testing kit should be made available and any suspect soils should be tested before work continues (Ahern et al., 2004). The pH of all drilling muds and slurries should be tested.

All field observations and pH testing should be recorded together with location and action taken.

Handling ASS

As stated above, an acid sulfate soils management plan has been prepared for the proposed works in accordance with the Acid Sulfate Soils Manual (NSW ASSMAC, 1998).

14 Randwick LEP Sheet ASS_004 https://www.legislation.nsw.gov.au/maps/a1d61ffc-4bf8-c161-8847-ba52e6b2b03e/6550_COM_ASS_004_010_20121113.pdf

https://www.legislation.nsw.gov.au/maps/a1d61ffc-4bf8-c161-8847-ba52e6b2b03e/6550_COM_ASS_004_010_20121113.pdf

https://www.legislation.nsw.gov.au/maps/a1d61ffc-4bf8-c161-8847-ba52e6b2b03e/6550_COM_ASS_004_010_20121113.pdf



Excavated material should be exposed to the air for the minimum duration possible as acid may be leached within hours of exposure. Spoil containing ASS should be managed in accordance with NSW EPA Waste Classification Guidelines Part 4: Acid Sulphate Soils15.

Any water that is pumped from excavations containing acid sulfate soils should be treated as contaminated.

All activities associated with acid sulfate soils should be documented.

6. SHEMP REVIEW

6.1.1. Assessment of Implementation Monitoring of SH&E performance against the SHEMP may include:

• Monitoring – regular monitoring is suggested, depending on the duration and nature of the work;

• Auditing – to verify that the safeguards are being carried out during the work; • Corrective Action – corrective action should be instigated if non-conformance

is found during an audit; and • Review – amendments to the SHEMP may be considered following any

significant incident, where there is a significant change to the scope of the project, or where inadequate performance is identified.

6.1.2. SHEMP Updates This Generic SHEMP for the Botany GEEA will be reviewed periodically as new information (e.g., regarding the nature or extent of the contamination) or legislative requirements come to light. The Generic SHEMP will be updated and re-issued if any changes have occurred.

7. REFERENCES Ahern C.R., McElnea, A.E. and Sullivan, L.A. (2004). Acid Sulfate Soils Laboratory Methods Guidelines. Queensland Department of Natural Resources, Mines and Energy, Indooroopilly, Queensland, Australia. June 2004.

Landcom (2004). Managing Urban Stormwater: Soils and Construction. 4th ed. March 2004.

NSW Acid Sulphate Soil Management Advisory Committee (NSW ASSMAC) (1998). Acid Sulphate Soil Manual. NSW Agriculture. 26 August 1998.

Orica (2017). Conceptual Site Model – Orica Botany. Orica Australia Pty Ltd. Rev. 2. 20 September 2017.

15 NSW EPA Waste Classification Guidelines Part 4: Acid Sulphate Soils https://www.epa.nsw.gov.au/~/media/EPA/Corporate%20Site/resources/wasteregulation/140798-acid-sulfate-soils.ashx

https://www.epa.nsw.gov.au/%7E/media/EPA/Corporate%20Site/resources/wasteregulation/140798-acid-sulfate-soils.ashx

https://www.epa.nsw.gov.au/%7E/media/EPA/Corporate%20Site/resources/wasteregulation/140798-acid-sulfate-soils.ashx

generic safety, health and environmental management plan

Documents