NOVEMBER 201501 SYDNEY SITE AUDIT TEAM CELEBRATES

AT OPENING OF BARANGAROO RESERVE

02 SITE AUDITOR TEAM GROWS AT RAMBOLL ENVIRON

03 CLEANUP 2015

04 NICNAS REFORMS: OVERHAUL OF AUSTRALIAN INDUSTRIAL CHEMICAL ASSESSMENT PROCESS

05 WA EPA RELEASES NEW ENVIRONMENTAL ASSESSMENT GUIDELINE FOR PREPARATION OF MANAGEMENT PLANS

06 UNDERSTANDING AND ASSESSING GROUND-LEVEL OZONE IMPACTS IN NSW

AUSTRALIA UPDATE

SYDNEY SITE AUDIT TEAM CELEBRATES AT OPENING OF BARANGAROO RESERVERamboll Environ staff were among the first to experience Sydney’s newly completed Barangaroo Reserve at a special picnic day for those involved in the iconic harbour front redevelopment. Auditors and staff from the Sydney office have worked on the project since 2009, after being engaged by the Barangaroo Delivery Authority to provide site audit services.

Barangaroo Reserve is located at the northern end of the twenty-two-hectare Barangaroo site on Sydney’s harbour front. The former industrial land is being redeveloped in stages to include a mix of public open space and commercial and residential developments.

The reconstructed six hectare headland reserve, being handed back to the public as recreational open space, features sandstone blocks quarried from beneath the site recreating the natural shoreline and includes a cultural centre built inside

the headland. The cultural centre, known as the Cutaway, features a six-storey high sandstone cut face.

Site audits have been required during the redevelopment process to ensure the various parts of the site are suitable for their intended uses. Graeme Nyland, Managing Principal of the Sydney office and NSW EPA-accredited contaminated land site auditor, is the site auditor for the Barangaroo development. Graeme’s projects cover separate portions of the site for two different clients—the Barangaroo Delivery Authority and Lend Lease. The audit has involved review of investigations, remediation action plans and remediation works undertaken. The first commercial building was opened in Barangaroo South in July 2015, with further buildings set to open in the coming months. Remediation of a former gasworks will be required as development continues.

Graeme has been assisted in a number of different aspects of the site audit by the four other EPA-accredited contaminated land site auditors from the Sydney office. The team was excited to bring along their families to enjoy the new parkland and celebrate with other workers involved in the project at the family wrap picnic hosted by the Barangaroo

Delivery Authority. The picnic was a fitting reward for the hard work to date by all involved in the Barangaroo Reserve project, as they continue to work on the remaining portions to complete this landmark development (see photo on next page).

Barangaroo Reserve 2012 (bottom) and 2015 (top). Photos courtesy of Barangaroo Delivery Authority

AUSTRALIA UPDATE ISSUE 6 2

Sydney auditors at the Barangaroo Reserve open day (from left): Tom Onus, Melissa Porter, Graeme Nyland, Rowena Salmon and Julie Evans

SITE AUDITOR TEAM GROWS AT RAMBOLL ENVIRONThe site auditor team at Ramboll Environ has grown with two existing staff recently becoming accredited. Fiona Robinson from our Hunter office and Tom Onus from our Sydney office have received their accreditation as site auditors under the New South Wales Contaminated Land Management Act (1997) (NSW CLM Act). They join the established team of auditors in the Sydney office, including Graeme Nyland, Melissa Porter, Rowena Salmon and Julie Evans.

The NSW site auditor scheme is administered by the Environment Protection Authority (EPA) and aims to ensure the protection of the

environment and human health through proper management of contaminated land, particularly during changes in land use. Accredited site auditors can be engaged to independently review reports on assessment, remediation, management and validation actions to ensure that the methodology used by consultants and their interpretation of data are consistent with current EPA regulations and guidelines.

The NSW Auditor accreditation process is held every two to three years, with only four new auditors appointed during the 2015 process. Graeme Nyland is also an accredited Site Auditor for Western Australia under the Contaminated Sites Act 2003.

For contaminated land auditing enquiries contact the Sydney office (02 9954 8100) or the Hunter office (02 4962 5444). 

CLIMATE CHANGE IMPACTS ON SITE INVESTIGATION AND REMEDIATION WORKS: CLEANUP 2015The impact of climate change on site investigation and remediation works were key topics addressed by Ramboll Environ staff at the CRC Care 2015 CleanUp conference in Melbourne in September.

Principal Scott Warner (Emeryville) gave a keynote presentation entitled The Influence of Climatic Uncertainty on Groundwater Restoration Methods and was the moderator for the afternoon panel on climate change and environmental remediation.

Scott, a Principal in our global water practice, has more than 27 years of experience in consulting hydrogeology, with specific expertise in water resources management, groundwater and in situ remediation. Scott’s presentation discussed how historic approaches to remediation have assumed relatively stable hydraulic

conditions at subject sites. The general acceptance that changing climatic conditions are strongly influencing hydraulic characteristics means past conditions may no longer be as reliable a predictor of future conditions. This therefore requires a new paradigm of remedial design considerations for contaminant clean up and groundwater protection.

Meanwhile Principal Stella Whittaker (Sydney) presented a platform talk Implications of Climate Change for Site Assessment, Management and Remediation and also participated in the afternoon panel. Stella has 30 years of executive management, business development and consulting experience in the areas of environmental, sustainability, urban planning and climate resilience consulting—the past 10 years of which focused on climate resilience, risk assessment, due diligence and adaptation pathways.

Stella’s presentation at the conference discussed the need to ensure that those responsible for planning or designing cities and new infrastructure or making strategic decisions take account of the projected climate over the applicable life span. Stella noted it is imperative for all environment professionals involved in contaminated site assessment, management and remediation to embed future climate considerations into their work.

The CleanUp biannual conference in Australia attracts scientists, engineers, regulators and other environmental professionals representing universities, government (site management and regulatory agencies) and R&D and manufacturing firms from more than 20 countries.

AUSTRALIA UPDATE ISSUE 6 3

NICNAS REFORMS: OVERHAUL OF AUSTRALIAN INDUSTRIAL CHEMICAL ASSESSMENT PROCESSThe Australian Government recently announced sweeping reforms to the National Industrial Chemicals Notification and Assessment Scheme (NICNAS), simplifying the assessment process for industrial chemicals to reduce regulatory burden on industry, while maintaining current health and environmental protections. The reforms follow an extensive review of NICNAS, conducted in consultation with stakeholders from industry, government and the public domain during 2012 and 2013, that identified a number of key issues associated with the NICNAS assessment framework that were

affecting effective regulatory outcomes.

The objective of the reforms is to refocus the efforts of NICNAS on higher risk industrial chemicals, by adopting a risk-based framework to match each assessment effort to the risk profile of each individual chemical. Implementation of the reforms will see chemicals classed according to one of following three categories:

Class 1 – Very Low Risk Chemicals

• These substances will be allowed immediate entry and will not require pre-entry notification or assessment, or post-market annual compliance declaration.

• Introducers will be required to keep records and may be audited for compliance. Usage will remain subject to existing state and territory regulation.

Class 2 – Low Risk Chemicals

• Introduction of Class 2 chemicals will be allowed following self-assessment

against criteria and pre-entry notification to NICNAS, which should include trade name, chemical name, CAS number (where available), hazard classification and/or information, volume (to be introduced) and intended use.

• Introducers will have to provide a yearly compliance declaration to confirm the class criteria and NICNAS will undertake annual audits for a proportion of notifications to validate compliance.

Class 3 – Medium to High Risk Chemicals

• An assessment certificate will be necessary before introduction of Class 3 chemicals, including details of the particulars and conditions of use (i.e. extent of the risk assessment undertaken, allowable annual volume, sites of use, time-limited certificate).

• Risk assessments will be conducted within a statutory period and a summary of the assessment will be published.

• Where risks cannot be managed (either by conditions of introduction or imposition of risk management conditions by risk management agencies), a certificate may be refused.

• NICNAS will undertake post-market auditing to ensure compliance and may initiate a post-market assessment if a possible new risk is identified.

Implementation of the risk-based framework is expected to significantly reduce the regulatory costs borne by industry. It is anticipated that more

than 70% of new chemicals currently assessed by NICNAS will be introduced as Class 1 or Class 2 via industry self-assessment, thereby reducing the time to market and the cost of assessment. The faster introduction of lower risk chemicals is expected to provide an incentive to introduce safer new industrial chemicals to replace more hazardous existing chemicals.

Although the reforms will mean less emphasis on pre-market assessment for lower risk chemicals, the Australian Government is confident the increased focus on post-market assessment and auditing practices will assist NICNAS in maintaining the health and safety of consumers, workers and the environment. Improved compliance powers are also expected to help NICNAS manage non-compliance more effectively.

An implementation plan was launched on 16 September 2015 and the Office of Chemical Safety has begun work on the reforms, which are expected to be fully implemented by September 2018. The first of four consultation papers was released for public comment on 31 October 2015, seeking stakeholder feedback regarding the criteria proposed to distinguish between new chemicals in Classes 1, 2 and 3. Information workshops will be held in Sydney and Melbourne in November and submissions are due by 14 December 2015. Subsequent consultation papers are expected to address the detailed data requirement for each of the classes.

Further information regarding the reforms can be found on the NICNAS website or by contacting Ruth Peiffer (08 9225 5199).

AUSTRALIA UPDATE ISSUE 6 4

The Western Australian Environmental Protection Authority (EPA) recently released a new Environmental Assessment Guideline (EAG17) to provide guidance on the preparation of environmental management plans (EMPs) required under Part IV of the Environmental Protection Act 1986. EAG17 was formally released in a presentation to industry, consultants and other interested parties, by the EPA on 27 August 2015.

Additionally, the EPA has revised its guidance for recommending environmental conditions (EAG11), to broadly align with guidance on conditions under the Commonwealth Environment Protection and Biodiversity Conservation Act 1999 and EAG 17.

EAG17 guidance relates to Condition EMPs that are specified in approval conditions for a project. Condition EMPs will either be outcome based or management based. A condition requiring preparation of an outcome-based Condition EMP for a particular environmental factor, will set out the proposal-specific environmental outcome (e.g. maintain groundwater levels at X metres from the baseline groundwater level at monitoring sites A, B and C). A condition requiring

preparation of a management-based Condition EMP will specify what the management actions should achieve (e.g. manage discharges to the creek to minimise impacts to riparian vegetation as far as practicable).

Proponents will be required to prepare a Condition EMP in accordance with the EPA’s templates for outcome-based and management-based plans, which will follow the format at right.

The EPA has issued templates for outcome-based and management-based Condition EMPs available at www.epa.wa.gov.au/EIA/templates/Pages/default.aspx.

The guidance takes into account the dynamic nature of ecosystems and supports an adaptive management approach, where mitigation measures and monitoring may be adapted based on what has been learnt through implementation of the Condition EMP. Proponents must formally seek approval from the Office of the EPA to amend a provision of a Condition EMP, based on information gained through an adaptive management approach.

EAG17 is available on the EPA’s website.

For more information, contact Kirsty Pope (08 9225 5199).

Format of Condition EMPs

Outcome-Based EMP Management-Based EMP

Condition environmental outcome Condition environmental objective

Performance indicators • Trigger criteria• Threshold criteria

Management actions to mitigate impacts

Response actions• Trigger-level actions• Threshold contingency actions

Management targets

Monitoring Monitoring

Reporting Reporting

WA EPA RELEASES NEW ENVIRONMENTAL ASSESSMENT GUIDELINE FOR PREPARATION OF MANAGEMENT PLANS

AUSTRALIA UPDATE ISSUE 6 5

UNDERSTANDING AND ASSESSING GROUND-LEVEL OZONE IMPACTS IN NSW Why is ozone assessment important?

Short-term exposure to ozone pollution results in a range of health effects. While the strongest evidence is for respiratory effects, there is also a significant body of evidence to suggest that short-term exposure contributes to cardiopulmonary-related mortality.1 Annual mortality attributable to current short-term ozone exposure above background is estimated to be equivalent to approximately 3.7% of deaths at typical ages and 3.4% of annual childhood hospital emergency department attendances for the Sydney region.2 The health costs of air pollution, in the NSW Greater Metropolitan Region (GMR) have been calculated at $4.7 billion per annum.3

All areas of the Sydney region are currently classified as “non-attainment” for ozone, meaning they exceed an acceptance limit expressed as 82% of the NEPM standard and exceedances of the one-hour and four-hour NEPM standards occur in most years.

Guidance for ozone impact assessment in NSW

The formation of secondary pollutants, such as ozone, occurs through photochemical reactions from emissions of precursor gases, including oxides of nitrogen (NOx) and volatile organic compounds. Ozone impacts are assessed on regional scales.

The relationship between ozone formation and emissions of precursor gases is not linear. For example NOx emissions can lead to both formation and destruction of ozone, and the modelling and assessment of these photochemical reactions is complex.

In May 2015, the NSW Environment Protection Authority (EPA) published the “tiered procedure for estimating ground-level ozone impacts from Stationary Sources”, which was developed by Ramboll Environ on their behalf.4 Ramboll Environ also developed a screening tool which can be used as a ‘first pass’ (Level 1) assessment of ozone impacts.5 If the screening tool identifies ozone concentrations above a significant impact level, a refined (Level 2) ozone assessment may then be required.

The screening tool is based on the CAMx photochemical model, one of two models used by the USEPA to develop air quality regulations for ozone and secondary particulate matter.6 CAMx was developed and is actively maintained by Ramboll Environ and was recently used in a Level 2 ozone assessment for a significant infrastructure project in Western Sydney.

For further information, please contact Ronan Kellaghan (02 9954 8136).

1 http://cfpub.epa.gov/ncea/isa/recordisplay.cfm?deid=247492

2 https://www.environment.gov.au/system/files/pages/dfe7ed5d-1eaf-4ff2-bfe7-dbb7ebaf21a9/files/summary-policy-makers-hra-air-pollution-australia.pdf

3 http://www.epa.nsw.gov.au/resources/aqms/airpollution05623.pdf

4 http://www.epa.nsw.gov.au/resources/air/estimating-ground-level-ozone-report.pdf

5 http://www.epa.nsw.gov.au/resources/air/150507-ozone-procedure-tool.xls

6 http://www3.epa.gov/airtransport/pdfs/AQModeling.pdf