Remediation of 2 Christina Road Villawood, NSW ...

Remediation of 2 Christina Road, Villawood

Remediation of 2 Christina Road Villawood, NSW – Environmental Assessment February 2011

Prepared for:

Orica Australia Pty Ltd

Report by:

Thiess Services Pty Ltd

ABN: 69 010 725 247

88 Phillip Street Parramatta NSW 2150

PO Box 201 Parramatta CBD BC 2124

Ph: +61 2 8892 5900

Fax: +61 2 8892 5901

Thiess Services Ref: 050003


EA Orica Villawood FINAL February 2011

Statement of Validity Submission of Environmental Assessment Prepared under Part 3A of the Environmental Planning and Assessment Act 1979 Environmental Assessment prepared by Name John Hunt Qualifications Doctor of Philosophy Earth Sciences Technical Services Manager Address Thiess Services Pty Ltd Level 3, 88 Phillip Street Parramatta NSW 2150 In respect of Applicant & Land Details Applicant Orica Australia Pty Ltd 1 Nicholson Street Melbourne VIC 3001 Land to be Developed Part of Lot 1, DP 634604 Bankstown Local Government Area Project Summary Remediation of contaminated soil on site by thermal desorption Environmental Assessment An Environmental Assessment is attached Declaration I certify that I have prepared the contents of the Environmental Assessment in accordance with the requirements of the Environmental Planning and Assessment Act 1979 and Regulation and that, to the best of my knowledge, the information contained in this report is not false or misleading. Signature Name John Hunt Date


EA Orica Villawood FINAL February 2011


EA Orica Villawood FINAL

February 2011 i

CONTENTS

ABBREVIATIONS...................................... ................................................................................ VIII

EXECUTIVE SUMMARY ........................................................................................................ ES-1

1 INTRODUCTION ........................................................................................................ 1-1

1.1 Proposal Overview ...................................................................................... 1-1

1.2 Project Context and Objective ..................................................................... 1-1

1.3 Site Identification ......................................................................................... 1-2

1.4 Landuse and Zoning.................................................................................... 1-2

1.5 The Proponent ............................................................................................. 1-3

1.6 Environmental Assessment Process........................................................... 1-3

1.7 Environmental Assessment Requirements ................................................. 1-4

2 STATUTORY PLANNING ................................. ......................................................... 2-1

2.1 Local Planning Instruments ......................................................................... 2-1

2.1.1 Bankstown Local Environmental Plan 2001................................. 2-1

2.1.2 Development Control Plan 2005 .................................................. 2-2

2.2 State Planning Policies................................................................................ 2-2

2.2.1 Environmental Planning and Assessment Act 1979 .................... 2-2

2.2.2 State Environmental Planning Policy (Major Development) 2005...................................................................... 2-2

2.2.3 State Environmental Planning Policy 55 – Remediation of Land ............................................................................................. 2-4

2.2.4 Protection of the Environment Operations Act 1997.................... 2-5

2.2.5 Contaminated Land Management Act 1997 ................................ 2-5

2.2.6 Environmentally Hazardous Chemicals Act 1985 ........................ 2-6

2.2.7 Water Act 1912............................................................................. 2-7

2.2.8 State Environmental Planning Policy 33 – Hazardous and Offensive Development................................................................ 2-7

2.2.9 Greater Metropolitan Regional Environmental Plan No 2 – Georges River Catchment......................................................... 2-8

2.3 Commonwealth Matters............................................................................. 2-10

2.3.1 Environment Protection and Biodiversity Conservation Act 1999 ..................................................................................... 2-10

3 THE SITE AND CONTEXT......................................................................................... 3-1

3.1 Site History .................................................................................................. 3-1

3.2 Site Investigations ....................................................................................... 3-1



February 2011 ii

4 ASSESSMENT OF REMEDIATION ALTERNATIVES ............. ................................. 4-1

4.1.1 First Stage of Assessment ........................................................... 4-1

4.1.2 Second Stage of Assessment ...................................................... 4-2

4.2 Remedial Technology Assessment Summary............................................. 4-3

4.2.1 Alternative Remediation Technologies ........................................ 4-3

4.2.2 Directly-heated Thermal Desorption ............................................ 4-3

4.2.3 Indirectly-heated Thermal Desorption.......................................... 4-4

4.2.4 Electrical Conductive Heating ...................................................... 4-5

4.3 Selection of Preferred Remediation Option................................................. 4-5

5 PROJECT DESCRIPTION ......................................................................................... 5-1

5.1 Overview of the Project ............................................................................... 5-1

5.2 Site Establishment and Construction .......................................................... 5-1

5.3 Water Management ..................................................................................... 5-2

5.4 Soil Treatment Facility ................................................................................. 5-3

5.4.1 Feed Soil Building ........................................................................ 5-3

5.4.2 Directly-heated Thermal Desorption Plant ................................... 5-4

5.5 Decommissioning ........................................................................................ 5-7

5.6 Reinstatement of Site .................................................................................. 5-7

5.7 Access and Transport.................................................................................. 5-7

5.7.1 Access.......................................................................................... 5-7

5.7.2 Vehicle Movements and Parking ................................................. 5-7

5.7.3 Transportation of Material ............................................................ 5-8

5.8 Control of Site Entry and Exit ...................................................................... 5-9

5.9 Environmental Controls ............................................................................. 5-10

5.10 Waste Management .................................................................................. 5-11

5.11 Program of Works...................................................................................... 5-12

5.12 Utilities and Resources.............................................................................. 5-12

5.12.1 Natural Gas ................................................................................ 5-13

5.12.2 Electricity .................................................................................... 5-13

5.12.3 Diesel ......................................................................................... 5-13

5.12.4 Potable Water............................................................................. 5-13

5.13 Auditing and Validation.............................................................................. 5-13

6 CONSULTATION AND ISSUES IDENTIFICATION ............. ..................................... 6-1

6.1 Formal Procedures for Consultation............................................................ 6-1

6.1.1 New South Wales Formal Procedures......................................... 6-1

6.2 Consultation with Stakeholders and Other Relevant Authorities................. 6-5

6.2.1 Statutory and other relevant authorities ....................................... 6-6

6.2.2 Community Consultation ............................................................ 6-23

6.3 Ongoing Consultation ................................................................................ 6-28



February 2011 iii

7 ISSUES PRIORITISATION......................................................................................... 7-1

7.1 Issues Identification ..................................................................................... 7-1

7.2 Prioritisation of Issues ................................................................................. 7-1

7.3 Initial Assessment........................................................................................ 7-1

7.4 Community Views........................................................................................ 7-3

7.5 Final Assessment ........................................................................................ 7-4

8 ASSESSMENT OF KEY ENVIRONMENTAL IMPACTS............ ............................... 8-1

8.1 Soil ............................................................................................................... 8-1

8.1.1 Existing Environment ................................................................... 8-1

8.1.2 Soil Remediation Criteria ............................................................. 8-2

8.1.3 Soil Treatment Criteria ................................................................. 8-4

8.1.4 Contaminated Soil Characterisation ............................................ 8-5

8.1.5 Potential Impacts.......................................................................... 8-8

8.1.6 Environmental Safeguards........................................................... 8-8

8.1.7 Residual Impacts.......................................................................... 8-9

8.1.8 Conclusion.................................................................................... 8-9

8.2 Groundwater and Surface Water............................................................... 8-10

8.2.1 Existing Environment ................................................................. 8-10

8.2.2 Potential Impacts........................................................................ 8-11

8.2.3 Environmental Safeguards......................................................... 8-12

8.2.4 Residual Impacts........................................................................ 8-12

8.2.5 Conclusion.................................................................................. 8-13

8.3 Air Quality .................................................................................................. 8-13





8.3.5 Conclusion.................................................................................. 8-31

8.4 Noise.......................................................................................................... 8-32

8.4.1 Introduction................................................................................. 8-32

8.4.2 Existing Environment and Noise Criteria ................................... 8-32


8.4.4 Noise Modelling.......................................................................... 8-34

8.4.5 Assessment of Predicted Noise Levels...................................... 8-35

8.4.6 Traffic Noise ............................................................................... 8-36

8.4.7 Vibration ..................................................................................... 8-36



8.4.10 Conclusion.................................................................................. 8-37



February 2011 iv

8.5 Hazards and Risk ...................................................................................... 8-38

8.5.1 Introduction................................................................................. 8-38




8.5.5 Conclusion.................................................................................. 8-41

8.6 Human Health Risk.................................................................................... 8-41





8.6.5 Conclusion.................................................................................. 8-46

8.7 Cumulative Impacts ................................................................................... 8-46

9 ASSESSMENT OF NON-KEY ENVIRONMENTAL IMPACTS........ .......................... 9-1

9.1 Social Impacts ............................................................................................. 9-1

9.2 Visual Impacts ............................................................................................. 9-2

9.3 Traffic and Access ....................................................................................... 9-3

9.4 Flora and Fauna .......................................................................................... 9-3

9.5 Heritage ....................................................................................................... 9-4

9.6 Land Use and Services ............................................................................... 9-5

10 STATEMENT OF COMMITMENTS.......................................................................... 10-1

10.1 Introduction ................................................................................................ 10-1

10.2 Statement of Commitments ....................................................................... 10-1

11 RESIDUAL RISK ANALYSIS............................. ...................................................... 11-1

11.1 Approach ................................................................................................... 11-1

11.2 Analysis ..................................................................................................... 11-3

12 PROPOSAL JUSTIFICATION AND CONCLUSION .............. ................................. 12-1

12.1 Project Justification.................................................................................... 12-1

12.1.1 Biophysical ................................................................................. 12-1

12.1.2 Economic.................................................................................... 12-2

12.1.3 Social.......................................................................................... 12-3

12.2 Ecologically Sustainable Development ..................................................... 12-3

12.2.1 Precautionary Principle .............................................................. 12-4

12.2.2 Intergenerational Equity ............................................................. 12-5

12.2.3 Biological Diversity and Ecological Integrity............................... 12-5

12.2.4 Valuation and Pricing of Environmental Resources................... 12-6

12.2.5 Decision Making Process........................................................... 12-6

12.3 Climate Change and Greenhouse Effect................................................... 12-6

12.4 Consequences of Not Proceeding............................................................. 12-7

12.5 Conclusion ................................................................................................. 12-8

13 REFERENCES ......................................................................................................... 13-1



February 2011 v

TABLES

Table 6-1: Director-General's Requirements .......................................................................... 6-1

Table 6-2: Statutory Requirements for EA (Including EP&A Regulation Clause 51 Matters). 6-4

Table 6-3: Government Agency Requirements and EA Reference ........................................ 6-6

Table 8-1: Remediation Criteria .............................................................................................. 8-3

Table 8-2: Soil Remediation and Treatment Criteria............................................................... 8-5

Table 8-3: Contaminated Soil Characterisation for FSB and DTD ......................................... 8-7

Table 8-4: Summary of monitoring data recorded at Chullora monitoring

station (2008, 2009) ............................................................................................. 8-14

Table 8-5: DECCW Impact Assessment Criteria for SO2, NO2, PM10, TSP, CO and HF ..... 8-15

Table 8-6: DECCW Impact Assessment Criteria for deposited dust .................................... 8-15

Table 8-7: DECCW Impact Assessment Criteria for toxic air pollutants ............................... 8-16

Table 8-8: DECCW Impact Assessment Criteria for odorous air pollutants ......................... 8-16

Table 8-9: Predicted concentration of Category 1 pollutants at surrounding sensitive

receptors from the Project, 30 m DTD Plant stack .............................................. 8-20

Table 8-10: Maximum predicted ground level SO2 concentrations at any offsite sensitive

receptors (µg/m³) ................................................................................................. 8-21

Table 8-11: Maximum predicted ground level NO2 concentrations at any offsite sensitive

receptors (µg/m³) ................................................................................................. 8-21

Table 8-12: Maximum predicted ground level CO concentrations at any offsite sensitive

receptors (mg/m³) ................................................................................................ 8-22

Table 8-13: Maximum predicted ground level PM10 concentrations at any offsite sensitive

receptors (µg/m³) ................................................................................................. 8-22

Table 8-14: Predicted maximum offsite concentrations for toxic air pollutants (listed in

DECCW guideline)............................................................................................... 8-24

Table 8-15: Predicted maximum offsite concentrations for toxic air pollutants (not listed in

DECCW guideline)............................................................................................... 8-25

Table 8-16: Predicted Peak Concentrations of Volatile Chlorinated Organic Compounds..... 8-27

Table 8-17: Revised Predicted Peak Concentrations of Volatile Chlorinated Organic

Compounds.......................................................................................................... 8-28



February 2011 vi

TABLES (cont'd)

Table 8-18: Noise Criteria ....................................................................................................... 8-32

Table 8-19: Sleep Disturbance Criteria ................................................................................... 8-33

Table 8-20: Source Noise Levels ............................................................................................ 8-34

Table 8-21: Scope of Works for Noise Generating Activities in Stages.................................. 8-34

Table 8-22: Predicted Operational Noise Levels, LAeq,15min ..................................................... 8-35

Table 8-23: Predicted Noise Level, Evening and Night Time, LAeq,period dBA.......................... 8-35

Table 10-1: Statement of Commitments ................................................................................. 10-1

Table 11-1: Residual Risk Matrix ............................................................................................ 11-2

Table 11-2: Risk Profile........................................................................................................... 11-3



February 2011 vii

FIGURES

Figure 1 Location of Orica Villawood Site

Figure 2 Land Subject of Proposal ‘The Site’

Figure 3 Zoning Plan

Figure 4 Sensitive Surrounding Land Uses

Figure 5 General Arrangement

Figure 6 Internal Haulage Routes

Figure 7 Water Management

Figure 8 Conceptual Layout of Feed Soil Building and DTD Area

Figure 9 DTD Process Flow Diagram

Figure 10 Remediation Areas

Figure 11 Air Quality Receptors

Figure 12 Noise Receptors

Figure 13 Site Access and Key Traffic Routes

APPENDICES

Appendix A Record of Ministers Opinion

Appendix B Environmental Assessment Requirements (DGR)

Appendix C Site Identification

Appendix D Remedial Action Plan

Appendix E Regulatory Compliance

Appendix F Agency Responses

Appendix G Human Health and Environmental Risk Assessment

Appendix H Air Quality Assessment

Appendix I Human Health Impact Assessment

Appendix J Noise Assessment

Appendix K Preliminary Hazard Analysis

Appendix L Visual Assessment

Appendix M Bushland Management Plan

Appendix N Aboriginal Cultural Assessment

Appendix O Groundwater Monitoring Program



February 2011 viii

ABBREVIATIONS

Abbreviation Defnition

AADT Annual Average Daily Traffic

BCC Bankstown City Council

CCO Chemical Control Order

CEMP Construction environmental management plan

CHAZOP Control Hazard and Operability Study

Cl2 Chlorine

CLM Act Contaminated Land Management Act 1997

CNVMP Construction Noise and Vibration Management Plan

CO2 Carbon dioxide

CoC chemicals of concern

CTC carbon tetrachloride

DCP Development Control Plan

DECCW Department of Environment Climate Change and Water

DGRs Director General’s Requirements

DNR Department of Natural Resources

DoP Department of Planning

DP Deposited plan

DTD Directly-heated thermal desorption

EA Environmental assessment

EAR Environmental Assessment Requirements

EASR Environmental Assessment Scoping Report

ECS Emission control system

EDC 1,2-dichloroethane

EHC Act Environmentally Hazardous Chemicals Act 1985

EP&A Act Environmental Planning and Assessment Act 1979

EPA Environment Protection Authority

EPBC Act Environment Protection and Biodiversity Conservation Act 1999

EPL Environment protection licence

ERP Emergency Response Plan

ESD Environmentally Sustainable Development

GLC Ground level concentration

HAZOP Hazard and Operability study



February 2011 ix

Abbreviation Defnition

HCB Hexachlorobenzene

HCl Hydrogen chloride

HHIA Human Health Impact Assessment

ID Induced Draught

INP NSW Industrial Noise Policy

ITD Indirectly-heated Thermal Desorption

LEP Local environment plan

LGA Local Government Area

NEPC National Environment Protection Council

NEPM National Environment Protection Measure

NP&W Act National Parks and Wildlife Act 1974

NSW New South Wales

OH&S Occupational Health and Safety

OHSP Occupational Health and Safety Plan

PCB Polychlorinated biphenyls

PCE Tetrachloroethene

PHA Preliminary Hazard Analysis

POEO Act Protection of the Environment Operations Act 1997

PPE Personal protective equipment

Pt Part

QA Quality assurance

RAP Remediation Action Plan

SCW Scheduled Chemical Wastes

SEPP State Environmental Planning Policy

SoC Statement of commitments

SSF Secure Soil Facility

SSO Site Safety Officer

STA Soil Treatment Area

TCE Trichloroethylene

TMP Traffic Management Plan

TPH Total petroleum hydrocarbons

US United States

VOC Volatile Organic Compound

WTP Water Treatment Plant



February 2011 x


EA Orica Villawood FINAL February 2011 ES - 1

EXECUTIVE SUMMARY

Introduction

The proposed project is the remediation of part of the former chemical manufacturing facility owned by Orica Australia Pty Ltd (Orica) at 2 Christina Road Villawood in the Local Government Area of Bankstown. The proposed remediation works would allow the Site to be returned to a standard suitable for ongoing industrial use. The Site contains certain waste by-products of previous industrial activities including total petroleum hydrocarbons, benzene, DDT (and its degradation products DDD and DDE), 1,2-dichloroethane (1,2-DCA), Trichloroethene (TCE),Chlorobenzene (MCB), 1,4-dichlorobenzene (1,4-DCB), Hexachlorobenzene (HCB), Lindane (a-BHC), Polycyclic Aromatic Hydrocarbons (PAHs), including Benzo(a)pyrene (BaP), and Cyanide. The proposed remediation works fall within the type of development identified in Group 9 of Schedule 1 to State Environmental Planning Policy (Major Projects) 2005 (SEPP 2005) and are therefore eligible for assessment under Part 3A of the Environmental Planning and Assessment Act 1979 (EP&A Act). A project approval is therefore being sought for the proposed works (Appendix A) . The Site is surrounded on three sides by light industrial facilities and to the south by Christina Road which is used for primarily for commercial purposes. The Villawood Immigration Detention Centre is located several hundred metres north of the Site and the closest residences are approximately one hundred metres to the east. The Chester Hill High School is several hundred metres to the north east.

Planning and Approvals

The Site is located within the Bankstown City Council LGA where the principal local environmental planning instrument is Bankstown Local Environmental Plan 2001 (LEP 2001). Under LEP 2001, the Site is located within the 4(a) General Industrial zone. The proposed remediation is permissible in this zone. State Environmental Planning Policy 55 – Remediation of Land (SEPP 55) is also relevant. Clause 8(1) of SEPP 55 states that:

A person may carry out a remediation work in accordance with this Policy, despite any provision to the contrary in an environmental planning instrument, except as provided by clause 19 (3).

The proposed remediation works are permissible in accordance with Clause 8(1) of SEPP 55. As outlined previously, approval is required for the proposed project under Part 3A of the EP&A Act, and the proposed project has been declared a ‘Major Project’ under that Act. The Minister for Planning is the approval authority for the proposed remediation works (Appendix A and B). Orica is seeking project approval for the proposed remediation works at the Site.



Orica has engaged an independent site auditor accredited under the Contaminated Land Management Act 1997 (CLM Act) to endorse the Remedial Action Plan (RAP), to comment as required for the duration of the remediation, and to undertake a site audit upon completion of remediation of the Site.

The Site and Context

The site to be remediated is located at 2 Christina Road and is legally described as Lot 1 in Deposited Plan (DP) 634604. It covers approximately 12.6 Ha and is located in the suburb of Villawood on the northern side of Christina Road between Birmingham Avenue and Miller Road. The proposal excludes the pharmaceutical building and surrounding land to the west which occupy about 2.1 ha. This area has previously been remediated and validated from November 2003 to December 2004. The balance of property is the Site which is the subject of this proposal.

Project Description

The project involves the remediation of the Site area using Directly-heated Thermal Desorption (DTD) technology. The detailed design of the DTD Plant has not yet been finalised therefore the EA presents the preliminary details of the remediation project. The proposed remediation works involve the following key steps:

1 Construction of necessary buildings, plant and facilities on the Site including a Water Treatment Plant (WTP), a Feed Soil Building (FSB) and associated ECS, the DTD Plant, hardstand areas, environmental controls, and internal haulage roads.

2 Excavation of contaminated soil.

3 Coarse screening of excavated material to remove oversized materials.

4 Transportation of contaminated soil by covered truck from the excavation areas to the FSB.

5 Further screening, drying and testing of contaminated material within the FSB.

6 Feeding of contaminated material from the FSB into the DTD Plant.

7 Treatment of contaminated material in the DTD Plant.

8 Validation testing of material treated by the DTD Plant and excavation areas.

9 Stockpiling of treated material.

10 Decommissioning of plant and buildings.

11 Reinstatement of the Site with validated material. The remediation process is expected to take approximately 14 months to complete including site establishment, pre-treatment, treatment, validation, decommissioning and reinstatement.



The breakdown of this program is generally as follows:

• Site establishment and construction (including DTD Plant commissioning and PoP testing) – approximately 26 weeks;

• Excavation and treatment – approximately 20 weeks;

• Decommissioning and demobilisation – approximately 12 weeks; and

• Reinstatement of excavated areas – approximately 12 weeks (NB concurrent with demobilisation).

Consultation with Stakeholders

Statutory Authority Consultation

As part of the environmental assessment process, consultation was undertaken with the following authorities:

• NSW Department of Planning (DoP);

• NSW Department of Environment, Climate Change and Water

• NSW Health (Sydney South West Area Health Service)

• Bankstown City Council; and

• NSW Office of Water (NOW).

Community Consultation

Orica has undertaken an extensive program of community consultation both in respect of selection of the preferred remediation technology and the preparation of the EA. The program involved a number of meetings with the local community and stakeholders to provide information on the project and gather feedback. A detailed description of the community consultation undertaken is provided in Section 6.2.2 of the EA.

Issues Identification

In response to consultation undertaken, Orica received comments covering the following key issues:

• Air quality and Odour

• Noise and Vibration

• Water management

• Waste products

• Energy requirements

• Hazards and Risk

• Human Health

• Traffic

• Occupational Health and Safety

• Visual impact

• Remediation criteria

• Remediation technology



Issues Prioritisation

A prioritisation analysis was undertaken in respect of the key issues identified to address the need to recognise that the higher the potential severity of adverse environmental effects and the greater the potential consequence of those unmanaged effects, the higher the degree of environmental assessment required. Where greater potential impacts were identified, the attribute or issue was allocated a higher priority for assessment. The analysis assesses the potential risk on the basis of the potential severity of environmental effects and the likely consequences of those potential effects if unmanaged. Community views were also taken into account - where community concern regarding an issue was greater, a higher priority was assigned for the environmental assessment. The analysis identified that the prioritisation of environmental issues and therefore the focus of environmental assessment for the proposed project should be as follows:

• High - Air quality, noise, hazard and risk, social, traffic and land use;

• Medium – Soils, land use and water; and

• Low – Ecology, resources, heritage and economic.

These issues have been addressed accordingly within this EA.

Environmental Assessment

Soil

The potential for contaminants at the Site to be transferred to surrounding soils would be minimised through the implementation of mitigation and management measures, including sediment and erosion controls, throughout the duration of the works to ensure that contaminants are contained within the Site until treated. Appropriate spill and incident management procedures would further ensure that environmental impacts are minimised.

Water

The potential for contaminants to be transferred to surface and groundwater would be minimised through the implementation of mitigation and management measures, including containing the excavation of material within exclusion zones and the implementation of sediment and erosion controls throughout the duration of the works to ensure that contaminants are contained within the Site until treated. While the proposal involves remediation of land to remove existing contaminants, it would ultimately result in benefits to both surface and groundwater quality.



Air Quality

An air quality assessment was undertaken in respect of the proposal. An inventory of emissions from the FSB and DTD Plant was compiled, including details for stack conditions and expected maximum pollutant concentrations and discharge rates for both stack and fugitive emissions. These emissions were estimated based on the maximum capacity of the treatment plant and minimum performance specifications provided to the plant designers for the off-gas treatment systems in order to provide a conservative, worst-case assessment of likely air quality impacts under normal operating conditions. Dispersion modelling undertaken for the proposed remediation has demonstrated that under worst-case pollutant emission rates and meteorological conditions, all pollutant concentrations are predicted to be below the DECCW assessment criteria for all sensitive receptors. Residual impacts associated with dust emissions would be of a minor and temporary nature. Given that the emissions resulting from the proposed remediation works are below the DECCW assessment criteria, there is no requirement for additional specific environmental safeguards to be implemented, above those built into the design of the FSB and DTD plant. These measures include the enclosure of contaminated material handling activities in the FSB. The FSB would incorporate emission control systems, which include carbon adsorption and dust filters.

Odour

Odour was assessed at the Site by comparing the predicted concentrations of modelled odorous compounds against reported odour thresholds, or detection limits. The results of the odour screening assessment indicate that odour concentrations are well within the relevant limits.

Dust

Dust emissions from the construction phases of the project would not be expected to result in offsite nuisance impacts. The construction periods for dust generating activities are relatively short and access roads are sealed. Dust mitigation measures would be specified in the Construction Environment Management Plan (CEMP) for the remediation project to minimise the potential for emissions from construction activities. During operations, dust emissions from activities in the FSB will be contained inside, which will be operated so that airflow will pass through an emission control system. Wheel-generated dust from truck and machinery movements outside of the buildings would not be expected to cause nuisance and these would be controlled by water sprays, if necessary.

Noise and Vibration

Construction and Operational Noise

Unmitigated noise levels at the nearby receivers during all time periods considering neutral meteorological conditions and adverse meteorological conditions that are typical to the area were calculated to assess potential noise impacts. For residential receptors, the predicted levels comply with the noise criteria at all locations for all Stages of work, except at Receiver 4 during Stage 1 work. This is when work occurs closest to the Receiver 4 and a 2dBA exceedance is predicted. As the exceedance is only 2dBA, and occurs for only 1 week, it is considered only a marginal impact.



During the night time period (10 pm to 7 am) the noise continues at a constant level throughout the period. Because of this, the determining criteria are the amenity criteria. No exceedances of the noise criteria (including the sleep disturbance criteria) are predicted at any location. At the commercial premises across Christina Road the predicted noise levels are always below 65dBA, which complies with the criterion. At industrial premises adjacent to the site, predicted noise levels will generally comply with the criteria. Some exceedances are predicted when the earthmoving equipment is within 20m of the facades. However the neighbouring facades are all masonry and only minor impacts are predicted. Details of the mitigation measures and noise reductions achieved shall be provided to the DoP during the detailed design stage of the project. The following additional safeguards would be implemented to mitigate noise emissions in respect of the project:

• Preparation and implementation of a Construction Noise and Vibration Management Plan (CNVMP) to ensure noise level criteria are met;

• Notification to all those impacted by works likely to cause excessive vibration or noise – i.e. if sheet piling is required;

• Periodic noise and vibration testing should be undertaken during any activity associated with the proposed works that is likely to generate high noise and vibration levels; and

• Provision of a 24hr community hotline.

Vibration

The impact of vibration to sensitive receivers was also assessed. Although perceptible, it is unlikely that vibration would exceed the required guideline levels, with reference to relevant guidelines and standards, to the nearby residences or commercial businesses. The risk of building damage is considered low. Given the low risk associated with vibration impacts (both annoyance and structural damage) a detailed vibration assessment is not deemed necessary. However, monitoring is recommended prior to works that would generate significant vibration.

Road Traffic Noise

All traffic movements entering and exiting the Site during both construction and operation would be from Christina Road. Traffic flows of less than 10 heavy vehicles per day are anticipated during the busiest initial construction period, with flows reducing significantly during operation of the remediation facility. Using the DEC’s NSW Environmental Criteria for Road Traffic Noise, traffic generating developments are allowed an increase of 2dBA, (assuming the worst case that these limits are currently exceeded) once all reasonable and feasible mitigation is considered. Given the low number of vehicle movements generated by this development and given the negligibly low risk of exceeding the 2dB limit, a detailed assessment is not deemed necessary.



Hazard and Risk

A Preliminary Hazard Analysis (PHA) has been prepared in respect of the project to address the potential impacts of the proposed works in terms of hazard and risk. The PHA concluded that the project would not increase the offsite fatality risk and therefore does not increase the societal risk contribution to the area from the site. The potentially hazardous incidents identified in the PHA did not have the potential to have a significant effect (safety, health or environmental) outside the immediate incident area. No incidents were identified with an offsite fatality risk, or an injury or irritation effect in residential areas. The risk level associated with the proposed facility is therefore considered to be very low, and the quantitative risk criteria suggested by the DoP are therefore satisfied. The risk level is also in the ‘acceptable’ band for most identified issues when assessed against the internal Orica risk matrix criteria. The incident scenarios identified involving either a gas emission or a loss of material from a transport incident had very limited impact area due to the relatively small quantities of contaminants and short incident durations. The risk to environment from accident scenarios occurring at the proposed remediation facility is therefore regarded as low.

Human Health Risk

A Human Health Impact Assessment (HHIA) was undertaken in respect of the project. The overall objective of the HHIA is to identify, characterise and evaluate potential risks to human health associated with the operation of the proposed remediation project. It was concluded that the proposed remediation would potentially result in some fugitive emissions during the excavation and treatment process. However, the mitigation measures to be implemented as part of the project, including those inherent to the design of the plant, are designed to ensure that these emissions do not pose an unacceptable risk to human health. The proposal would result in the remediation of land which is currently contaminated, thereby ultimately removing future risk to human health associated with the contaminants contained on the Site. Therefore, the proposal is considered to have a net positive residual impact in terms of human health risk.

Non-Key Environmental Issues

Social

The social impacts associated with the proposed remediation works primarily relate to amenity issues such as visual and noise impacts that would be generated during the remediation project. Other potential social impacts include increased traffic and impacts associated with hazard and risks. Given that the potential impacts of the proposal in terms of noise, visual impact, traffic and hazard and risk are not significant and are temporary and manageable, significant adverse effects upon the amenity of the surrounding area are not anticipated. The proposal is expected to result in social benefits through the removal of existing contaminants at the Site and the facilitation of the return of the land to a productive use. These social benefits are considered to outweigh the temporary potential social impacts associated with the proposed works.



Visual

As part of the EA, a visual assessment was carried out to determine the impacts of the proposed remediation on the surrounding area. Potential visual impacts associated with the proposal are likely to be minimal as the proposed remediation facility will be viewed in the wider context of the surrounding industrial and commercial land uses. The remediation area is surrounded by high commercial and industrial buildings on three sides so that excavation will be visible only from commercial premises on the southern boundary. This would be screened to some extent by existing mature vegetation, which will be retrained under the remediation plan. Potential residual impacts associated with the proposal include visual impacts associated with stacks and buildings on the Site and visual impacts associated with night time lighting for 24 hour operation. The visual impacts of the stacks and buildings will not be visually intrusive given the industrial nature of the Site and the stacks would be removed upon completion of works. Given that the residual impacts will be short lived and temporary and in most cases are unlikely to be perceptible, they are considered to be outweighed by the benefits of the proposed remediation works.

Traffic

During both construction and operation, Site access would be through Christina Road. Primary routes to and from the Site are likely to be:

• Inbound from the west (only) – drive along Woodville Road turning onto Christina Road and accessing the Site via Gate 1;

• Outbound to the west – exit via Gate 1 along Christina Road and turn onto Woodville Road; and

• Outbound to the east – exit via Gate 1 along Christina Road and turn onto Miller Road at the roundabout. Proceed in northerly or southerly direction.

The primary traffic routes to and from the Site utilise arterial roads to access to the Sydney metropolitan area, therefore minimising the impact on the local road network. As there would be minimal appreciable change in traffic volumes during operation and construction (less than 1%), with the implementation of environmental safeguards identified in this EA, the proposed works are not expected to result in significant traffic impacts. Additional environmental issues including ecology, heritage and economic were identified, however the impacts resulting from the proposed remediation works are predicted to be minimal, and/or confined to the construction period.

Flora and Fauna

The Site has been largely cleared in the past and comprises disturbed land which is covered by roadways, building slabs, areas of fill, some patches of shrubs and mature trees planted for landscaping purposes, some isolated remnant native trees and an area of regrowth native vegetation along a drainage line on the western boundary.



Given the disturbed nature of and general lack of vegetation over the formerly developed part of the site, it is considered that:

• the remediation area does not support significant flora or fauna species; • the remediation works would not have a significant adverse impact on biodiversity;

and • the remediation works project would not significantly impact threatened species,

communities or habitats.

Heritage

There are no items on the Site that are listed by local government, state government of the National Estate Register as being of heritage significance. A due diligence assessment of aboriginal cultural heritage for the site found that all previously recorded Aboriginal archaeological sites were adjacent to the Georges River and the Duck River. No aboriginal archaeological sites were recorded within the Site. A detailed assessment of the nearby Villawood Detention Centre in 2005 also failed to identify archaeological sites or areas of Aboriginal cultural heritage sensitivity.

Land Use

The proposed remediation works are considered to be compatible with the industrial zoning of the Site. The proposed remediation works would ultimately result in the return of the Site to a productive industrial use consistent with surrounding land use. Potential impacts on these surrounding land uses as a result of the proposed remediation project relate to amenity issues, such as noise, visual, air quality and traffic impacts as well as hazard and risk. These potential impacts would be temporary, given that the project is to be completed within an 18 month period. Once appropriate environmental safeguards have been implemented (see Sections 8 and 9 of the EA), potential residual impacts associated with the proposal on surrounding land uses include:

• A minor increase in traffic of less than 1%;

• Occasional noise impacts if sheet piling is to be required;

• The possibility of fugitive emissions as a result of a system failure; and

• Visual impacts associated with stacks and buildings on the Site; The identified residual impacts in relation to land use would be temporary and minor and are considered manageable. The removal of contaminants would provide benefits to surrounding land uses through the cleanup of the land. Given the temporary and manageable nature of the potential impacts, they do not outweigh the overall benefits of the proposed remediation works.

Statement of Commitments

In accordance with the EA requirements issued under Part 3A of the EP&A Act, a Statement of Commitments (SoC) is provided in Section 10 of the EA. The SoC states Orica’s environmental commitments and details on the environmental management and monitoring of the proposed project during its construction and operational activities. Orica commits to the preparation and implementation of the environmental mitigation measures detailed in the SoC for the proposed remediation works as detailed in the EA.



Residual Risk

The Environmental Risk Analysis for the proposed project is based on a process adapted from Australian Standard AS 4369:1999 Risk Management, as well as environmental risk tools developed by other organisations. Residual Environmental Risk is assessed on the basis of the significance of environmental effects of the proposed project and the ability to confidently manage those effects to minimise harm to the environment. The analysis of residual environmental risk for issues related to the proposed project is shown in Section 11. This analysis indicates the environmental risk profile for the proposed project based on the assessment of environmental effects, the identification of appropriate safeguards, and the SoC shown in this EA. The residual risk analysis indicates that the proposed remediation works present an overall low to medium risk in relation to the identified environmental issues, provided that the recommended mitigation measures are implemented.

Project Justification

The assessment of the proposal undertaken in the preparation of this EA has considered the biophysical, economic and social environments. The proposed remediation of the Site would provide numerous benefits associated with the destruction of contaminants. Substantial environmental benefits would result from the remediation of the Site, as well as numerous social and economic benefits including the cleanup of contaminated material, and the return of the site to a productive use, compatible with the industrial zoning. The proposal would therefore have resultant benefits for the local and wider community and the environment, as well as present and future generations. Should the project not proceed, the contaminants contained within the Site would remain on the site with the following consequences:

• Further breakdown of contaminants leading to potential release into surrounding soil and groundwater;

• Possible spread of contaminants off-site;

• Legacy of contamination left for future generations; and

• Limited use of prime industrial land. The above consequences are considered serious enough to outweigh the potential residual environmental impacts of the remediation proposal and to justify the proposed works being undertaken.



Findings

Physical and Pollution Effects

The physical and pollution effects of the proposal include the potential for air pollution as a result of emissions from the DTD Plant and associated equipment, the potential for water pollution associated with the release of contaminated water or run off from contaminated soil and the potential for noise emissions during the construction and operation of the remediation project. These issues have been assessed in the EA and appropriate mitigation measures recommended. With the implementation of appropriate mitigation measures, the proposal poses a low to medium risk in terms of physical and pollution effects. The risks associated with leaving the Site in its contaminated state are considered to far outweigh the potential risks associated with undertaking the remediation works.

Biological Effects

The proposed remediation works are to take place on a highly disturbed industrial site located within an established industrial park. The works would not require the clearing of stands of vegetation and would not impact upon threatened flora or fauna. The proposal is therefore considered to be a low risk in terms of biological effects and the environmental benefits which would be gained through the remediation of the land are considered to outweigh this risk.

Resource Implications

The Site already exists as an industrial site and as such, has access to the necessary infrastructure and services required for the proposed project. The proposal would result in some additional traffic during the construction and operation period and would use some additional fuel however, overall, the resource implications of the project are considered to be negligible. Given that the proposal would result in the return of a currently vacant block of land to productive industrial use, the project is considered to have a net positive impact in terms of resources.

Community Effects

The community and social effects of the proposed remediation project are largely related to noise, traffic, and hazards and risks. These issues have been assessed in relation to the proposed project and mitigation measures recommended to minimise potential impacts. With the implementation of these mitigation measures, the potential negative community effects of the proposal are considered to be manageable. The project would result in community benefits in terms of providing local employment opportunities, particularly during the construction period as well as improving the health and amenity of the environment in the immediate vicinity.



February 2011 1-1

1 INTRODUCTION

1.1 Proposal Overview

The proposed project is the remediation of part of the former chemical manufacturing facility at 2 Christina Road Villawood, in the Bankstown Local Government Area (LGA) (Figure 1 ). It was initially part of a much larger site owned by the Commonwealth of Australia, subsequently purchased by Taubmans and then ICIANZ Pty Ltd. Later, Orica Pty Ltd formed out of ICIANZ Pty Ltd. The site was used to formulate a wide range of agricultural and pharmaceutical chemicals until it was closed in 2000. Numerous investigations have been undertaken since 2000 on site soils and groundwater, and several zones of impacted soil and groundwater plumes have been identified. Orica plans to remediate the site to a standard suitable for ongoing industrial use. Clean up to site specific risk based criteria with onsite treatment by a Directly-heated Thermal Desorption (DTD) plant is proposed for remediation of contaminated soil on the Site. Source removal to the extent practicable by remediation of soil, followed by monitored natural attenuation is the proposed strategy for remediation of the groundwater plumes.

1.2 Project Context and Objective

On 29 July 2004, Orica notified the NSW EPA1 under Section 60 of the Contaminated Land Management Act 1997 (CLM Act) that the Site presented a potential significant risk of harm (SRoH) to human health and the environment. On 22 April 2005 the EPA declared the site to be a remediation site and issued a Remediation Order (RO) (No 23019, Area 3200) to Orica on 2 November 2005 which states that the Site is contaminated with:

“Total Petroleum Hydrocarbons (TPH); Benzene; DDT (and its degradation products DDD and DDE)2; 1,2-dichloroethane (1,2-DCA)3; Trichloroethene (TCE); Chlorobenzene (MCB); 1,4-dichlorobenzene (1,4-DCB) Hexachlorobenzene (HCB); Lindane (a-BHC); Polycyclic Aromatic Hydrocarbons (PAHs), including Benzo(a)pyrene (BaP); and Cyanide”.

Because cyanide was not identified in soil and groundwater on the site it is not, however, considered to be a Contaminant of Potential Concern (CoPC) for the Site.

1 The NSW EPA is part of the Department of Environment, Climate Change and Water (DECCW) 2 DDT and its degradation products will be referred to as DDX throughout this report 3 1,2-dichloroethane will be referred to as EDC throughout this report



February 2011 1-2

The RO specified certain tasks to be completed. These included:

• carrying out additional investigations into soils and groundwater; • engaging a Site Auditor; • assessing soil and water treatment technologies; and • preparing a RAP for soil and groundwater

A portion of the site west of the pharmaceuticals building was remediated in 2004, as part of a potential sale agreement. This area and the pharmaceuticals building, which are to be retained for future commercial / industrial use, are excluded from this proposal. A Remediation Action Plan has been prepared by AECOM (2010) for remediation of the balance of the Site. The proposed project comprises the remediation of the Site in accordance with the RAP.

1.3 Site Identification

The property at 2 Christina Road is owned by Orica and is legally described as Lot 1 in Deposited Plan (DP) 634604. It covers approximately 12.6 Ha and is located in the suburb of Villawood on the northern side of Christina Road between Birmingham Avenue and Miller Road. The proposal excludes the pharmaceutical building and surrounding land to the west which occupy about 2.1 ha. This area has previously been remediated and validated from November 2003 to December 2004. The balance of property is the Site which is the subject of this proposal. The boundary of the Site within the Orica property is shown in Figure 2 . Co-ordinates of the boundary within the property are included in Appendix C .

1.4 Landuse and Zoning

The Site is surrounded on three sides by light industrial facilities and to the south by Christina Road. The southern side of Christina Road is used for commercial purposes and those premises back onto the Bankstown / Inner West railway line. Figure 3 shows land use zoning of the Orica property and surrounding land. The Villawood Immigration Detention Centre is located several hundred metres north of the Site and the closest residences are approximately one hundred metres to the east. The Chester Hill High School is several hundred metres to the north east. Figure 4 shows sensitive receptors on the Orica property and surrounding land.



February 2011 1-3

1.5 The Proponent

Orica Limited is an Australian publicly listed company which operates through the following business platforms:

• Mining services - offering commercial explosives, initiating systems and advanced mining solutions to the mining, quarrying and construction industries;

• Chemicals - is a leading manufacturer, trader and distributor of chemicals and services for customers in industrial, mining, pulp and paper, water treatment, construction, dairy, food and beverage and agricultural markets

• Minova - Manufacturer and marketer of high quality speciality chemicals and bolts to support underground mining and tunnel operations.

1.6 Environmental Assessment Process

Group 9 of Schedule 1 to State Environmental Planning Policy (Major Projects) 2005 (SEPP 2005) identifies classes of development defined as ‘major projects’, including remediation of contaminated land, being: Development for the purpose of remediation of land that is category 1 remediation work on a remediation site. The definitions of category 1 remediation work, remediation and remediation site are detailed in SEPP no 55. A ‘Remediation site’ is land declared to be a remediation site by a declaration under Division 3 of Part 3 of the Contaminated Land Management Act 1997. The Site is considered to be a ‘remediation site’ even though the RO was issued under s.23 (now repealed) of the CLM Act, because Schedule 2 of the CLM Act makes provision for existing Remediation Orders to remain in force. ‘Category 1 remediation’ includes remediation carried out or to be carried out in a manner that does not comply with a policy made under the contaminated land planning guidelines by the council for any local government area in which the land is situated. The Site is located in the Bankstown City Council (BCC) Local Government Area (LGA), so BCC’s Policy for the Management of Contaminated Land applies. The proposed development would comply with BCC’s policy, except for hours of operation. The DTD plant would operate 24 hours a day, while permitted hours of operation under BCC’s policy are 7am – 6pm Monday to Friday, 7 am – 1pm Saturday and no work Sunday or public holidays. For this reason the development is not considered to comply with the policy and it is therefore Category 1 remediation. The Deputy Director-General for the NSW Department of Planning has provided his opinion that the Orica Villawood remediation project is a ‘major project’ under the provisions of the Environmental Planning and Assessment Act 1979 (EP&A) and SEPP 2005. Project approval is therefore being sought under Part 3A of the EP&A Act.



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Orica has engaged an independent site auditor accredited under the Contaminated Land Management Act 1997 (CLM Act) to endorse the Remedial Action Plan (RAP), and to oversee the works for the duration of the remediation program. The site auditor will also undertake a site audit upon completion of remediation of the Site.

1.7 Environmental Assessment Requirements

Under section 75F of the EP&A Act, an Environmental Assessment (EA) must be prepared in accordance with the Environmental Assessment Requirements (EARs) of the Director-General of the Department of Planning (DoP). A request for these requirements was made on 16 February 2010. The Director-General’s EARs were issued on 12 May 2010 and a copy is attached as Appendix B to this EA. This EA has been prepared by Thiess Services Pty Ltd (Thiess) on behalf of Orica for the proposed remediation of the Site. In accordance with Part 3A of the EP&A Act, this EA has been prepared pursuant to the Director-General’s EARs and addresses the matters listed by the Director-General. The purpose of this report is to assess the environmental effects of the proposal and to describe the measures that Orica would take in order to minimise the impact of identified adverse environmental effects such that the Minister for Planning can make an informed decision with regard to the proposal. As the detailed design of the proposed DTD Plant has not been finalised, the EA has been prepared utilising conservative assumptions as the basis for assessment (for example, minimum performance specifications for air quality assessment), in the knowledge that the plant’s actual performance would be within these parameters and would therefore perform better environmentally. This could be further demonstrated once the detailed design has been developed and the Technology Assessment (under the EHC Act) for the proposed plant has been prepared and submitted to DECCW. The EP&A Act requires that the EA be placed on exhibition for public review for a minimum period of 30 day.



February 2011 2-1

2 STATUTORY PLANNING

2.1 Local Planning Instruments

2.1.1 Bankstown Local Environmental Plan 2001

The Bankstown Local Environmental Plan (LEP) 2001 is the principal local environmental planning instrument that applies to the site. Under the provisions of LEP 2001 the Site is zoned 4(a) General Industry. The objectives of the 4(a) General Industry zone are:

“(a) to permit primarily industrial uses or uses which are inappropriate in other zones, and

(b) to limit retail development, except where: (i) it is ancillary to an industrial use of land, or (ii) it services the daily convenience needs of the local workforce and does not

have an adverse impact on the viability of the business areas of the City of Bankstown, and

(c) to promote a high standard of: (i) building design (particularly along arterial roads), and (ii) environmental management, energy efficiency and resource conservation,

and (d) to allow bulky goods salesrooms or showrooms only where they will not have an

adverse impact on the viability of the business areas of the City of Bankstown.” The proposed remediation project is consistent with the objectives of the 4(a) General Industry zone. The proposed project consists of the remediation of land, which is not defined under LEP 2001. However, Clause 12 of LEP 2001 allows the consent authority to grant consent to development that is not so defined (or would otherwise be prohibited), where it is satisfied that the proposed development:

“(a) is of a nature (whether by reason of its design, scale, manner of operation or otherwise) that would, in the absence of this clause, justify an amendment to this plan in order to permit the particular development, and

(b) is not inconsistent with the objectives of the zone in which the development site is situated, and

(c) is not inconsistent with the provisions of any other environmental planning instrument, and

(d) will not have an adverse effect on other land in the vicinity.” The proposed remediation project satisfies clause 12 of LEP 2001, and is therefore permissible with consent in the 4(a) General Industry Zone. Clause 52 of LEP 2001 specifies matters which must be taken into consideration by the consent authority prior to granting consent to development in the industrial zones. The matters relevant to the current project are:

“...(c) whether the proposed development will contribute to the maintenance or improvement of the character and appearance of the locality,...

...(e) whether goods, plant, equipment and other material used in carrying out the proposed development will be suitably stored or screened,...”



February 2011 2-2

The proposed remediation project will contribute to the improvement of the locality by ameliorating the identified levels of soil contamination and removing the source of groundwater contamination at the Site. Storage and screening of the remediation plant and equipment has been considered in the planning of the proposed project.

2.1.2 Development Control Plan 2005

Part D6 of Development Control Plan (DCP) 2005 relates to industrial zones, the objectives of which, relevantly include:

“... (b) to minimise pollution and environmental risk, and enhance ecological values;

(c) to protect the amenity of residential zoned land that adjoin the industrial precincts...” The proposed remediation project will reduce the environmental risk posed by the Site, and the Site is remote from residentially zoned land. No other clauses relevant to the remediation of land are included in DCP 2005.

2.2 State Planning Policies

2.2.1 Environmental Planning and Assessment Act 1979

The Environmental Planning and Assessment Act 1979 (EP&A Act) and the Environmental Planning and Assessment Regulation 2000 (EP&A Regulation) provide the framework for environmental planning in NSW and include provisions to ensure that proposals which have the potential to impact the environment are subject to detailed assessment and public participation. The development assessment system in New South Wales is set out in Parts 3A, 4 and 5 of the EP&A Act. The Minister for Planning determines applications for major infrastructure or other major projects of State or regional environmental planning significance under Part 3A of the EP&A Act. This section of the EP&A Act provides a single assessment process specifically designed for major projects and improved transparency and community consultation. The State Environmental Planning Policy (Major Developments) 2005 and declarations made under S75B of the Act define which projects are determined by the Minister.

2.2.2 State Environmental Planning Policy (Major Development) 2005

State Environmental Planning Policy (Major Development) 2005 (Major Development SEPP) came into effect on 1 August 2005. It replaced all previous provisions related to former ‘State significant development’ in planning instruments, directions and declarations. The primary aim of the Major Development SEPP is ‘to identify development of economic, social or environmental significance to the State or regions of the State so as to provide a consistent and comprehensive assessment and decision making process for that development’. Schedule 1 of the Major Development SEPP identifies classes of development which are candidates for declaration under Part 3A of the EP&A Act. This includes development for the purpose of the remediation of contaminated land being “Development for the purpose of remediation of land that is category 1 remediation work on a remediation site.” In this clause, “category 1 remediation work", "remediation" and "remediation site" have the same meanings as in State Environmental Planning Policy No. 55 - Remediation of Land (SEPP 55).



February 2011 2-3

Under SEPP 55, "remediation" is defined as:

“(a) removing, dispersing, destroying, reducing, mitigating or containing the contamination of any land, or

(b) eliminating or reducing any hazard arising from the contamination of any land (including by preventing the entry of persons or animals on the land).”

The proposed remediation project will remove, destroy and reduce the contamination of the Site. Under SEPP 55, a "remediation site" is defined as:

“(a) land declared to be a remediation site by a declaration in force under Division 3 of Part 3 of the Contaminated Land Management Act 1997, or

(b) premises:

(i) in respect of which there is in force a notice under section 35 of the Environmentally Hazardous Chemicals Act 1985 requiring prescribed remedial action to be taken, or

(ii) that are the subject of prescribed remedial action (whether being undertaken by the Environment Protection Authority or by another public authority at the direction of that Authority) under section 36 of that Act.”

The then EPA declared the Site to be a remediation site on 22 April 2005. Part 9 of SEPP 55 defines “category 1 remediation work" as (in part): “...a remediation work (not being a work to which clause 14 (b) applies) that is:

(a) designated development, or...

...(d) development for which another State environmental planning policy or a regional environmental plan requires development consent...”

Designated development is defined in Part 1 of Schedule 3 of the Environmental Planning and Assessment Regulation 2000 (EP&A Regulation), and includes ‘contaminated soil treatment works’: “ Contaminated soil treatment works (being works for on-site or off-site treatment of

contaminated soil, including incineration or storage of contaminated soil, but excluding excavation for treatment at another site):

(a) that treat or store contaminated soil not originating from the site on which the development is proposed to be carried out and are located:

(i) within 100 metres of a natural waterbody or wetland, or

(ii) in an area of high watertable or highly permeable soils, or

(iii) within a drinking water catchment, or

(iv) on land that slopes at more than 6 degrees to the horizontal, or

(v) on a floodplain, or

(vi) within 100 metres of a dwelling not associated with the development, or

(b) that treat more than 1,000 cubic metres per year of contaminated soil not originating from the site on which the development is located, or



February 2011 2-4

(c) that treat contaminated soil originating exclusively from the site on which the development is located and:

(i) incinerate more than 1,000 cubic metres per year of contaminated soil, or

(ii) treat otherwise than by incineration and store more than 30,000 cubic metres of contaminated soil, or

(iii) disturb more than an aggregate area of 3 hectares of contaminated soil.” The proposed project will treat approximately 25,000 m3 of contaminated soil, including approximately 2,000 m3 of contaminated soil originating from the Orica Chester Hill site, and is therefore classed as designated development under the EP&A Regulation. In addition, the proposed project is also defined as “category 1 remediation work" as the work requires approval under the Greater Metropolitan Regional Environmental Plan No 2 – Georges River Catchment. As such, the proposed project is defined as ‘remediation of contaminated land’ and, under Schedule 1, is classified as a project to which Part 3A of the EP&A Act applies. Consent for Part 3A projects is required from the Minister for Planning, and an environmental assessment is required to be prepared in accordance with the Director-General’s requirements.

2.2.3 State Environmental Planning Policy 55 – Remediation of Land

State Environmental Planning Policy 55 – Remediation of Land (SEPP 55) aims to provide a State-wide planning approach to the remediation of contaminated land, and in particular, promotes the remediation of contaminated land for the purpose of reducing risk of harm to human health or the environment. Clause 8 of SEPP 55 provides that, despite the provisions of another environmental planning instrument, remediation work can be carried out in accordance with the provisions of the policy, though a “person must not carry out a category 1 remediation work except with the consent of the consent authority”. Therefore, under the provisions of SEPP 55, the proposed remediation works are permissible with consent. A remediation work is to comply with clauses 17 and 18 of SEPP 55, which relate to the use of guidelines and notices. Clause 17 states that:

“(1) All remediation work must, in addition to complying with any requirement under the Act or any other law, be carried out in accordance with:

(a) the contaminated land planning guidelines, and

(b) the guidelines (if any) in force under the Contaminated Land Management Act 1997, and

(c) in the case of a category 1 remediation work-a plan of remediation, as approved by the consent authority, prepared in accordance with the contaminated land planning guidelines.

(2) A notice of completion of remediation work on any land must be given to the council for the local government area in which the land is situated (or, if the land is within the unincorporated area, to the Western Lands Commissioner).



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(3) The notice is to be given within 30 days after the completion of the work.

(4) A copy of the notice must also be given within the same period to the consent authority, if consent was required for the remediation work and the consent authority is not one of the authorities referred to in subclause (2).”

The proposed remediation works will be carried out in accordance with the Contaminated Land Planning Guidelines, and a Remedial Action Plan has been prepared for the Site. A notice, prepared in accordance with clause 18, is to be given to Bankstown Council and DoP within 30 days of the completion of the remediation works.

2.2.4 Protection of the Environment Operations Act 1997

Section 48 of the Protection of the Environment Operations Act 1997 (POEO Act) requires a person to obtain a licence from DECCW before carrying out any of the premises-based activities described in Schedule 1 of the POEO Act. Schedule 1 includes the following activity: "Contaminated soil treatment works for on-site or off-site treatment (including, in either case, incineration or storage of contaminated soil but excluding excavation for treatment at another site) that:

(1) handle more than 1,000 cubic metres per year of contaminated soil not originating from the site on which the works are located; or

(2) handle contaminated soil originating exclusively from the site on which the works are located; and (a) incinerate more than 1,000 cubic metres per year of contaminated soil, or (b) treat otherwise than by incineration and store more than 30,000 cubic metres

of contaminated soil, or (c) disturb more than an aggregate area of 3 hectares of contaminated soil."

The remediation works will involve the treatment of approximately 25,000 m3 of contaminated soil, including approximately 2,000 m3 of contaminated soil originating off site, from Chester Hill. Accordingly, the remediation works require a licence under the POEO Act. The Site currently has two POEO licences (# 2149 and # 6964), of which one (# 2149) has been amended on 18 May 2009 to include waste storage and contaminated soil treatment.

2.2.5 Contaminated Land Management Act 1997

The Contaminated Land Management Act 1997 (CLM Act) is the primary act under which contaminated land is regulated by the Department of Environment, Climate Change and Water (DECCW). The CLM Act was amended on 10 December 2008, to allow sites to be cleaned up more efficiently while reinforcing the "polluter pays" principle. The amendments have:

• Introduced a new power to enable DECCW to require certain persons to carry out a preliminary investigation of site contamination.

• Amalgamated the investigation and remediation stages into a single "management" stage that can cover investigation, remediation or both.

• Removed the concept of "significant risk of harm".

• Enabled DECCW to declare land to be "significantly contaminated land" if it has reason to believe that land is contaminated and the contaminated is significant enough to warrant regulation.

• Enabled management orders to be issued to any one or more persons who are responsible for the contamination of land.



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If DECC has reason to believe that land is contaminated and that the contamination is significant enough to warrant regulation, DECC may declare the land to be 'significantly contaminated land'. Under these amendments, after 1 July 2009, the former declarations of land as investigation areas and declarations of remediation sites are taken to be declarations of ‘significantly contaminated land’. Under Schedule 2 of the CLM Act, the remediation order for the Site (Order number 23019 Area Number 3200) is taken to be a management order in force on the same terms as the remediation order. Clause 28 relates to ongoing maintenance orders, and applies to land that has been the subject of a management order. Under this clause DECCW may order an owner or occupier of land to carry out any ongoing management or monitoring of the land; to provide reports at specified periods; to inform DECCW of any change in land ownership; and may restrict specified activities or purposes on the land. The process contaminated land consultants are to follow in assessing urban redevelopment sites under the CLM Act are the Guidelines for the NSW Site Auditor's Scheme (DEC, 2006). The Guidelines prescribe soil investigation levels (SILs), which are the concentration levels of particular contaminants above which further investigation and evaluation are required. A number of substances for which SILs have been prescribed have been identified on the Site, however, other contaminants of potential concern (CoPC) identified on the Site do not have prescribed SILs. The Guidelines make the following provision for such circumstances:

“…where SILs are not available for particular contaminants, or assessment of contaminants against SILs at a particular site is inconclusive… The auditor must check whether the risk assessment is in accordance with the NEPM [National Environmental Protection (Assessment of Site Contamination) Measures] and any relevant guidelines made or approved by DEC. The auditor must also check that any human health risk assessment satisfies all the requirements in the checklist in Appendix VII. The auditor must check that all site-specific risk assessments are scientifically valid and that the site-specific criteria recommended by the consultant are appropriate to protect public health and the environment.”

As SILs are not available for all CoPC identified at the Site, it is necessary and appropriate to adopt a health-based risk assessment approach in determining suitable criteria for these chemicals and the level of remediation required for the proposed future use of the Site, which is commercial/industrial. The risk assessment process, by which the site-specific criteria were derived, is detailed in the Remedial Action Plan prepared for the Site (AECOM, 2010).

2.2.6 Environmentally Hazardous Chemicals Act 1985

The primary regulatory instrument for remediating the Site is the CLM Act, however prior to the enactment of the CLM Act, the DECCW regulated sites by orders under sections 35 and 36 of the Environmentally Hazardous Chemicals Act 1985 (EHC Act). The transitional arrangements for the commencement of the CLM Act repealed these sections of EHC Act, but preserved the operation of orders made under the EHC Act.



February 2011 2-7

Under Division 5, Part 3 of the EHC Act the DECCW can make a Chemical Control Order (CCO) in relation to an environmentally hazardous chemical or a declared chemical waste. CCOs are a primary regulatory tool under the EHC Act and are used by the DECCW to establish requirements for the management and control of wastes that contain scheduled chemicals at a combined concentration above two (2) milligrams per kilogram (mg/kg) of particular compounds, and their potential or actual impact on the environment. CCOs set out requirements for manufacturing, keeping, using, processing, storing, selling, transporting or disposing of chemicals and declared chemical wastes. A site auditor must not endorse a management strategy proposed for a site which involves chemicals or chemical wastes subject to a CCO, unless they are satisfied it complies with the requirements set down in the CCO. The nature of the contaminated materials at the Site is such that they are considered to be Scheduled Chemical Waste under the Scheduled Chemical Waste CCO (NSW EPA, 2004a). The CCO in relation to Scheduled Chemical Waste (the Scheduled Chemical Wastes Chemical Control Order 2004) prohibits the manufacturing, processing, keeping, distributing, conveying, selling or disposing of scheduled chemical wastes, unless it is otherwise permitted by, and carried out in accordance with the conditions of, the Scheduled Chemical Waste CCO. The SCW CCO (NSW EPA, 2004a) requires a licence for various activities, including processing, which is defined as ‘an activity which transforms, destroys, recovers, separates or concentrates scheduled chemical wastes’. The proposed treatment technology used in the remediation works will be reviewed and licensed by the DECCW separately under the appropriate provisions of the EHC Act based on a Technology Assessment to be completed in accordance with the National Protocol for Treatment of Schedule X wastes.

2.2.7 Water Act 1912

A licence under Part 5 of the Water Act 1912 will be required to authorise the short and medium term groundwater monitoring bores required to demonstrate natural attenuation of contaminants in site groundwater post remediation, as described in Section 2.2.1 .

2.2.8 State Environmental Planning Policy 33 – Hazardous and Offensive Development

The aims of State Environmental Planning Policy 33 - Hazardous and Offensive Development (SEPP 33) include the amendment of definitions of hazardous and offensive industries where used in environmental planning instruments and to require development consent for hazardous and offensive development. The document Applying SEPP33 – Hazardous and Offensive Development Application Guidelines was prepared by the Department of Urban Affairs and Planning (DUAP) in 1994 to provide assistance primarily to councils but also to industry, consultants and other government agencies, in implementing SEPP 33. The Guidelines recommend a ‘risk screening’ method for determining whether a proposal is hazardous and provides guidance on assessing potentially offensive development proposals.



February 2011 2-8

The Guidelines state that the first step to determining whether SEPP 33 applied to a proposal is to consider whether the proposed use falls within the definition of ‘industry’ adopted by the planning instrument which applies. The proposal does not fall within the definition of ‘industry’ under BCC LEP 2001 (‘industry means the manufacturing, assembling, altering, repairing, renovating, ornamenting, finishing, cleaning, washing, dismantling, processing or adapting of any goods, articles, materials, liquids or gases for commercial purposes’) and therefore the provisions of SEPP 33 do not apply.

2.2.9 Greater Metropolitan Regional Environmental Plan No 2 – Georges River Catchment

As of 1 July 2009, planning instruments known as Regional Environmental Plans (REPs) are deemed to be State Environmental Planning Policies (SEPPs) (clause 120 of Schedule 6 to the Environmental Planning and Assessment Act 1979). The site is located within the Georges River catchment and therefore the Greater Metropolitan Regional Environmental Plan No 2 - Georges River Catchment (REP 2) is applicable. The general aims and objectives of this planning instrument are:

“(a) to maintain and improve the water quality and river flows of the Georges River and its tributaries and ensure that development is managed in a manner that is in keeping with the national, State, regional and local significance of the Catchment,

(b) to protect and enhance the environmental quality of the Catchment for the benefit of all users through the management and use of the resources in the Catchment in an ecologically sustainable manner,

(c) to ensure consistency with local environmental plans and also in the delivery of the principles of ecologically sustainable development in the assessment of development within the Catchment where there is potential to impact adversely on groundwater and on the water quality and river flows within the Georges River or its tributaries,

(d) to establish a consistent and coordinated approach to environmental planning and assessment for land along the Georges River and its tributaries and to promote integrated catchment management policies and programs in the planning and management of the Catchment,

(e) (Repealed)

(f) to provide a mechanism that assists in achieving the water quality objectives and river flow objectives agreed under the Water Reform Package.”

The proposed remediation project is remote from the Georges River and upstream of its tributaries, though will improve the environmental quality of part of the Catchment and ameliorate any potential risk to the site’s groundwater.



February 2011 2-9

Section 11 of REP 2 identifies development for the purposes of ‘land fill’ as requiring development consent. ‘Land fill’ is defined as being the “use of land for the purpose of disposing of waste, including use of a site for the collection and disposal of industrial, trade or human waste (other than development defined elsewhere in this table).” The specific matters for consideration for ‘land fill’ works are:

• “Whether groundwater contamination is likely to occur.

• The adequacy of any proposed leachate management system and surface water controls.

• The long-term stability of the final landform and the adequacy of a site management plan prepared for the development.”

The proposed remediation works will ameliorate the contamination of the Site and will remove any potential risk to the site’s groundwater. The surface water considerations relating to the proposed works are addressed in Section 8.2 of this report. The final land use of the Site has not been finalised as yet, but the remediation will allow for continued commercial/industrial activities. The general and specific planning principles presented in REP 2 are to be applied when a consent authority determines a development application. The general principles of REP 2 require the following to be taken into account:

“ (a) the aims, objectives and planning principles of this plan,

(b) the likely effect of the proposed plan, development or activity on adjacent or downstream local government areas,

(c) the cumulative impact of the proposed development or activity on the Georges River or its tributaries,

(d) any relevant plans of management including any River and Water Management Plans approved by the Minister for Environment and the Minister for Land and Water Conservation and best practice guidelines approved by the Department of Urban Affairs and Planning (all of which are available from the respective offices of those Departments),

(e) the Georges River Catchment Regional Planning Strategy (prepared by, and available from the offices of, the Department of Urban Affairs and Planning),

(f) all relevant State Government policies, manuals and guidelines of which the council, consent authority, public authority or person has notice,

(g) whether there are any feasible alternatives to the development or other proposal concerned.”

The proposed remediation works will ameliorate the contamination of the Site such that the works will have a beneficial impact rather than cumulative negative impact on the Georges River Catchment and is therefore likely to be in accordance with relevant local and regional planning strategies. The proposed works will be undertaken in accordance with the Guidelines for the NSW Site Auditor's Scheme (DECCW, 2006), the National Environmental Protection Measures (Assessment of Site Contamination) and the RAP prepared for the works.



February 2011 2-10

2.3 Commonwealth Matters

2.3.1 Environment Protection and Biodiversity Conservation Act 1999

The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) came into effect in July 2000 and requires the approval of the Commonwealth Minister for the Environment and Heritage for actions that may have a significant impact on matters of National Environmental Significance (NES). Approval from the Commonwealth is in addition to any approvals under NSW legislation. Approval under the EPBC Act is triggered by a proposal which has the potential to have a significant impact on a matter of NES or by a proposal which has the potential to have a significant impact on the environment which involves the Commonwealth. The EPBC Act lists the matters of NES which must be addressed when assessing the impact of a proposal. Based upon preliminary assessment, the proposal is not expected to impact on matters of NES, and as a consequence the EPBC Act is not triggered and approval from the Commonwealth Minister for Environment and Heritage is not required.



February 2011 3-1

3 THE SITE AND CONTEXT

3.1 Site History

The Site was initially part of a larger site owned by the Commonwealth of Australia and used for the manufacturing of munitions, including trinitrotoluene (TNT), in 1941. It was subsequently purchased by Taubmans in 1946, who manufactured a range of chemicals including chlorobenzene and DDT. The southern portion of the Site was purchased by ICIANZ Pty Ltd in 1953, where ICIANZ (and later Orica) continued to formulate a wide range of agricultural and pharmaceutical chemicals until the Site was closed in 2000. These chemicals included DDT and other organochlorine pesticides which are persistent in the environment and are covered by international treaties, national management plans and state legislation. Most structures across the site were demolished to slab level after operations ceased in 2000. The Site currently consists of concrete and bitumen pavements, concrete building slabs, retaining walls, a contaminated material store and open spaces. The main site entrance and site offices, amenities and decontamination unit are located on the southern boundary of the site. The proposal excludes the pharmaceutical building and surrounding land to the west which occupy about 2.1 ha. Between November 2003 to December 2004, limited remediation and validation was undertaken in this area and a new building (the Secure Soil Facility (SSF) was constructed to store about 10,000m3 of contaminated material excavated from the western part of the property (in the vicinity of the pharmaceuticals building). This is detailed further in the RAP (Section 3.3.9 of Appendix D ). Approximately 2,000m3 of contaminated material from remediation of the former Orica Chester Hill facility was brought onsite in 2008 and is stored above ground in a HDPE lined stockpile. The Site is regulated by the DECCW under Orica’s EPL (No. 2149 and No. 6964). As part of the management process, Orica conducts routine visual inspections and monitoring of the Site and its surrounds.

3.2 Site Investigations

Numerous investigations have been undertaken since 2000 on site soils and groundwater, and several zones of impacted soil and groundwater plumes have been identified. These are discussed in the RAP and include:

• SHE Pacific Pty Limited, 2000, Site Historic Review;

• URS 2000, Stage 1 Phase 2 Environmental Site Audit (Draft);

• CH2MHill, January 2004, Additional Stage 2 ESA;

• CH2MHill, April 2005a, Conceptual Site Model. Reference 32177;

• CH2MHill, September 2005b, Preliminary Report (Draft Version) Voluntary Investigation Part 1A – Groundwater and Soil;

• HLA, 2005, Phase 1 Remedial Investigation (RI), 2 Christina Road Villawood. Report S4056125_RPTFinal_22Dec05;

• HLA, August 2006a, Phase 2 Remedial Investigation, 2 Christina Road Villawood. Report S4060632_RPTFinal_30August06;



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• HLA, December 2006b, Remedial Technology Assessment (Soil), 2 Christina Road Villawood. Report S4066001_Final_22Dec06;

• HLA, December 2006c, Remedial Technology Assessment (Groundwater), 2 Christina Road Villawood. Report S4066001_Final_22Dec06;

• HLA, 2007, Phase 3 Data Gap Investigation, 2 Christina Road Villawood. Report S4075424_RPTFinal_29May07;

• HLA, 2007, Remedial Action Plan (original version), 2 Christina Road, Villawood, NSW. Report S4066001_Final_RPT_3Oct07;

• CH2M Hill, May 2007a. Pharmaceuticals Site, Villawood Under Building Investigation (Reference 359640.T1.02);

• CH2M Hill, June 2007b. Validation Report Pharmaceuticals Site, Christina Road, Villawood (Reference 359640.T1.01);

• A.D. Laase Hydrologic Consulting, June 2007. Groundwater Flow and Contaminant Transport Modelling;

• URS, 2007. HHERA, Orica Villawood site, 22 June 2007. Ref. 43217484 (original version);

• AECOM, 2010. Round 1 Groundwater Monitoring Event, 2 Christina Road, Villawood, NSW. Report S41070_RPT_Final_01Mar10;

• AECOM, July 2009. Remedial Action Plan Addendum, 2 Christina Road Villawood, S4063810_RAPaddendum_09July_2009;

• URS, 2010. HHERA, Orica Villawood Site, April 2010; and

• AECOM, June 2010. Remedial Action Plan Final, 2 Christine Road, Villawood, S4149701_Final_RAP_2June10.

Orica plans to remediate the site to a standard suitable for ongoing industrial use. A Remediation Action Plan (RAP) for the site was prepared by HLA Envirosciences (now AECOM) in 2007 and amended by AECOM in 2010. Further details of ongoing management and monitoring of the Site are provided in the RAP (Appendix D ). The RAP evaluated several alternative remedial strategies and technologies. Clean up to site specific risk based criteria with onsite treatment by a directly-heated thermal desorption (DTD) plant was identified as the preferred strategy for soil on the site given the nature of the soil and contaminants. Source removal to the extent practicable followed by monitored natural attenuation is the preferred strategy for remediation of the groundwater plumes.

Remediation of Car Park Waste Encapsulation, Botany Industrial Park’


February 2011 4-1

4 ASSESSMENT OF REMEDIATION ALTERNATIVES

Alternatives for the remediation of contaminated soil on the Villawood Site were considered systematically by HLA (and later AECOM), taking into account insitu soil identified in ten zones of concern and the excavated soils stockpiled within the SSF. The initial assessment covered both onsite and off-site options. However given the estimated volume of materials to be treated, and lack of licensed offsite treatment facilities in NSW, the latter option was eliminated. The assessment of potential treatment technologies was undertaken in three stages. The initial stage involved a review of twenty-five treatment technology options potentially applicable to the remediation of the contaminated soil on the Site. These options were selected for further review in the first stage of assessment.

4.1.1 First Stage of Assessment

The first stage of assessment involved screening the technologies against four parameters:

• Applicability - potential applicability considering the following:

- soil type and contaminant concentrations;

- the chemical and physical properties of the contaminants including the likelihood that contaminant concentrations could be reduced to meet clean-up goals;

- distribution of contaminants in the subsurface (vadose/saturated zone);

- access and space constraints;

- efficacy; and

- Occupational Health & Safety (OH&S) issues.

• Technology Status – the degree proven of the technology, history of use by remediation practitioners, acceptance by consultants and regulators, as well as availability of remedial equipment/infrastructure;

• Secondary Treatment Requirements - identification of secondary waste stream types and quantities and requirements for further treatment and / or disposal;

• Monitoring - short-term and long-term monitoring requirements to assess remediation performance and / or adverse impacts;

The technologies were ranked on the basis of an overall rating from 1 (low) to 5 (high) for each criterion. The following technologies were selected for further screening:

• Ex-situ Directly-heated Thermal Desorption (DTD);

• Ex-situ Plasma Arc Centrifugal Treatment (PACT);

• Ex-situ Startech;

• Ex-situ Mobile High Temperature Incineration;

• Ex-situ Cement Kilns;

• In-situ Vitrification;

• Ex-situ Vitrification;

• In-situ Electrical Conductive Heating;



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• Ex-situ Indirectly-heated Thermal Desorption (ITD), with condensate treated by another technology;

• In-situ Electrical Conductive Heating (ECH);

• In-situ Vitrification;

• In-situ / Ex-situ Biodegradation;

• Base Catalysed Decomposition (BCD); and

• Plascon. While not highly ranked, biodegradation was included because some of the contaminants at the Site could have been treated using this method. BCD and Plascon were included in the second stage of assessment since because these technologies have been successfully used in combination with ITD for the treatment of condensate.

4.1.2 Second Stage of Assessment

The second stage of assessment involved a more detailed screening of the highest ranking technologies from Stage 1. The second stage of assessment involved screening the technologies against eight parameters:

• Risk and Controls – technology limitations or constraints which may require additional controls prior to implementation to ensure appropriate containment of contaminants;

• Site Specific Issues – site specific factors that may pose constraints that limit the ability to implement the technology or efficacy of treatment;

• Bench/Pilot Scale Trial Requirements - need for additional testing of technology for site specific conditions;

• Timing of Technology Implementation - timeframe required to complete feasibility assessments and design of remediation system;

• Schedule - time required to reduce contaminant mass following implementation of technology, including the time required to achieve cleanup goals;

• Regulatory Approvals - likelihood of regulatory acceptance giving consideration to current policies including emissions, energy requirements and sustainability;

• Community Acceptance - likelihood of technology being acceptable to local community including adjacent industrial/commercial properties and nearby residents; and

• Relative Costs - including the capital costs such as equipment and its installation/commissioning, coupled with ongoing costs such as for maintenance and waste treatment/disposal.



February 2011 4-3

4.2 Remedial Technology Assessment Summary

The ratings from the first stage of assessment were carried over and added to the ratings from the second stage to identify the three highest rating technologies, which were;

• Ex-situ DTD (52 points);

• Ex-situ ITD (52 points) coupled with treatment of the condensate by BCD or Plascon; and

• In-situ ECH (48 points) with recovery of condensate and treatment by BCD or Plascon.

The lower score for ECH reflected lack of certainty about its ability to treat excavated material in the SSF and the fact that it is less mature the DTD and ITD. All three technologies were then assessed in greater detail for application as a single or combined solution. A brief description of each is given below.

4.2.1 Alternative Remediation Technologies

DTD, ITD and ECH are thermal technologies involving the application of heat to the contaminated soil to cause the contaminants to separate or vaporise from the soil. The result is ‘clean’ soil and a gas stream containing the vaporised contaminants. This process of separation is called thermal desorption. The main differences between the technologies relate to how the heat is applied to the soil, and the type of gas stream treatment system used to treat the resultant contaminated gas stream (off-gas). There are two main types of gas stream treatment systems: a recovery type system and destructive type system. The recovery type system involves cooling the gases and condensing the contaminants into a liquid which is collected and stored for further treatment. The destructive type system involves destroying the contaminants in the gas stream in a thermal oxidiser. ECH can be fitted with either a recovery type or a destruction type emission control system. A brief review of each of the technologies is provided below:

4.2.2 Directly-heated Thermal Desorption

DTD is an ex situ treatment method requiring the excavation of the waste from identified contaminated soil zones. To control emissions of dust and odour, the material handling process would be undertaken within an enclosed building, also fitted with an emission control system (ECS). The excavated soil would be stockpiled and screened to remove any debris, breakdown any large soil particles and homogenise the soil. The soil would then be transported via a conveyor system to the DTD Plant for treatment. There are two main types of DTD plants currently used to treat contaminated material, including chlorinated compounds. They differ principally in terms of the direction of gas and soil flow in the rotary dryer (co-current and counter current), with consequent differences in gas temperatures and the sequence of unit operations used to treat the off-gas. Both types of plants produce similar outcomes in terms of soil treatment levels and air emissions, the latter providing the ECS is Stockholm Convention on Persistent Organic Pollutants (December, 2004) compliant (i.e. includes a thermal oxidiser with appropriate residence time, temperature and turbulence, fast cooling and acid gas scrubbing). For convenience the co-current type of plant is described herein – this consists of a rotary dryer where the feed soil enters at the end where the gas burner is located, so that the soil and combustion gas move in the same direction where they exit at the opposite end. More detail is provided below.



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In a DTD Plant, heat is applied directly to the soil in a rotary dryer by intimate mixing of the soil and combustion gases from a gas fired burner that fires inside the dryer. The treated soil passes along the dryer, and then drops into a soil cooler (or pugmill) where the soil is cooled. The cooled soil is then stockpiled, and tested to confirm that contaminants have been removed to an appropriate level. DTD technology utilises a destructive type gas stream treatment system. The off-gas that arises from the rotary dryer typically passes through a cyclone to remove large dust particles prior to being routed to a thermal oxidiser, where contaminants are destroyed by combustion at a temperature of around 1,000oC. The hot gas stream is then transferred to an evaporative cooler where water mist is injected to rapidly cool the treated gas. The gas stream then passes through a baghouse, where fine dust particles are removed. An acid gas scrubber is the final step in the gas treatment system where products from the combustion of chlorinated contaminants are neutralised.

4.2.3 Indirectly-heated Thermal Desorption

As for DTD, ITD is an ex situ treatment process requiring the excavation of the waste prior to treatment. The excavation and material handling processes described above for DTD are also applicable for ITD. In an ITD plant, heat is applied to the soil indirectly by radiating through the shell of the rotary dryer. To achieve this, a number of gas fired burners are positioned external to the dryer shell. ITD plants typically use a recovery type gas treatment system. The off-gas from the rotary dryer is first directed to a particle removal device such as a baghouse, and then to a gas scrubbing and condensing unit. Within this unit, the gases are cooled by water and condensed. The emissions from this process are uncondensable gases. The residues are condensate containing the contaminants and water. The uncondensable gases then pass through activated carbon to remove any remaining condensable contaminants. The contaminated carbon is recycled through the process. The off-gas is then routed back to the furnace of the plant to combust any carbon monoxide and non-condensable hydrocarbons present. The condensate, which contains the contaminants would be collected and stored (in 200 L drums or equivalent containers) whilst awaiting further treatment. Recovered water is transported to an onsite wastewater treatment facility, where it is treated and then discharged. Treated water may also be used for cooling and rehydrating the treated soil. The hot treated soil is transported to a soil cooler, where it is re-moisturised and discharged. The cooled soil is transported to a storage area and sampled to confirm that contaminants have been removed to an appropriate level. The stored condensate, containing concentrated contaminants, would then require a second stage treatment for destruction. This was likely to have involved transport to another off-site facility for treatment.



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4.2.4 Electrical Conductive Heating

Unlike ITD and DTD, desorption of contaminants in the ECH process occurs in situ. Therefore, excavation of the soil and control of associated emissions from materials handling would not be an issue. The ECH process involves the installation of a series of heater and vacuum wells in the soil to be treated. The heater wells are installed in a hexagonal pattern arrangement and used to transfer heat into the soil. The vacuum wells are installed in the centre of each hexagon and used to extract the vaporised contaminants (off-gas). To ensure worker safety and minimise heat loss at the surface, an insulation layer would be placed over the area undergoing treatment. To enable access to the wells and other equipment, concrete is typically placed over the insulation layer. The heater wells use electrical energy to conductively heat the soil surrounding each well. In the heating process, some contaminants are destroyed in situ and some are vaporised. Like the ITD and DTD processes, the off-gas also has to be treated. ECH processes have been developed with either a recovery system, like ITD, or a destructive system, like DTD. For the Villawood site, a recovery system with subsequent destruction of the condensate by BCD or Plascon was considered most suitable. A thermal oxidiser or similar would still be required to treat the high levels of CO in the offgas.

4.3 Selection of Preferred Remediation Option

Based on the findings of the RTA and further evaluation of the three thermal technologies above DTD was selected as the preferred remediation technology for the following reasons:

• Degree proven:

DTD is considered to be a proven technology because it has been in use since the mid-1980s. The technology has been applied to around 120 remediation projects, treating approximately 3.5 million tonnes of soil contaminated by hazardous compounds. It is suitable for treating the CoCs at the Site.

A DTD plant was used at the former Allied Feeds site (completed in August 2009) and was used to treat to treat 180000 tonnes contaminated soils at the Lednez site on the Rhodes Peninsula (completed May 2010) to treat 80,000 tonnes of soil contaminated by chlorinated compounds. The successful local demonstration of the technology at full scale at the above projects provides confidence in the technology and will assist in achieving planning approvals and community acceptance.

• Simplicity of design and operation

DTD is a relatively ‘simple’ technology when compared to ITD. It is more robust and easier to operate and maintain compared with ITD, which means that the likelihood of operational success for DTD is greater than for ITD.

• Stack Emissions

Emissions to air for the ITD and DTD technologies are anticipated to be comparable, but ITD has marginally lower emissions than DTD for some (but not all) air pollutants. If designed and operated properly in accordance with the best practice guidance of the Stockholm Convention, emissions from either technology are not anticipated to cause appreciable health or environmental risks.



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• Residues

As DTD utilises a destructive Emission Control System (ECS) to treat the off-gases, significant residues are not generated. Consequently, secondary treatment systems are not required. ITD, by contrast, produces secondary wastes that require extensive secondary treatment processes such as BCD or plasma arc to destroy the concentrated residues that are produced. For DTD there is no requirement for treatment, storage and transport of residues, as there is for ITD.

• Schedule

DTD is anticipated to be faster in treating the Site’s contaminated material than ITD. The reduced timeframe of the DTD operations would directly translate into a shorter overall project duration with corresponding reduction in associated impacts for the local community.

• Space

There is sufficient space on the Site to establish the plant and treatment infrastructure.

• Applicability

DDT is suitable for treating soil contaminated by OCPs in the SSF, contaminants present in hotspots remaining on the site as well as the covered stockpile of contaminated soil from Chester Hill stored on the site.

It is noted that a similar process was followed for Orica's Car Park Waste Encapsulation Remediation Project at the Botany Industrial Park site. Under the approval of the DoP, a DTD plant was selected as the preferred remedial technology and thermal operations commenced in February 2011.



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5 PROJECT DESCRIPTION

5.1 Overview of the Project

The primary objective of the project is to remediate the Site to an extent suitable for ongoing industrial purposes, compatible with surrounding land uses. It is proposed to remediate contaminated soil on the site including insitu soil in several hotspots, a covered stockpile of soil from Chester Hill and contaminated soil stored in a Secure Soil Facility (SSF) on the site. The remediation would include the following steps:

• Mobilisation to site and set up of an onsite soil treatment facility (STF) comprising a Water Treatment Plant (WTP), a Feed Soil Building (FSB) and associated Emission Control System (ECS), a Directly-heated Thermal Desorption (DTD) plant, hardstand areas, environmental controls, and internal haulage roads;

• Sequential targeted excavation of contaminated soil across the Site exceeding site specific reuse criteria and transport to the STF;

• Pre-treatment of the excavated soil in the FSB including screening to remove oversized materials, mixing of the excavated, stockpiled and stored soil, testing of contaminated materials and feeding of contaminated material into the DTD Plant.

• Treatment of the pre-treated soil in the DTD plant;

• Validation testing of remaining unexcavated soil and of treated soil;

• Stockpiling of treated material;

• Reinstatement of the excavated area s with validated material; and

• Decontamination and decommissioning of plant and buildings. The remediation method is described in greater detail in the following sections.

5.2 Site Establishment and Construction

The proposed remediation process would require an initial construction and set up period of some 26 weeks which would include the following:

• Site establishment and construction of the WTP;

• Establishment at the Site (including laying of hardstand area) and construction of the FSB and associated ECS, as well as the DTD Plant;

• Construction of internal haul roads linking the FSB and the treatment area to the surplus soil stockpile area; and

• Targeted bulk earthworks to remove hotspots.



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In addition to the general plant and treatment buildings required for the project the following accommodation and facilities would be established at the Site:

• Site offices, stores, work sheds, lunchrooms and changing areas; and

• Temporary site sheds, ablution blocks and decontamination units. A range of Site establishment activities would also be undertaken prior to the commencement of remediation works on the Site. These activities would include the establishment of environmental protection, materials handling, site security and health and safety measures. The layout of the Site showing the arrangement of the above buildings, plant and support facilities is illustrated in Figure 5 . The internal haul roads to be used during site establishment and throughout the project are detailed in Figure 6 . Further details of this process are provided in the RAP prepared in respect of the works and included as Appendix D to this EA. Excavation of the materials within the targeted remediation areas will be undertaken within areas segregated by fencing from the remainder of the Site. If required, the material will be fed to a coarse vibrating screen (“Grizzly”) by a front end loader to remove oversized materials, such as bricks, concrete, crushed drums, etc. Oversized material will be stockpiled and tested for contamination before being disposed to an appropriate waste facility, recycled where possible or transported to the FSB for treatment. The remaining material will be temporarily stockpiled before being transportation to the FSB. Further information on the air emissions from open excavations is detailed in Section 8.3 . Any seepage or free water encountered during excavation would be removed and treated in the onsite WTP.

5.3 Water Management

Over the course of the remediation works, the types of water that may be encountered are clean water, contaminated water, grey water and sewer quality water. Water management has been further discussed in Section 8.0 . As detailed previously, groundwater is not subject to the remediation activities under this EA. All potentially contaminated water collected on the Site from the following areas/activities will be collected and transported to the dedicated on-site WTP for treatment:

• Surface water falling on areas such as the external bunded areas of the treatment area;

• Water purged during the acid gas scrubbing phase of the DTD treatment process;

• Small volumes of free water (seepage) accumulating in active excavations; and

• Water from personnel and plant decontamination processes. The Site would be serviced by a WTP. The WTP would use a process of filtration and carbon absorption to treat water to a standard to enable reuse in the wheel wash, on treated soil stockpiles for rehydration and dust control, or disposal to the sewer. Other water collected from the Site will be reused during the excavation, remediation and reinstatement works, where possible. A process flow diagram of the water management onsite is shown in Figure 7 .



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Surface Water Quality Criteria

Surface waters captured on building roofs at the Site will be considered to be free from contamination and will be discharged directly to the stormwater system during the remediation works or reused for dust mitigation purposes. Surface water collected from the treatment and excavation areas will be recovered and managed as if it is contaminated, and directed to the on-site WTP. No other discharges to surface waters are proposed to be recovered during the works. A Water Management Program would be implemented at the Site to minimise the volume of contaminated water generated, and to manage the water in the most efficient manner possible in compliance with regulatory requirements. In summary, water that does not meet the water reuse criteria as presented in the RAP (Appendix D ) would be recovered and treated in the WTP before being recycled or disposed of as appropriate.

5.4 Soil Treatment Facility

The Soil Treatment Facility (STF), located to the west of the SSF, comprises the FSB, DTD Plant, WTP and treated soil stockpiles. The layout of the STA is shown in Figure 5 . The processes proposed in this area are discussed in more detail below.

5.4.1 Feed Soil Building

Handling and testing of excavated material would take place within the FSB before material is fed into the DTD Plant for treatment. The FSB would be constructed over a hardstand area and would be fully enclosed and ventilated. The FSB would be constructed of steel and fitted with louvres or hatches for ventilation as required to facilitate management of air flow. An ECS would be constructed and operated to preserve air quality within the building and minimise emissions to the atmosphere. The ECS would be operated to ensure the flow of air into the building and through the ECS at all times. The ECS would typically comprise a fan, duct work, dust filters, two stage carbon beds and a stack. It is anticipated that the ECS used would be sized at 90,000 m³/hr. However, the actual capacity would be determined through detailed design studies, to satisfy Occupational Health and Safety (OH&S) considerations. Loaded trucks would enter the FSB through a double air-lock door before being unloaded by front end loaders in the central area of the FSB. The trucks then proceed to the decontamination area (automated wheel wash) before exiting via another double air-lock door. Water collected from the decontamination area and wheel wash would be pumped to the WTP for treatment and recycling/disposal as appropriate. Material transported to the FSB would be stockpiled using a front end loader before undergoing further screening and testing for contaminant levels and other characteristics. The material would be blended (physically and chemically) to achieve a relatively homogenous feed material prior to being loaded into the feed hopper of the DTD Plant. Material must be continually fed into the plant 24 hours per day and this would take place at a rate of up to 35 tonnes/hour. Activities within the FSB, including screening and testing would therefore also take place 24 hours per day.



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Oversized contaminated materials (which may include concrete, steel corroded drums and timber) requiring treatment would be crushed or shredded in the FSB and fed into the DTD Plant. The layout and operations within the FSB are schematically illustrated in Figure 8 .

5.4.2 Directly-heated Thermal Desorption Plant

Following an extensive program of technology assessment, feasibility studies and community consultation, Orica has identified DTD technology as the most appropriate method to undertake the remediation of contaminated soil the Site. The detailed design of the DTD Plant and associated plant/equipment to be used for this project would be undertaken following any project approval. Details would be provided as part of the Technology Assessment required to be submitted under the EHC Act. All elements of the plant would be Stockholm Convention compliant, where relevant, and plant components would be selected to ensure that the actual environmental performance is within the commitments set by this EA. Further information is provided in Appendix E . DTD technology has been used for more than 20 years to treat hazardous waste and has been used extensively in the United States (US) to treat soil contaminated with chlorinated organic compounds. There are two main types of DTD plants currently used to treat contaminated material including chlorinated compounds. They differ principally in terms of the direction of gas and soil flow in the rotary dryer (co-current and counter current), with consequent differences in gas temperatures and the sequence of unit operations used to treat the off-gas. Both types of plants produce similar outcomes in terms of soil treatment levels and air emissions when treating material that contains chlorinated chemicals. As indicated, the detailed design for the DTD Plant and associated equipment/plant would be completed following any project approval. For convenience the co-current type of DTD plant is once again described herein. Further detail on the compliance to the Stockholm Convention and NSW legislation and regulations in regard to the DTD Plant is provided in Appendix E . The process is illustrated in Figure 9 and is discussed in more detail below.

Rotary Dryer

The first step in the DTD treatment process involves the volatilisation or separation of contaminants from the material in the rotary dryer. The dryer utilises natural gas as fuel to heat the contaminated material to a temperature of approximately 300ºC to 450ºC. In a co-current system, the contaminated material enters the rotary dryer at the end where the burner is located and the combustion gas and treated soil move in the same direction to where they exit at the opposite end of the dryer. Contaminants desorb and volatilise as they pass through the dryer. Soil is heated in the first third of the dryer with most desorption and volatilisation occurring in the next third as contaminants reach their boiling points.



February 2011 5-5

The operating temperature of the rotary dryer would be determined considering both the efficiency of removal of organics from the soil and the environmental sustainability of the process. The optimum soil treatment temperature is the temperature above which there is a diminishing removal rate for organics from the soil. Operating above this temperature would raise broader environmental issues such as the greenhouse impact of the carbon dioxide (CO2) generated and climate change. This issue has not previously been considered in the context of thermal treatment of contaminated soil. A further consideration in determining the optimum soil treatment temperature for the rotary dryer is the volatilisation of mercury from the soil and consequent emission of mercury to air from the DTD Plant stack. As the soil treatment temperature is increased from 350 to 550°C, the amount of mercury released from the soil would increase from around 50 to around 100%. Given that removal of mercury from the process gas is poorly understood, it may be necessary to lower the soil treatment temperature to minimise potential emissions of mercury from the stack. This is further detailed and discussed in Section 8.3 . Therefore, a balance must be determined that optimises the outcome for these competing environmental outcomes. This balance would have a bearing on the final operating temperature of the rotary dryer. These issues which would be further considered when refining the detailed design of the plant and would be addressed as part of the Technology Assessment for the project. Further information is provided in Appendix E . Once it has passed through the rotary dryer, the heated soil material passes to a pugmill where it is sprayed with water for cooling and rewetting. The treated material is then transferred to temporary treated soil stockpiles awaiting validation, while the off-gases move on to the cyclone.

Cyclone

The off-gases flow from the rotary dryer through a cyclone, where large dust particles are removed, to the thermal oxidiser. The dust from the cyclone is directed to the pugmill where it is mixed with the treated soil for rewetting and validation.

Thermal Oxidiser

The thermal oxidiser is used to treat the gases produced through the heating of the soil material in the rotary dryer and would be designed in compliance with the Stockholm Convention (i.e. with appropriate residence time, temperature and turbulence). The thermal oxidiser operates at a temperature typically between 900 to 1,000ºC using natural gas fuel. At this temperature, the contaminants present in the gas (from the feed material) oxidise or decompose forming carbon dioxide (CO2), water vapour and hydrogen chloride (HCl) with small amounts of other by-products such as chlorine (Cl2) and sulphur compounds. In order to maintain the correct temperature to maximise destruction efficiency and minimise the formation of by-products, the thermal oxidiser would be fitted with a sophisticated temperature control system which would be consistently monitored.



February 2011 5-6

The operating temperature and destruction efficiency of the thermal oxidiser would be discussed in the Technology Assessment. A new consideration would be balancing the competing environmental issues of contaminant destruction and greenhouse gas emissions, in line with the principles of ecologically sustainable development (ESD), as described above for the rotary dryer. There would also be an optimum operating temperature for the thermal oxidiser, above which there is a diminishing return in terms of the incremental mass of contaminant destroyed and incremental amount of greenhouse gas produced. Further information on the thermal oxidiser is provided in Appendix E .

Evaporative Cooler

Once gases have passed through the thermal oxidiser they must be rapidly cooled to minimise the potential for dioxin formation and allow further treatment before release to the atmosphere – as required by the Stockholm Convention. To achieve this, the hot gases are drawn into the evaporative cooler by an induced draught (ID) fan. In the evaporative cooler, water is injected to rapidly cool the gases to a temperature which is suitable for further treatment. Further information on the evaporative cooler is provided in Appendix E .

Baghouse

The cooled gas from the evaporative cooler is combined with steam from the pugmill and drawn into the baghouse by an ID fan. The baghouse contains a series of fabric filters which remove particulates. The design of the baghouse would also take into account other factors such as the high moisture and acidity of the gas stream and suitable materials of construction and insulation would be used as required. These are matters of detail that will be addressed in the plant design, Hazard and Operability (HAZOP) study and Technology Assessment. However preliminary design data has been included as Appendix E to this EA.

Acid Gas Scrubber

The final step in the treatment process involves the removal of acid gases from the exhaust gas. The acid gas scrubber consists of a packed tower with a re-circulating caustic solution that reacts with any HCl and Cl2 in the exhaust gas to form a salt solution. Following this, the ‘clean’ treated gas is vented to the atmosphere via the scrubber stack which is greater than 15 m in height.

Treated Soil

Treated soil would be stockpiled adjacent to the STA with drains and bunds provided to manage runoff. Stockpiles would be stabilised with spray grass or other such treatment and would be wetted when necessary to control dust. The treated, stockpiled soil will be retained until completion of remediation works at the Site when it will be transported (by truck) back to the targeted excavation areas for reinstatement works.



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5.5 Decommissioning

Upon completion of the remediation works, the Site buildings, plant and equipment would be decommissioned, decontaminated and removed from the Site. Decommissioning of the Site would include:

• Disconnection of unnecessary utilities;

• Removal of Site facilities;

• Removal of temporary fencing;

• Removal of pollution controls; and

• Removal of plant and equipment.

5.6 Reinstatement of Site

The Site would be reinstated using the treated, validated soil material generally to the existing levels of surrounding areas.

5.7 Access and Transport

5.7.1 Access

The primary access route to the Site would be via the main entry gate on Christina Road (Gate 1). A security gate will be patrolled at this entry point to control access to and around the Site during the operational hours of the project. The site offices, amenities and decontamination facilities would be located at the northern end of the Site adjacent to Christina Road (refer to Figure 5 ). All site personnel entering and leaving the Site would be required to pass through the clean/dirty zone and the decontamination station located adjacent to the Site offices.

5.7.2 Vehicle Movements and Parking

Vehicles travelling to and from the Site will be limited to employees, delivery of plant and equipment and deliveries of consumables. Likely routes to the Site would be:

• Inbound from the west (only) – drive along Woodville Road turning onto Christina Road and accessing the Site via Gate 1;

• Outbound to the west – exit via Gate 1 along Christina Road and turn onto Woodville Road; and

• Outbound to the east – exit via Gate 1 along Christina Road and turn onto Miller Road at the roundabout. Proceed in northerly or southerly direction.

The primary traffic routes to and from the Site utilise arterial roads to access the Sydney metropolitan area, therefore minimising the impact on the local road network.



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There is expected to be a maximum of 45 construction personnel at any one time during the Site establishment and construction period. During operation, it is anticipated that there would be a maximum of 30 employees on the Site and it is assumed that all employees would travel by private car to work. Parking for employees will be provided in the existing car park (adjacent to Gate 1 at Christina Road).

5.7.3 Transportation of Material

Materials at the Site will be excavated, handled, moved, treated and stockpiled in a manner designed to minimise exposure to the environment. For materials being handled within the site, the following procedures would be implemented:

• Trucks carrying excavated materials will be covered and decontaminated in the wheel wash facility within the excavation area before exiting;

• Trucks will proceed directly to the FSB or soil stockpile areas as appropriate along the predetermined haul roads;

• Trucks carrying contaminated materials will not be permitted to drive over areas which have previously been excavated, validated or reinstated;

• Trucks carrying contaminated materials will remain covered until authorised to unload within the FSB. The trucks will be decontaminated at the FSB and the truck body covered before exiting the building;

• Empty trucks will return directly to the excavation area along predetermined haul roads; and

• Validated areas will be effectively isolated from contaminated areas of the Site by the use of physical means such as the placement of clean material bunds, temporary fences and by use of signage.

It is anticipated that these trucks would operate on the Site up to 12 hours per day (7am to 7pm), six days per week.



February 2011 5-9

5.8 Control of Site Entry and Exit

Fencing will be erected where necessary to secure portions of the Site. Shade cloth will be erected on all perimeter fences. Entry to the Site will be controlled through the introduction of a sign-on/sign-off log system at the entry point. Alternative entrances to the specific areas of the Site such as the STA will only be used in the event of an emergency. The following Site controls will be implemented:

• Only authorised personnel will be allowed on-site;

• Site personnel will gain access to the Site only after they have:

- Undertaken the required medical examination;

- Signed on in the sign-on/sign-off logbook;

- Attended and completed a site safety induction briefing (applicable to all site workers and visitors);

- Are wearing all applicable personal protective equipment (PPE); and

- Signed the OH&S Plan (OHSP) acceptance form (applicable to all site workers and visitors).

• All construction vehicles and delivery vehicles will enter the Site through the nominated gate. When a vehicle enters the Site, it will proceed along the designated vehicle route to the pre-arranged rendezvous area where an authorised person will meet the vehicle and provide the driver with further instructions.

In the event of an emergency on-site and the need for off-site emergency services personnel to access the Site works, the access process may be expedited. In these situations, which require the need to minimise delays in accessing injured site personnel or critical areas of the Site, prior arrangement will be made for special Site access procedures. However, given the nature of the remediation works, all PPE and decontamination protocols will remain in effect at all times. An Emergency Response Plan (ERP) will be developed prior to site establishment detailing the specific procedures relating to site emergencies. In addition, appropriate OH&S and planning activities would be completed, documented and approved where necessary prior to site establishment. These activities include:

• Verifying the OH&S training of all employees and subcontractors scheduled to work at the Site;

• Medical examinations for all employees and subcontractors who are to work at the Site for a period of more than one month;

• Documented attendance at an on-site safety induction briefing for all employees and subcontractors scheduled to work at the Site;

• Appointment of a Site Safety Officer (SSO);

• Provision of first aid and medical facilities and supplies at the Site;

• The procurement, provision and training in the use of personal protective equipment (PPE) detailed in the OH&S Plan (OHSP) and works procedures;



February 2011 5-10

• Completion of all quality assurance (QA) and maintenance checks on all electrical equipment, plant and tools to be used at the Site at the commencement of works. Scheduled ongoing checks will be performed on all plant and equipment brought on-site;

• Installation of decontamination units at the specified areas on the Site, as detailed in the OH&S Plan and the design drawings; and

• All activities required to provide a safe and healthy work environment for all personnel who work or visit the Site.

5.9 Environmental Controls

Excavation and handling of contaminated material will be undertaken within Exclusion Zones and the FSB. The FSB will be fitted with an ECS to minimise release of contaminated emissions and to protect workers. Further measures to protect the environment during the remediation works include:

• Stormwater control measures such as retention basins, bunding, silt fences, oil absorbent materials, dewatering systems, and water treatment systems for the management of site water;

• Process venting controls, vehicle emission controls, stockpile covering and treatment designed to control air and dust emissions from equipment, plant and stockpiles used during Site works;

• Layout of Site such that noise generating plant and equipment is located as far from residences as possible with buildings and soil stockpiles providing visual and acoustic buffers;

• Silencers fitted to plant and equipment to minimise noise;

• Equipment decontamination control measures comprising a wheel wash and truck wash facilities, to manage the potential for cross-contamination during the excavation and soil treatment phases of works; and

• Protective fencing and restricted Site access including delineation of Exclusion Zones (areas of the Site outlined in the OHSP that either require additional protective measures or may require the adoption of additional OH&S requirements and work practices) to limit unauthorised access to designated areas of the Site.

For spill management, plant, buildings and decontamination units will be bunded and appropriate emergency response and incident management procedures would be in place on the Site at all times. Regular inspections of all implemented environmental control measures will be undertaken as follows:

• Within the vicinity of the STA area – prior to the commencement of work on each day;

• Along haul roads and in perimeter areas outside Exclusion Zones – prior to the commencement of work on the first working day of each week; and

• At all Site locations – at hourly intervals throughout major storm events.



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An inspection report will be recorded and maintained on file after each inspection.

Further details of specific environmental controls to be implemented on the Site are provided in the RAP included as Appendix D , and the Statement of Commitments in Section 10 of this EA.

5.10 Waste Management

It is anticipated that the off-site disposal of materials may be necessary during the course of the remediation works to remove foreign material such as crushed drums, steel reinforcement, scrap steel, pipework and timber. These materials (if they do not require treatment in the DTD Plant) and low level contaminated clothing and PPE from Site workers, will be transported off-site for disposal at an appropriately licensed landfill or recycling facility. Other waste streams may also include bulk asbestos containing material which may be present in the form of stormwater pipes and drains. These issues are further discussed throughout the RAP (Appendix D ). The procedure for off-site waste disposal will be as follows:

• Material requiring off-site disposal will be stockpiled separately and will be tracked using the Materials Tracking System;

• The liquid or non-liquid material will be classified in accordance with the NSW EPA (2004) Environmental Guidelines: Assessment, Classification and Management of Liquid and Non-Liquid Wastes;

• Notification of the waste facility organised to receive the waste to confirm that the facility is licensed to accept the material;

• If the waste facility is licensed to accept the class of waste, the material will be transported under the appropriate licence to the designated receiving facility. Every load of waste removed from the Site will be recorded; and

• A copy of the waste depot weighbridge docket will be collected and retained for each load of waste delivered.

Waste material from the remediation works will be disposed only at appropriately licensed landfill and recycling facilities. Waste destined for off-site disposal will be hauled from the Site in semi-trailers or truck-trailer combinations. All loads will be secured prior to leaving the Site with appropriate covers. Trucks wheels and bodies will be washed to ensure that site materials are not tracked onto local roads.

Excavated Material

The RAP (Appendix D ) specifically deals with the handling, classification, management and tracking of excavated material associated with the project. Specifically, the RAP details the materials handling procedures and how it has been designed to provide “cradle-to-grave” control and management at all times to ensure that the Site is suitable for the proposed land use with a high level of confidence. If required, excavated materials will initially be screened to separate oversize material (greater than 100 mm) from materials suitable for treatment. All screened material will be loaded into trucks for transportation to the FSB for further processing and treatment. Oversize material will be temporarily stockpiled, and subsequently sampled and analysed to assess their suitability for disposal to landfill or recycling facilities in accordance with Waste Classification Guidelines (DECC 2008). Materials considered unsuitable for off-site disposal or re-use on-site will be transported to the FSB for further processing.



February 2011 5-12

If available data indicates that materials overlying contaminated materials may be unimpacted, the overlying materials will be sampled and analysed, and the results compared against the site based criteria. Where the results indicate that the material may be reused on-site, it will be transported directly to soil stockpiling areas. Alternatively, where the results indicate that the material is unsuitable for reuse and treatment is required, it will be hauled to the FSB for processing and treatment.

Liquid Trade Waste

A trade waste licence will be obtained (or an existing one will be modified) from Sydney Water for the disposal of treated waters into the sewerage system. This licence will nominate the appropriate types and concentrations of any contaminants that are permitted for discharge. Site water will not be discharged from the Site unless tested and in full compliance with the licence water quality criteria. All discharges will be documented in terms of quantity and quality, and compliance with the licence criteria will be recorded.

5.11 Program of Works

The remediation process is expected to take approximately 14 months to complete including site establishment, pre-treatment, treatment, validation, decommissioning and reinstatement. The breakdown of this program is generally as follows:

• Site establishment and construction (including DTD Plant commissioning and PoP testing) – approximately 26 weeks;

• Excavation and treatment – approximately 20 weeks;

• Decommissioning and demobilisation – approximately 12 weeks; and

• Reinstatement of excavated areas – approximately 12 weeks (NB concurrent with demobilisation).

It is anticipated that construction and demobilisation hours would be between the hours of 7am and 6pm Monday to Friday, and 7am to 1pm Saturdays. No construction work would occur on Sundays and Public Holidays. Operation hours for the excavation activities would be between 7am to 5pm, six days per week. Operation hours for the FSB and the DTD Plant would be 24 hours per day, seven days a week, with maintenance days scheduled as required.

5.12 Utilities and Resources

Utilities and resources required for the proposed remediation works include:

• Natural gas;

• Electricity;

• Diesel; and

• Potable water. Any existing utilities located within materials requiring excavation would be temporarily bypassed and removed so as not to hinder excavation activities. These services and utilities would be re-established as required as part of the reinstatement works.



February 2011 5-13

5.12.1 Natural Gas

Natural gas is required for the rotary dryer and thermal oxidiser of the DTD Plant. Gas will be supplied to the DTD via underground pipe from the main gate at Christina Road. The amount of natural gas required to operate the plant will depend on the final operating temperatures of the rotary dryer and thermal oxidiser. As discussed previously, the principles of ESD must be considered to determine the appropriate operating temperatures for these components, and to balance competing outcomes of contaminant removal and destruction, against greenhouse gas emissions and climate change. No alternative or back-up fuels are proposed and a loss of gas supply would automatically initiate a controlled shutdown of the DTD Plant.

5.12.2 Electricity

During normal operation all power for the plant will be supplied from the existing grid. The DTD Plant will be fitted with a back-up power supply to enable controlled shutdown and restart in the event of a power outage.

5.12.3 Diesel

Diesel is required for the back-up generator fitted to the DTD Plant as well as for the operation of equipment to be used on Site such as excavators, loaders and trucks. All re-fuelling will be by mini-tanker in a dedicated bunded area. No diesel storage will be provided on Site.

5.12.4 Potable Water

Water is required for the cooling process within the evaporative cooler and the acid gas scrubber within the DTD Plant. This water will be supplied from the existing town water supply to a break tank at the DTD. It will then be pumped from the break tank to the evaporative cooler and acid gas scrubber. A back-up water tank will be provided for the evaporative cooler, pressurised by air cylinders to cater for loss of mains water flow.

5.13 Auditing and Validation

The CLM Act sets out requirements for site audits. The Act requires a site audit to be undertaken under certain circumstances such as where a voluntary investigation proposal or voluntary remediation proposal has been agreed with the DEC or where required under State Environmental Planning Policy No. 55 - Remediation of Land (SEPP 55). Orica submitted a draft voluntary proposal for remediation of the site and investigation of the nature and extent of groundwater contamination on 1 March 2005. Following comments from DECCW, a final voluntary proposal was submitted by Orica on 18 March 2005. Following formal approval of the remediation project, the voluntary proposal will be revised and will likely be issued as a Voluntary Management Proposal (VMP).



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6 CONSULTATION AND ISSUES IDENTIFICATION

6.1 Formal Procedures for Consultation

6.1.1 New South Wales Formal Procedures

This EA has been prepared in accordance with Part 3A of the EP&A Act and its Regulation. Part 3A of the EP&A Act ensures that the potential environmental effects of a proposal are properly assessed and considered in the decision making process. In preparing this EA, the requirements of the Director-General have been addressed as required by Clause 75F of the EP&A Act. Each of the matters raised by the Director-General for consideration in the EA is outlined in Table 6-1 below, together with the relevant section of the EA which addresses that matter. A copy of the EARs issued by the Director-General is provided in Appendix B .

Table 6-1: Director-General's Requirements

Matter Reference in EA

General Requirements

The EA must include:

• An executive summary; Executive Summary • a description of the overall remediation strategy for the site,

including the: - objectives of the remediation strategy; - proposed staging of the strategy; and - relationship between the various stages of the

strategy;

Section 1.2, 4 and 5

• a detailed description of the project, including the: - need for the project; - alternatives considered; - Remedial Action Plan for the project, which includes:

o characterisation of the nature and extent of contaminated material

o and contaminated groundwater plumes; o details of the proposed remediation process,

including treatment o methodologies and processes, as well as

further justification for why o contaminated groundwater does not require

remediation; o justification of the proposed treatment and

remediation criteria; o details of proposed remediation management

measures including o the management of excavated material,

stockpiles and wastewater; o a site validation plan; and o details of compliance with the Contaminated

Land Management Act 1997;

Section 3, 4 and 5,

Appendix D – RAP



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- final landform following remediation and the suitability of fill material; and

- ongoing management of the site following remediation works;

Section 3, 4 and 5,

Appendix D – RAP

• demonstration that the current storage of contaminated material on site is compliant with relevant licences;

• a risk assessment of the potential environmental impacts of the project, identifying the key issues for further assessment;

• a detailed assessment of the key issues specified below, and any other significant issues identified in the risk assessment (see above), which includes:

• a description of the existing environment, using sufficient baseline data;

• an assessment of the potential impacts of all stages of the project, including any cumulative impacts that may arise from the combined remediation of the site and the adjacent industrial uses, taking into consideration any relevant guidelines, policies, plans and statutory provisions (see below);

• a description of the measures that would be implemented to avoid, minimise, mitigate, rehabilitate/remediate, monitor and/or offset the potential impacts of the project, including detailed contingency plans for managing any potentially significant risks to the environment;

• a statement of commitments, outlining all the proposed environmental management and monitoring measures;

• a conclusion justifying the project on economic, social and environmental grounds, taking into consideration whether the project is consistent with the objects of the Environmental Planning & Assessment Act 1979; and

• a signed statement from the author of the Environmental Assessment, certifying that the information contained within the document is neither false nor misleading.

Section 11

Sections 8 and 9

Section 8.7

Section 8 ,

Appendix D – RAP

Section 10

Section 12

(see signature page of this EA)

Air Quality and Health • a quantitative assessment of potential air quality and odour

impacts of the project; • a human health risk assessment covering the inhalation of

criteria pollutants and exposure (from all pathways i.e., inhalation, ingestion and dermal) to specific air toxics as a result of the contamination of the site; and

• details of pollution control measures for fugitive and point source emissions;

Section 8.3 and 8.6,

Appendix H – Air Quality Assessment

Appendix I – HHIA



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Soil and Water • an assessment of the potential groundwater and surface

water impacts which includes: - sediment and erosion controls during excavation and

stockpiling of contaminated material, as well as the re-instatement of the site;

- details of the management of “clean” and contaminated material;

- stormwater management including management of “clean areas”, treatment and disposal of contaminated stormwater, and management of stormwater following remediation;

- management measures in the event that contaminated groundwater is encountered; and

- groundwater monitoring program;

Section 5, Sections 8.1 and 8.2,

Appendix D – RAP

Ongoing Groundwater Monitoring Program (separate to this EA)

Noise and Vibration Impacts

The Environmental Assessment must include an assessment of the noise impacts of the project in accordance with the NSW Industrial Noise Policy (EPA 2000) and the Environmental Criteria for Road Traffic Noise (EPA 1999). The Assessment shall include consideration of noise impacts resulting from all noise sources associated with the project including (but not necessarily limited to) excavation works, noise emissions from the DTD Plant, any activities proposed to be undertaken during evening or night time periods and traffic noise.

Section 8.4, Appendix J – Noise Assessment

Hazards

The Environmental Assessment must include a Preliminary Hazard Analysis.

Section 8.5, Appendix K – PHA

Traffic

The Environmental Assessment must outline: • details of the traffic volumes likely to be generated during

construction and operation; and • an assessment of the predicted impacts of this traffic on the

safety and capacity of the surrounding road network.

Section 5, Section 9.3

Visual

The Environmental Assessment must assess the visual impact of the proposal (height, scale and lighting) on the local and regional area.

Section 9.2, Appendix L – Visual Assessment



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Consultation Requirements

You must undertake an appropriate and justified level of consultation with the following parties during the preparation of the Environmental Assessment:

• NSW Department of Environment Climate Change and Water

• NSW Department of Health

• Bankstown City Council

• Office of Water; and

• The local community and relevant community groups.

The EA must clearly indicate issues raised by stakeholders during consultation, and how those matters have been addressed in the EA.

Section 6,

Appendix F – Agency Responses

In addition to the above, the EA must include the general requirements for projects under Part 3A of the EP&A Act, as outlined in Table 6-2 below.

Table 6-2: Statutory Requirements for EA (Including EP&A Regulation Clause 51 Matters)

Requirement Reference in EA

• Executive Summary Executive Summary

• Description of the proposal, including construction, operation and staging

Section 5

• Details of the location of the project and environmental planning provisions applicable to the site and the project

Section 2 and Section 3

• Consideration of Alternatives Section 4

• An assessment of the environmental impacts of the project, with particular focus on the key assessment requirements specified below

Sections 8 and 9

• Proposed mitigation/ management measures of residual environmental impacts

Section 11

• Justification for undertaking the project with consideration of the benefits/ impacts of the proposal, and proposed management/ mitigation

Section 12

• A draft Statement of Commitments for environmental mitigation, management and monitoring for the project

Section 10

• Certification by the author of the Environmental Assessment that the information contained in the Assessment is neither false nor misleading

Certificate at front of EA



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6.2 Consultation with Stakeholders and Other Relevant Authorities

The communication and consultation process during the EA phase has been led by Orica with support from Thiess Services. Given the nature of the remediation project proposed, the issues it will involve and the potential for community interest and concern, an “open engagement” communication and consultation process has been maintained for the diverse range of stakeholders. The primary objectives of the consultation process have been to:

• Create stakeholder awareness of the proposal to remediate the Orica Villawood site

• Assist stakeholders to understand the need for the Environmental Assessment and the approvals phase

• Identify and gain an understanding of stakeholder interests and issues related to the remediation

• Incorporate stakeholder interests and issues into the Environmental Assessment

• Assist stakeholders to understand the proposed remediation process

• Create stakeholder awareness of how potential remediation impacts can be mitigated and how the environment will be monitored

The key stakeholders that have been identified and consulted about the remediation proposal are:

• Local residents

• Local industry – immediately adjacent neighbours

• Local industry – within close proximity of the site

• Local industry – those neighbours who have groundwater wells installed and/or groundwater testing conducted on their properties

• The Department of Environment, Climate Change and Water (including the NSW Office of Water)

• NSW Health (including the Sydney South West Area Health Service)

• Bankstown City Council The activities undertaken during the stakeholder consultation program, including those undertaken for the benefit of the local community, have been formally reported to the DECCW every 12 months since 2005 in compliance with the Remediation Order.



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6.2.1 Statutory and other relevant authorities

The proposed project is classed as a ‘Major Project’ as discussed in Section 1.6. As such, written comments from relevant statutory agencies were requested by DoP. In addition, Orica has consulted with the Department of Environment Climate Change and Water, Department of Health, Bankstown City Council (BCC) and the Office of Water, requesting any specific requirements for the EA or comments on the proposal. Table 6-3 below summarises the responses with the full responses provided as Appendix F to this EA.

Table 6-3: Government Agency Requirements and EA Re ference

Requirement EA Reference/Comment

Department of Environment Climate Change and Water

The DECCW provided detailed comments in respect of the project with regards to:

• Air

• Noise and Vibration

• Water

• Waste and Chemicals

• Threatened Species and Aboriginal Cultural Heritage

• Site-specific Requirements

Section 8 and 9

Air

• The EA prepared in respect of the project should:

- Identify all sources of air emissions from the development

- Provide details of the project that are essential for predicting and assessing air impacts including:

(i) the quantities and physio-chemical parameters (e.g. concentration, moisture content, bulk density, particle sizes etc) of materials to be used, transported, produced or stored;

(ii) an outline of procedures for handling, transport, production and storage; and

(iii) the management of solid, liquid and gaseous waste streams with potential for significant air impacts.

Section 8.3, Appendix H – Air Quality Assessment

- Include clear diagrams illustrating

(i) The physical layout of the plant and pollution control equipment; and

(ii) the material and air flows through the plant and any pollution control equipment, including structures or enclosures for controlling air and odour emissions.



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- Establish existing background levels of the key air pollutants in the ambient air at potentially affected sensitive receptor locations;

- Detail how background levels and emissions from other potential sources of the key air pollutants have been cumulatively assessed at sensitive receptors locations;

- Detail how fugitive emissions of potentially contaminated material will, essentially, be eliminated;

- Provide details of an appropriate odour impact assessment and detail how potentially offensive odour will be eliminated at any sensitive receptor location; and

- Provide details of trials to verify (before treating and disturbing contaminated materials) that the process will not create fugitive emissions and that point emissions will meet predicted levels.


• The EA must provide a description of existing air quality and meteorology, using existing information and site representative ambient monitoring data. This description must include the following:

- A description of the typography and surrounding land uses;

- Details of the exact locations of dwellings, schools and hospitals;

- A perspective view of the study area such as the terrain file used in dispersion;

- A description of surrounding buildings that may affect plume dispersion.


• The EA needs to include site representative data on the following meteorological parameters:

- temperature and humidity;

- rainfall, evaporation and cloud cover;

- wind speed and direction;

- atmospheric stability class;

- mixing height (the height that emissions will be ultimately missed in the atmosphere);

- katabatic air drainage; and

- air re-circulation.




February 2011 6-8


• With respect to the assessment of air quality impacts, the EA should include:

- An air quality and odour impact assessment in accordance with the requirements of the Approved Methods for Modelling and Assessment of Air Pollutants in NSW August 2005 and with regard to Assessment and Management of Odour from Stationary Sources in NSW (EPA 2001) and Technical Notes: Draft Policy: Assessment and Management of Odour from Stationary Sources in NSW (EPA 2001).

- A health risk assessment acceptable to the NSW Department of Health.

Section 8.3, Appendix H – Air Quality Assessment, Section 8.6, Appendix I - HHIA

• The EA should also:

- Identify all pollutants of concern and estimate emissions by quantity (and size for particles), source and discharge point;

- Describe the effects and significance of pollutant concentration on the environment, human health, amenity and regional ambient air quality standards or goals;

- Describe the contribution that the development will make to regional and global pollution, particularly in sensitive locations; and

- For potentially odorous emissions provide the emission rates in terms of odour units (determined by techniques compatible with EPA/DECCW procedures).

Section 8.3, Appendix H – Air Quality Assessment, Section 8.6, Appendix I - HHIA

• The EA must outline specifications of pollution control equipment (including manufacturer's performance guarantees where available) and management protocols for both point and fugitive emissions. Where possible, this should include cleaner production processes.


Noise and Vibration

• The EA must:

- Identify, assess and model all noise sources from the remediation project (including both construction and operation phases). Detail all potentially noisy activities including ancillary activities including transport; and

- Specify the times of operation for all phases of the project and for all noise producing activities.

Section 8.4, Section 9, Appendix J – Noise Assessment



February 2011 6-9


• The EA must:

- Identify any noise sensitive locations likely to be affected by activities at the project site, such as residential properties, schools, churches, and hospitals; and

- Identify the land use zoning of the site and the immediate vicinity and the potentially affected areas.


• The EA must demonstrate how the proponent will:

- Determine the existing background (LA90) and ambient industrial (LAeq) noise levels in accordance with the NSW Industrial Noise Policy, inclusive of industrial noise from surrounding area; and

- Determine the existing road traffic noise levels in accordance with the NSW Environmental Criteria for Road Traffic Noise, where road traffic noise impacts may occur.


• The noise impact assessment report should provide details of all monitoring of existing ambient noise levels including:

- Details of equipment used for the measurements;

- A brief description of where the equipment was positioned;

- A statement justifying the choice of monitoring site, including the procedure used to choose the site, having regards to the definition of 'noise sensitive location(s)' and 'most affected location(s)' described in Section 3.1.2 of the NSW Industrial Noise Policy;

- Details of the exact location of the monitoring site and a description of land uses in the surrounding areas;

- A description of the dominant and background noise sources at the site;

- Day, evening and night assessment background levels for each day of the monitoring period;

- The final RBL value;

- Graphs of the measured noise levels for each day should be provided;

- A record of periods of affected data (due to adverse weather and extraneous noise), methods used to exclude invalid data and a statement indicating the need for any re-monitoring under Step 1 in Section 81.3 of the NSW Industrial Noise Policy; and

- Determination of LAeq noise levels from existing industry.




February 2011 6-10


• The EA must demonstrate how the Proponent will:

- Determine the INP project specific noise levels for the site. For each identified potentially affected receiver, this should include:

- Determine the intrusive criterion for each identified potentially affected receiver; selection and justification of the appropriate amenity category for each identified potentially affected receiver;

- Determine the amenity criterion for each receiver; and determination of the appropriate sleep disturbance limit.

- Determine expected noise level and noise character (e.g.: tonality, impulsiveness, vibration, etc) likely to be generated from noise sources during

(i) site establishment;

(ii) construction;

(iii) operational phases;

(iv) transport including traffic noise generated by the proposal; and

(v) other services.


• The EA must demonstrate how the Proponent will determine the noise &vibration levels likely to be received at the most sensitive locations (these may vary for different activities at each phase of the development).


• Potential vibration impacts should be assessed using the DECCW guideline titled: "Environmental Noise Management - Assessing Vibration: a technical guideline"




February 2011 6-11


• The noise impact assessment report should include:

- A plan showing the assumed location of each noise source for each prediction scenario;

- A list of the number and type of noise sources used in each prediction scenario to simulate all potential significant operating conditions on the site;

- Any assumptions made in the predictions in terms of source heights, directivity effects, shielding from topography, buildings or barriers, etc;

- Methods used to predict noise impacts including identification of any noise models used. Where modelling approaches other than the use of the ENM or Soundplan computer models are adopted, the approach should be appropriately justified and validated;

- An assessment of appropriate weather conditions for the noise predictions including references to any weather data used to justify the assumed conditions;

- The predicted noise impacts from each noise source as well as the combined noise level for each prediction scenario under any identified significant adverse weather conditions as well as calm conditions where appropriate;

- For developments where a significant level of noise impact is likely to occur, noise contours for the key prediction scenarios should be derived; and

- An assessment of the need to include modification factors as detailed in Section 4 of the NSW Industrial Noise Policy.


• The noise impact assessment report should discuss the findings from the predictive modelling and, where relevant noise criteria have not been met, recommend additional mitigation measures; and should include details of any mitigation proposed including the attenuation that will be achieved and the revised noise impact predictions following mitigation.




February 2011 6-12


• Where relevant noise/vibration criteria cannot be met after application of all feasible and reasonable mitigation measures the residual level of noise impact needs to be quantified by identifying:

- locations where the noise level exceeds the criteria and extent of exceedance;

- numbers of people (or areas) affected;

- times when criteria will be exceeded;

- likely impact on activities (speech, sleep, relaxation, listening, etc);

- change on ambient conditions; and

- the result of any community consultation or negotiated agreement.


• For the assessment of existing and future traffic noise, details of data for the road should be included such as assumed traffic volume; percentage heavy vehicles by time of day; and details of the calculation process. These details should be consistent with any traffic study carried out in the EA. Alternatively, measured noise levels can be used provided the traffic volume during the period of measurement is demonstrated to be typical of normal volumes etc.


• The EA must demonstrate how the Proponent will determine the most appropriate noise mitigation measures and expected noise reduction including noise controls and management of impacts for both construction and operational noise. This will include selecting quiet equipment and construction methods, noise barriers or acoustic screens, location of stockpiles, temporary offices, compounds and vehicle routes, scheduling of activities, etc.


Water

• The DECCW is concerned about groundwater contamination which may arise once the encapsulation is disturbed. The EA needs to address:

- An accurate representation on the extent of the extent and nature of the plumes underneath the Site;

- How groundwater in the surrounding area will be monitored;

- Details of any contaminated soil management arrangements; and

- Details of the installation, operation and maintenance of the sediment and erosion controls associated with the construction works.

Section 8.2, Appendix D – RAP

Appendix O – Groundwater Monitoring Program

Note: The proposed remediation project does not involve remediation of groundwater.



February 2011 6-13


• A detailed Surface Water Management Plan must be developed that includes:

- Details of erosion and sediment controls to be used during excavation, stockpiling and backfilling;

- Details of how “clean” areas will be separated from contaminated areas ;and

- Details of how contaminated water will be treated and its final disposal location.


Note: The proposed remediation project does not involve remediation of groundwater.

Waste and Chemicals

• The EA must demonstrate how the Proponent will manage all materials and wastes containing scheduled chemical waste, dioxin and/or polychlorinated biphenyls (PCBs) in accordance with the applicable Chemical Control Order. National Management Plan or in accordance with a licence under the Environmentally Hazardous Chemicals Act 1985.

Section 2, Section 5.10, Appendix D – RAP

• Prior to the issue of any variation of the existing Environmental Protection Licence and Environmentally Hazardous Chemicals Act Licence to permit the proposed works, the proponent must provide the EPA with sufficient and appropriate documentation for a technology assessment to be undertaken by the EPA, in accordance with the following:

- 'National Protocol – Approval/Licensing of Trials of Technologies for the TreatmentlDisposal of Schedule X Wastes -July 1994'; and

- 'National Protocol for Approval/Licensing of Commercial Scale Facilities for the Treatment/Disposal of Schedule X Wastes -July 1994'.

To be submitted separate to this EA

• Within the technology assessment application, the applicant must develop a Commissioning and Proof of Performance Program (CPoP) to demonstrate the technology's capability to meet best practice emission and treatment levels. The CPoP must include the proposed staging of treatment consistent with the requirements of the 'National Protocols'. Consideration should also be given to the Basel General technical guidelines for the environmentally sound management of wastes consisting of, containing or contaminated with persistent organic pollutants (POPs) and Stockholm BAT BEP guidance.

To be submitted separate to this EA



February 2011 6-14


• The EA must demonstrate how the Proponent will:

- Process all Scheduled Chemical Waste, dioxin waste and/or Polychlorinated Biphenyls Waste (PCBs), and any wastes generated by the treatment process until the materials wastes meet:

(i) a statistical average dioxin, furan and dioxin like PCB WHO-TEQ of less than 1 uglkg-' (1 000 ppt) determined with a methodology acceptable to the EPA;

(ii) an aggregate concentration of scheduled chemical waste constituents of less than 2mglkg;

(iii) a polychlorinated biphenyl concentration of less than 2mglkg;

(iv) the requirements that apply in accordance with the Hexachlorobenzene Waste Management 1996; and

(v) best practice limits as demonstrated within the Commissioning and Proof of Performance Program for other principal contaminants of concern.

Section 5,

Appendix D – RAP,

Appendix E – Regulatory Compliance

• The EA must demonstrate that excavation, handling, pre-treatment, storage and other activities involving materials and wastes containing scheduled chemical waste, dioxin, polychlorinated biphenyls (PCBs) and other principal contaminants of concern will be conducted in accordance with best practice measures to minimise loss to the environment, exposure to humans and maximise destruction through the proposed treatment plant. The applicant should present within the Environment Assessment how this will be achieved and in addition to the NSW statutory requirements should consider the USEPA Best Management Practices (BMPs) for Soils Treatment Technologies - Suggested Operational Guidelines to Prevent Cross-Media Transfer of Contaminants During Cleanup Activities - EPA530-R-97-007. The DECWC can provide the proponent with all the application forms, protocols and guidelines covered in relation to the EHC Act and technology assessment.

Section 5, Appendix D – RAP

• The EA needs to include risk assessment details covering exposure by inhalation and ingestion of contaminated soil if there is to be any loss of dust from the site during the rehabilitation process. However, the risk assessment should focus on inhalation of possibly higher air concentrations than those existing at present, because of opening the encapsulation.

Section 8.6, Appendix I – HHIA, Appendix K - PHA



February 2011 6-15


Other Waste

• For any waste that is not suitable for treatment in the DTD Plant, but requires disposal off-site, the EA must:

- Identify and characterise the waste;

- Propose quantities of waste; and

- Disposal location for waste.


• For waste leaving the site, the EA must outline:

- How waste will be handled and managed onsite and during transport;

- How waste will be treated or immobilised to render it suitable for transport and disposal;

- Detail the material tracking requirements; and

- All procedures and protocols to be implemented to show how material leaving site does not pose a risk to human health or the environment.


Impact on Threatened Species and their habitat

• The DECCW acknowledges that the site is highly disturbed and therefore the presence of threatened species is unlikely. Nonetheless, the EA should, if applicable, include a brief field survey of the site. If any TS are identified then likely impacts on threatened species and their habitat need to be assessed, evaluated and reported on. The EA must describe the actions that will be taken to avoid or mitigate impacts or compensate for unavoidable impacts of the project on threatened species and their habitat. This should include an assessment of the effectiveness and reliability of the measures and any residual impacts after these measures are implemented.

Section 9.4, Appendix M – Bushland Management Plan

Impacts on Aboriginal cultural heritage values

• The DECCW acknowledges that the site is highly disturbed and therefore the presence of Aboriginal cultural heritage artefacts is unlikely. Nonetheless, the EA should if applicable:

- Address and document the information requirements set out in the draft Guidelines for Aboriginal Cultural Heritage Impact Assessment and Community Consultation involving surveys and consultation with the Aboriginal community;

- Identify the nature and extent of impacts on Aboriginal cultural heritage values across the project area;

Section 9.4, Appendix N – Aboriginal Cultural Assessment



February 2011 6-16


- Describe the actions that will be taken to avoid or mitigate impacts or compensate to prevent unavoidable impacts of the project on Aboriginal cultural heritage values. This should include an assessment of the effectiveness and reliability of the measures and any residual impacts after these measures are implemented; and

- Demonstrate that effective community consultation with Aboriginal communities has been undertaken in determining and assessing impacts, developing options and making final recommendations.

Section 9.4, Appendix N – Aboriginal Cultural Assessment

Site Specific Requirements

Excavation works

• The EA must specifically state whether excavation of material will be wholly completed within a building or out in the open.

• For excavation works in buildings, the EA must detail:

- Size and specifications of the building;

- Mitigation measures associated with the building to address air quality, noise and odour emissions; and

- Details of how the building will be relocated around the site to different excavation areas.


• Provide details for how excavations out in the open will be managed to control dust, noise and odour emissions.


Stockpile Management

• The EA must specifically state whether excavation of material will be wholly completed within a building or out in the open.

• For excavation works in buildings, the EA must detail:

- Size and specifications of the building;

- Mitigation measures associated with the building to address air quality, noise and odour emissions; and

- Details of how the building will be relocated around the site to different excavation areas.

• Provide details for how excavations out in the open will be managed to control dust, noise and odour emissions.


Hazards

• The EA must include a Preliminary Hazard Analysis of the treatment facility including a detailed assessment of the potential off-site risks.

Section 8.5, Appendix K – PHA



February 2011 6-17


Visual

• The EA must include an assessment of the visual impact of the treatment facility on the local and regional area.

Section 9.2, Appendix L – Visual Assessment

Sampling

• The EA must include details of sampling methodology to ensure appropriate characterisation of site areas, handling and management and frequency and timeframes for sampling.

Appendix D – RAP

Contingency Plans

• The EA must outline contingency plans for any event that affects contaminated soil treatment operations at the site, particularly in relation to the DTD Plant.

Sections 5 and 8.5,

Appendix D – RAP, Appendix K – PHA

Traffic

• The EA must consider the impacts of extra traffic and truck movement as a result of the project, including details on quantity of traffic generated, transport routes, traffic management procedures and safety impacts on other road users.


Department of Health

• It is unknown whether a human health and environmental risk assessment was finalised with the Department of Environment, Climate Change and Water (DECCW).

Section 8, Appendix H – Air Quality Assessment Appendix I – HHIA

• Offsite migration monitoring may need to be longer than 5 years because some plumes extend quite a distance off site.

Appendix D – RAP

• Soil investigation levels are not available for all contaminants of potential concern identified on site. A health risk assessment approach was used to determine suitable criteria for these chemicals and level of remediation for the proposed future use of the site. This assessment is apparently detailed in the risk assessment process document RAP (HLA, 2009), The Public Health Unit has not seen this document.

Appendix D – RAP

• At community consultation meetings, some long term residents had concerns about potential impact on their health following past practices on the Orica site. They also had concerns about noise, odour and emissions from site and potential impacts on their health. The community consultation so far has been an effective method of providing information and allowing an opportunity for the community to raise concerns. We would suggest that community consultation continue through the remediation project as per the model followed in Rhodes.

Section 6, Appendix F – Agency Responses



February 2011 6-18


• Persons most likely to be affected by remediation works (sensitive receptors) would include: (1) the residents, with the closest being about 100

metres away; (2) various businesses that border the site; (3) the boundary of the immigration detention centre

within about 150 metres; (4) the Independent Motor Auctions would have the

general public and car buyers wandering around their site on auction days; and

(5) the high school over 400 metres away.

• The proposed health risk assessment for the on−site workers should be extended to also cover the potential impact and health risks to residents, and workers in surrounding businesses and school for likely exposures to contaminants emanating from the site during the remediation work.

Section 8, Appendix D – RAP, Appendix H – Air Quality Assessment Appendix I – HHIA, Appendix K – PHA

• Control measures during remediation should include a monitoring program to measure potential levels of dusts and odours that emanate from the site during remediation. If certain threshold levels (alert levels) of particulates, volatiles or other pollutants at the site boundary are exceeded there should be agreed actions that follow. On−site monitoring including alert levels could be similar to those used for the Rhodes remediation site.

Section 5, Section 8.3, Section 8.5, Section 8.6, Appendix D – RAP, Appendix H – Air Quality Assessment Appendix I – HHIA, Appendix K – PHA

• Monitoring should also extend to surface waters and runoff to ensure that no contaminated waters leave the site untreated.


• The prioritisation of potential environmental issues seems reasonable.


• Offsite residuals from past munitions and paint factories on what has been residential land for many decades needs to be discussed with DECCW and Bankstown Council.


Bankstown City Council

• Description of the remediation techniques to be used, and a clear statement of the remediation standard being adopted for the site, the future uses that will be suitable when the remediation is complete;

Section 5 , Appendix D – RAP

• A peer review of the proposed remediation techniques by an accredited site auditor, and an assessment of their adequacy and a confirmation that the site will be suitable for the intended use when the remediation has been completed;


• Proposals to validate that the remediation has been completed to the proposed standard;




February 2011 6-19


• Proposals to manage the migration of contaminants during the remediation process, including both the dispersal of contaminants through the air and the groundwater;

Sections 5 and 8.2

• Proposals to manage the stockpiles of contaminated material in the event of a flood event, or during heavy rain. This should be considered with reference to the Villawood Catchment Flood Study that has recently been adopted by Bankstown Council;

Sections 5

• Identification of any sensitive land uses in the vicinity of the site and which could be impacted on by the decontamination works, and proposals to manage any impacts (e.g. is it necessary to advise uses such as schools, child care centres etc to stay indoors on windy days);

Section 9.6

• A risk assessment of the proposed remediation works, including a consideration of potentially hazardous events (fire, explosion or release of toxic substances). This should be carried out in accordance with the Department of Planning's Guidelines, and should include a risk assessment and recommendations to minimise risk;

Section 8.3, Section 8.5, Section 8.6, Appendix D – RAP, Appendix H – Air Quality Assessment Appendix I – HHIA, Appendix K – PHA

• Impact of the proposal on items of ecological value, including the impact on any nearby threatened species or endangered ecological communities;

Section 9.4

• Impact of the proposal on any buildings of the site that have heritage value;

Section 9.5

• Noise impacts associated with the proposal and proposed mitigation measures;

Section 5, Section 8.4, Appendix J – Noise Assessment

• Traffic impacts of the proposal, and proposed mitigation measures (if necessary);

Section 9.3

• Air quality impacts, and proposed mitigation measures. This should include proposals to manage the stockpiles of contaminated material in the event of a very windy day;

Section 8.3, Section 8.6, Appendix H – Air Quality Assessment Appendix I – HHIA

• Acoustic/Noise Assessment – particularly with relation to the operation of the treatment plant, movement of vehicles at night during plant operation and weekend excavation activities;




February 2011 6-20


• Water Management Plan – for management of contaminated surface water to prevent off-site runoff (including onsite management of potential flooding); and

Section 5 and Section 8.2

• Soil Management Plan – for management of contaminated soil during treatment works to prevent offsite movement and tracking of material from hotspots to other parts of the site.

Section 5 and Section 8.1

Office of Water

• The EA needs to provide adequate details to assess the impact of the proposal on surface water and groundwater resources.


• Sufficient detail needs to be provided for the NOW to assess any water licensing requirements under the Water Act 1912, the EA needs to provide details on:

- the water supply source(s) for the proposal

- any proposed surface water extraction for the proposal, including purpose, location of any existing and proposed pumps, dams,

- any proposed groundwater extraction related to the project,

- volumes of water to be used

- the function and location of all existing and proposed storages/ponds on the site,

- the design, layout, pumping and storage capacities, all associated earthworks and infrastructure works must be clearly shown and explained.

Section 2.2.7

Groundwater

• The NOW is responsible for the management of the groundwater resources. The proposal needs to protect groundwater resources in accordance with NSW State groundwater policy, enhance groundwater quality and protect groundwater dependent ecosystems (GDEs).

Section 2, Section 8.2, Appendix D – RAP


It is noted that this EA is not subject to groundwater remediation



February 2011 6-21


• The EA should identify groundwater issues and potential degradation to the groundwater source and provide the following details:

- the predicted highest groundwater table at the site. - any works likely to intercept, connect with or infiltrate

the groundwater sources. - any proposed groundwater extraction, including

purpose, location and construction details of all proposed bores and expected annual extraction

Section 8.2, Appendix D – RAP Appendix O – Groundwater Monitoring Program


- volumes. - a description of the flow directions and rates and

physical and chemical characteristics of the groundwater source.

- the predicted impacts of any final landform on the groundwater regime.

- the existing groundwater users within the area (including the environment), any potential impacts on these users and safeguard measures to mitigate impacts.

- an assessment of the quality of the groundwater for the local groundwater catchment.

- an assessment of groundwater contamination (considering both the impacts of the proposal on groundwater contamination and the impacts of contamination on the proposal).

- how the proposed development will not potentially diminish the current quality of groundwater, both in the short and long term.

- measures for preventing groundwater pollution so that remediation is not required.

- protective measures for any groundwater dependent ecosystems (GDEs).

- proposed methods of the disposal of waste water and approval from the relevant authority.

- the results of any models or predictive tools used.



• Where potential impact/s are identified the assessment will need to identify limits to the level of impact and contingency measures that would remediate, reduce or manage potential impacts to the existing groundwater resource and any dependent groundwater environment or water users, including information on:

- any proposed monitoring programs, including water levels and quality data

- reporting procedures for any monitoring program including mechanism for transfer of information

Section 2, Section 8.2,

Appendix D – RAP




February 2011 6-22


- an assessment of any groundwater source/aquifer that may be sterilised from future use as a water supply as a consequence of the proposal.

- identification of any nominal thresholds as to the level of impact beyond which remedial measures or contingency plans would be initiated (this may entail water level triggers or a beneficial use category).

- description of the remedial measures or contingency plans proposed.

- any funding assurances covering the anticipated post development maintenance cost, for example ongoing groundwater monitoring for the nominated period.


Licensing

• Section 3.4.4 of the PEA notes a licence under Part 5 of the Water Act 1912 will be required to authorise the short and medium term groundwater monitoring bores. If the proposal is likely to intercept or use groundwater, the need for a water license should be addressed.

Section 2.2.7

• All proposed groundwater works, including bores for the purpose of investigation, extraction, dewatering, testing or monitoring must be identified in the proposal and an approval obtained from NOW prior to their installation.

Appendix D – RAP

Groundwater Dependent Ecosystems

• The EA should provide details on the presence and distribution of GDEs in the vicinity of the site and identify any potential impacts on GDEs as a result of the proposal.

Appendix D – RAP

• GDEs are ecosystems which have their species composition and natural ecological processes wholly or partially determined by groundwater. GDEs represent a vital component of the natural environment and can vary in how they depend on groundwater, from having occasional or no apparent dependence through to being entirely dependent. GDEs occur across both the surface and subsurface landscapes ranging in area from a few metres to many kilometres. Surface and groundwater are often interlinked and aquatic ecosystems may have a dependence on both.

Appendix D – RAP

• Ecosystems that can depend on groundwater and that may support threatened or endangered species, communities and populations, include:

- Terrestrial vegetation that show seasonal or episodic reliance on groundwater.

Appendix D – RAP



February 2011 6-23


- River base flow systems which are aquatic and riparian ecosystems in or adjacent to streams/rivers dependent on the input of groundwater to base flows.

- Aquifer and cave ecosystems.

- Wetlands

- Estuarine and near-shore marine discharge ecosystems.

- Fauna which directly depend on groundwater as a source of drinking water or live within water which provide a source.

6.2.2 Community Consultation

Orica has maintained an open dialog with the diverse sectors of the local community through newsletters, advertisements, “doorknock” visits, meetings and a constant site presence since their operations at Villawood ceased in 2000. During the EA, Orica and Thiess Services have continued to use the same broad range of communication tools for the consultation process. With an approach that has allowed communication at an individual level as well as at a group level, a variety of community views have been gathered and used to inform the EA.

6.2.2.1 Newsletter Distribution

Four newsletters have been distributed throughout the local area since 2005 with the latest being issued in July 2009. This four-page, full-colour newsletter provided information about the history and land use of the site, soil and groundwater contamination, the human health and environmental risk assessment, the Remediation Action Plan and the community meeting scheduled for the following month (Appendix F ). The newsletter also featured an aerial photographic map that depicted the areas of soil to be treated and the extent of the groundwater contamination. The newsletter was distributed to 2,500 households, businesses and other stakeholders.

6.2.2.2 Direct Contact

The Orica Villawood Site Manager has been instrumental in maintaining communication with local residents and businesses over a number of years. During face-to-face “doorknock” visits, newsletters and information kits have been distributed regularly. For the owners of properties where groundwater monitoring takes place, ongoing telephone contact, letterbox drops and personal visits have kept them informed of the latest test results. The invitation to the December 2009 community meeting was personally delivered by the Site Manager to more than 50 local businesses located in close proximity to the site.



February 2011 6-24

6.2.2.3 Community Meetings

With the support of Thiess Services, community meetings were held on 6 August and 16 December 2009 and 14 September 2010 to discuss Orica’s plans for remediating the site and the DoP process that was required to be followed before the remediation would be allowed. Approximately 2,300 businesses and residences were invited to each of the community information sessions. The invitation to the August 2009 session was incorporated into the July 2009 community newsletter. Letters of invitation were distributed to letterboxes for the December 2009 and September 2010 sessions. Further meetings are planned during and after the public exhibition of the Development Application. Participants in the three community meetings held to date during the EA have included:

• Local residents • Local industry representatives • The Department of Environment, Climate Change and Water • NSW Health (Sydney South West Area Health Service) • Bankstown City Council (including the North Ward Councillor) • Consultants engaged by Orica and Thiess Services

At the meetings, information has been provided about the:

• Site history and need for remediation; • Approvals process; • Environmental assessment studies; • Remediation schedule and key dates; • Proposed remediation method; • Potential impacts and their management; • Thermal treatment process; • Future plans for the remediated site.

The main issues raised by the community at these meetings have related to the:

• Approvals process - Part 3A was perceived to be undesirable because it did not allow the community appeal rights;

• Involvement of local government (BCC) and state government agencies – involvement by the DECCW in particular was perceived to be important;

• Duration of the remediation work, which was predicted to be 12 to 18 months; • Nature of potential impacts from the remediation work; • Potential for impacts to human health by emissions from the thermal treatment

plant; • Potential for contamination of surrounding residential areas by the remediation

work; • Potential for contamination of groundwater during the remediation work; • Monitoring of offsite impacts during the remediation work; • Timely and accessible reporting of environmental monitoring results; • Treatment of contaminated concrete on the site.

In addition, there was a high level of concern expressed about the potential existence of buried contaminated wastes in adjacent residential areas due to former industrial landuse by the Department of Defence and Taubmans Paints. It was recognised that these were not related to the use of land by Orica or the current remediation proposal and the matter was referred to the Department of Health representative who was present at the December 2009 meeting.



February 2011 6-25

A report about the community information session held in December 2009 was sent to more than 100 local residents, business representatives and other stakeholders who had registered their interest in the proposed remediation project. The mailout also confirmed another community information session would be held prior to the public exhibition of the EA, which occurred in September 2010. Both community meeting reports have been included in Appendix F . Issues raised by the community are considered further in the prioritisation of issues outlined in Sections 8 and 9 of the EA. Discussion with Industrial Neighbours The Orica Villawood Site Manager has been instrumental in maintaining communication with the industrial neighbours over a number of years. Through face-to-face “doorknock” visits, all industrial neighbours on Christina Rd and those adjoining the site on Miller Rd, Epic Place and Birmingham Avenue have been consulted. Their primary concerns relate to when the Site may become available for sale (i.e., potential for having extra customers and/or purchasing the land). On-going consultation will continue as detailed in Section 6.3 .

6.2.2.4 Agency Meetings and Consultation

Department of Planning The main submission to DoP to date is the Environmental Assessment Scoping Report (EASR), dated February 2010, which was submitted to the DoP with the Preliminary Project Application. This EASR formed the basis of the Director-General’s EARs detailed in Section 6.1.1 above. Department of Environment Climate Change and Water Consultation with the DECCW prior to and during the EA is described below along with the issues they have raised in relation to the EA. Key correspondence and meeting reports have been included in Appendix F . 2005

• Liaison and reporting on Remediation Order (RO). • Project briefing session held 7 December 2004 and 24 August 2005, including a

site tour.

2006 • Phase 1 Remedial Investigation Report issued 21 December 2005. • Liaison and reporting on Remediation Order (RO) progress. • Human Health and Environmental Risk Assessment (HHERA) workshop held 6

July 2006. • Phase 2 Remedial Investigation Report issued 31 August 2006. • Project briefing session held 21 September 2006, including a site tour.

2007

• Phase 3 Data Gap Investigation Report issued in April 2007. • Liaison and reporting on Remediation Order (RO) progress. • Human Health and Environmental Risk Assessment (HHERA) issued on 22 June

2007. • Draft Remediation Action Plan (RAP) issued on 23 July 2007. • Project briefing session held on 30 August 2007, including a site tour.



February 2011 6-26

2008 • Comments on Remediation Action Plan (RAP) received from DECC on 3

September 2008. • Comments on Human Health and Environmental Risk Assessment (HHERA)

received on 7 October 2008. 2009

• Representatives attended the community information sessions on 6 August and 16 December 2009.

2010

• Meeting to clarify EA requirements on 25 May 2010 (DECCW, Thiess Services and PAE-Holmes).

• Meeting held 26 August 2010 at DECCW to provide an overview of the Environmental Assessment for the proposed project.

• Representatives attended the community information session on 14 September 2010.

Issues Raised: Air

• A comprehensive assessment of air quality impacts from materials handling activities at the site be conducted that includes: o all chemicals of concern o a worst case assessment of impacts which considers the spatial distribution

of contaminated soil o the use of best practice management techniques

• The air quality assessment take into consideration cumulative impacts should surrounding operations offsite be producing air emissions.

• A full odour impact assessment be conducted that uses odour sampling results. • Ambient air quality monitoring be conducted for the duration of the project. • Controls to minimise regional contributions of criteria air pollutants as well as those

minimising global contributions of Stockholm Treaty chemicals be outlined. • A description of the CPoP to be provided.

Department of Health Consultation with NSW Health prior to and during the EA is described below along with the issues they have raised in relation to the EA. Key correspondence and meeting reports have been included in Appendix F . 2005

• Project briefing session held 7 December 2004 and 24 August 2005, including a site tour.

• Update on RO. • Liaison regarding HHERA.

2006

• HHERA workshop held 6 July 2006. • HHERA issued 31 August 2006. • Project briefing session held 21 September 2006, including a site tour. • Update on RO progress.



February 2011 6-27

2007 • HHERA issued on 22 June 2007. • Project briefing session held on 30 August 2007, including a site tour. • Update on RO progress.

2008

• No comments received on Human Health and Environmental Risk Assessment (HHERA) issued in June 2007.

2009

• Representatives attended the community information session on 16 December 2009.

2010

• Meeting held 7 September 2010 at NSW Health to provide an overview of the Environmental Assessment for the proposed project.


Office of Water Several attempts have been made to consult with the Office of Water (NOW) throughout 2010 regarding the EA. To date, it has been confirmed that NOW has received the updated Remedial Action Plan, but no additional comments or concerns have been raised. Key correspondence has been included in Appendix F . Bankstown City Council Consultation with Bankstown City Council prior to and during the EA is described below along with the issues they have raised in relation to the EA. Key correspondence and meeting reports have been included in Appendix F . 2005

• Project briefing session held 7 December 2004 and 24 August 2005, including a site tour.

• Updates on progress and consultation via email/phone/documents. • Liaison regarding groundwater well locations and approval regarding road opening.

2006

• Project briefing session held 21 September 2006, including a site tour. • Copies of investigation results and letters sent to off-site landowners.

2007

• Update on RO progress. • Meeting in March 2007 (with Department of Planning) to advise of intended

approach for divestment of the site • Copies of investigation results and letters sent to off-site landowners • HHERA issued on 22 June 2007 • Project briefing session held on 30 August 2007, including a site tour



February 2011 6-28

2008 • Copy of Community Newsletter outlining plans to transport and store contaminated

material from Chester Hill Site to Villawood Site distributed to BCC on 20 August 2008;

• Meeting held 17 October 2008 at Chester Hill Site to discuss plans to transport and store contaminated soil from Chester Hill Site on Villawood Site;

• Progress of works between Chester Hill and Villawood Sites communicated regularly to BCC in October/November 2008.

2009

• Representatives attended the community information sessions on 6 August and 16 December 2009.

2010

• Meeting held 7 September 2010 at BCC to provide an overview of the Environmental Assessment for the proposed project.


Issues Raised:

• Council’s ability to have input on the project. • The remediation standard.

6.3 Ongoing Consultation

Orica is committed to continuing the consultation process with stakeholders while the EA is being reviewed and a determination made. All interests and issues raised by stakeholders will be documented, discussed or responded to, and used to further inform the proposed project. It is understood that the DoP will advertise the public exhibition of this EA. Prior to/during the exhibition period, Orica plans to:

• Maintain/update the interested stakeholder database; • Distribute the report of the 14 September 2010 community information session to

all stakeholders who have registered their interest in the project; • Distribute another newsletter to the community advising of the EA exhibition and

providing a summary/overview on the EA; and • Hold another community information session to respond to any queries people may

have about the EA; Orica intends to expand the current community consultation process if the remediation project is approved. Under this scenario, use of the following communication tools will be continued or implemented:

• Regular community information sessions to provide project progress updates; • Written information distribution via letterbox drops and e-mail including community

newsletters, fact sheets and notifications; • Individual stakeholder consultations and special group presentations; • Advertising in local media; • Media briefings including the provision of proactive releases or “backgrounders”;

and • Site tours with key project team members.



February 2011 6-29

The implementation of the following communication tools will also be considered:

• A toll-free community contact telephone number to facilitate the handling of complaints and enquiries;

• The distribution of personalised response letters to community members and stakeholders who e-mail or call the toll-free community contact line; and

• Reporting to measure and evaluate the effectiveness of the strategies in place.



February 2011 7-1

7 ISSUES PRIORITISATION

7.1 Issues Identification

As identified in proceeding sections, the list of issues associated with the project includes:

• Soils • Water • Air quality • Hazard and risk • Noise and vibration • Visual amenity • Flora and fauna • Heritage • Land use • Transport and traffic • Social and economic.

7.2 Prioritisation of Issues

The prioritisation of issues for the proposed project recognises that the higher the potential severity of adverse environmental effects and the greater the consequence of unmanaged effects, the higher the degree of assessment required. The table below shows the Issues Prioritisation Matrix used to prioritise potential issues. The potential severity and consequence of environmental effects are given numerical values from 1 and 3. The numbers are then added to provide a result which is ranked and shaded by potential risk level being High, Medium or Low. Consequence of Unmanaged Effects Severity of Effects 1 Low 2 Medium 3 High 1 Low 2 Low 3 Low 4 Medium 2 Medium 3 Low 4 Medium 5 High 3 High 4 Medium 5 High 6 High

7.3 Initial Assessment

The prioritisation of environmental issues related to the proposed project is shown in the table below. The assessment aims to allow for prioritisation of issues without allowing for mitigation measures to manage them. In all cases appropriate and proven mitigation measures would be used to minimise potential impacts based on experience with similar projects. These measures will be detailed in the EA. In some cases operation is split into excavation and treatment to differentiate risks applying to each. In other cases commissioning and operation are lumped into project where the prioritisation is the same across all aspects.



February 2011 7-2

Issue Severity Consequence Priority Aspect: Soil Erosion and sedimentation - excavation 1 2 3 Spread of contaminants - excavation 2 2 4 Aspect: Water Surface water degradation – construction 1 1 2 Surface water degradation – excavation 2 2 4 Surface water degradation – treatment 2 1 3 Groundwater degradation – project 1 1 2 Aspect: Air Quality Air quality degradation - construction 1 1 2 Air quality degradation - excavation 3 3 6 Air quality degradation - treatment 3 2 5 Aspect: Hazard and Risk Exposure of offsite population 2 2 4 Exposure of onsite workers 3 3 6 Aspect: Noise and Vibration Temporary noise – construction 1 2 3 Ongoing noise - operation 2 3 5 Aspect : Visual Temporary visual impact - operation 1 1 2 Temporary night lighting - operation 1 2 3 Aspect: Ecological Loss of habitat and biodiversity 1 1 2 Impact on threatened species 1 1 2 Aspect: Resource Use Community, transport resources 1 1 2 Natural resources (gas, water, power) 2 1 3 Aspect: Socio-Economic Impacts on surrounding amenity 1 2 3 Job creation 1 1 2 Aspect: Heritage Damage / removal of aboriginal heritage 1 1 2 Damage / removal of non-aboriginal heritage 1 1 2 Aspect: Land Use Inappropriate use of land 1 1 2 Incompatible land use 1 1 2 Aspect: Transport and Traffic Increase in local traffic – construction 2 1 3 Increase in local traffic – operation 1 1 2



February 2011 7-3

7.4 Community Views

Two community meetings have been held in the lead up to the PEA submission, as well as letter box drops of newsletters, advertising in local newspapers and personal contact with surrounding premises. A final community meeting was held in September 2010 to introduce the EA process and the next steps moving forward. One area of concern for the local residential community related to residual contamination on adjacent residential areas due to past industrial uses, particularly the operation of munitions and paint factories in the past, and a legacy of buried wastes. The concerns centred on possible health effects due to buried contamination. It should be noted that these concerns while raised in the context of the proposed remediation project are outside the scope of the project. They are noted here for completeness and have been referred to the Department of Health who were at the consultation meetings. The main concerns to do with the proposed remediation project were offsite soil contamination, air quality, noise and onsite groundwater contamination. A ranking of community issues based on meetings to date is shown below: High

• Offsite soil contamination • Air Quality • Risk and hazard

Medium

• Noise • Onsite groundwater • Onsite soil • Surface water • Landuse • Traffic

Low

• Visual Amenity • Ecology • Resources • Heritage • Economic



February 2011 7-4

7.5 Final Assessment

The final assessment was made by combining the initial assessment and community views. The combined list of high priority issues is shown below.

Issue Severity Consequence Priority Aspect: Air Quality Air quality degradation - excavation 3 3 6 Air quality degradation - treatment 3 2 5 Aspect: Soil Contamination of offsite soil by air emissions 2 3 5 Aspect: Noise and Vibration Ongoing noise - operation 2 3 5 Aspect: Hazard and Risk Exposure of offsite population 3 2 5 Exposure of onsite workers 3 3 6

Of the high priority issues, exposure of onsite workers would be managed by preparation of an Occupational Health and Safety Plan as part of a wider suite of site management plans prior to mobilising to site.



February 2011 8-1

8 ASSESSMENT OF KEY ENVIRONMENTAL IMPACTS

8.1 Soil

8.1.1 Existing Environment

The Site lies is located on the Cumberland Plain of the Sydney Basin and slopes from the northeast corner (36 m AHD) towards the south-west corner (18.5 m AHD).The Site geology comprises fill material, overlying residual clay soil, overlying the basal Bringelly Shale. The fill material is mainly reworked clay from onsite. The local clay is mottled orange/grey, moist and of moderate to high plasticity. Highly weathered and fractured shale, is present at depths of greater than 1 m. Details are contained in the RAP (AECOM 2010). Orica divided the site into nine areas (A to I) based on the location of historical activities. Areas A and C in the southwest of the site have been previously remediated and validated and are not subject of this proposal. AECOM then developed investigation levels for CoCs across the entire site. Comparing these with the site investigation results, they identified six Impacted Soil Zones (ISZs), across Areas B and D to I (ISZ 1a and b, ISZs 2, 5, 7, 8 and 9), where chemical concentrations in soil was considered to pose a potential risk for human health or the environment. Subsequently ISZs 1a, 2 and 8 were combined. ISZ 3 is not a remediation zone because concentrations in it are below the soil RBSWC. Figure 10 shows the location and approximate boundaries of the ISZs. Further details are contained in the RAP (Appendix D ). Other contaminated or potentially contaminated soil on the site comprises:

• Backfill around trade waste lines;

• Previously excavated soil from Areas A and C, now in the Secure Storage Facility (SSF); and

• A stockpile of soil from the Orica Chester Hill site. Soil around the trade waste lines has not been sampled but there is potential for contamination. As the pipes are made of bonded asbestos, this soil may also contain broken bonded asbestos fragments. Approximately 10,000 m3 of soil (clay and weathered shale) from the excavation of hotspots in Areas A and C is stored in the SSF and is likely to be classified as Scheduled Chemical Waste (SCW) due to elevated DDX concentrations. Other CoCs likely to be present in the material include EDC, TCE, benzene and toluene. However no sampling of the soil has been undertaken since it was excavated due to the construction of the SSF. The soil within the SSF may also contain fragments of asbestos. A small amount (1,762 m3) of contaminated soil from a former Orica site at Chester Hill is also present in a covered stockpile on the Site. It contains a range of COCs, primarily TCE, carbon tetrachloride (CTC) and chloroform. Due to the age of the site, the presence of asbestos containing material (ACM) is likely to be encountered. Any asbestos waste from the piping or building fabric will be removed, contained and transported to a licenced landfill in accordance with all relevant standards and practices.



February 2011 8-2

8.1.2 Soil Remediation Criteria

URS (2010) has prepared a Human Health and Environmental Risk Assessment (HHERA) for the site that includes the development of risk-based soil concentrations (RBSC) for each ISZ where the potential for elevated risk has been identified. In addition, risk-based site-wide criteria (RBSWC) have been derived that can be applied in any area on the site.. The RBSWC supersede the development of zone specific RBSC, which were judged to be problematic in terms of future use and management of the site. The RBSWC take into account the toxicity or hazard of the chemical substances on the site the amount of exposure by people using the site. CoCs for the site were identified following review of relevant soil and soil gas data. Maximum contaminant concentrations identified in the ISZs were then assessed against screening guidelines. Contaminants that exceeded the screening guidelines were considered to be CoCs. The RBSWC were developed assuming that CoCs identified at any depth may be brought to the surface during excavation and construction works. Hence the RBSWC are relevant for all soil depths at the Site. Because not all compounds are present in each ISZ the RBSWC are conservative, that is they result in cleanup to a higher standard than would be required considering each zone separately. More detail regarding the required validation works for such works is provided in AECOM 2010 (Appendix D ) and URS 2010 (Appendix G ). The RBSWC for the Site from the HHERA are shown in Table 8-1 .



February 2011 8-3

Table 8-1 Remediation Criteria

Contaminant of Concern

Risk-Based Site Wide Remediation Criteria (mg/kg)

Hexachlorobenzene (HCB) *** 5c

1,2-dichloroethane (EDC) 700a

Vinyl chloride 10a

Chloroform 80a

Carbon tetrachloride 10a

Trichloroethene (TCE) 400a

Tetrachloroethene (PCE) 5b

1,1,2-trichloroethane 10a

Chlorobenzene 2500a

Benzene 5b

Toluene 200a

Ethylbenzene 200a

Xylenes 800a

PAHs (BaP equivalent) 10d

1,4-dichlorobenzene 15b

1,2,3-trichloropropane 0.5a

a-HCH (a-BHC) *** 30d

b-HCH (b-BHC) *** 15d

d-HCH (d-BHC) *** 1.2c

g-HCH (g-BHC or lindane) *** 15d

Dieldrin*** 15d

DDX (DDT + DDE + DDD) *** 2000d

Endosulfan II 100d

Pentachlorophenol 10d

Mercury (as total organic) 75c

NOTES: a = RBSWC for volatiles based on the maximum RBSC as available data suggests vapour inhalation

exposures are not significant and other exposures (ingestion and dermal contact) do not contribute

significantly to the total risk (for all key compounds).

b = RBSWC for volatiles based on the lower RBSC as the vapour pathways is not significant and other

exposures (ingestion and dermal contact) do not contribute significantly to the total risk (for all key

compounds). Hence to ensure the total risk remains acceptable, the lower RBSC has been adopted.

c = RBSWC based on the lowest RBSC

d = RBSWC derived to ensure a balance of total risk such that it remains acceptable (for all key

chemicals), and the extent of remediation (based on available data).

*** = Chemicals defined as Scheduled Chemicals (as per Schedule A, EPA NSW Scheduled Chemical

Waste Control Order 2004 [CCO]). Remediation of these chemicals might also require consideration of

other criteria to address requirements as outlined in the CCO.



February 2011 8-4

8.1.3 Soil Treatment Criteria

Soil treatment criteria may differ from the RBSWC, for Persistent Organic Pollutants (POPs) that are regulated under various state Acts, Regulations, Chemical Control Orders and national and international management plans and treaties. In general the state instruments require that treated soil meet lower criteria than required in national management plans which differentiate between soil and concentrates. The relevant national management plans (for concentrates) allow treatment to lesser risk based standards if it is not practicable to treat to more stringent standards. The relevant NSW instruments also give the DECCW the ability to agree to lesser standards. The outcome is that the soil on site would be treated to meet the RBSWC above as a minimum with the goal of meeting the following criteria in the NSW CCOs at a maximum providing it is practicable to do so:

• Statistical average of dioxin, furan and dioxin like PCB WHO-TEQ of less than 1ug/kg;

• An aggregate concentration of SCW constituents of less than 2 mg/kg; and

• A PCB concentration of less than 2 mg/kg.

If the RBSWC could not be achieved due to considerations of practicability, the matter would be raised with the DECCW. The proposed treatment criteria are shown in Table 8-2 .



February 2011 8-5

Table 8-2 Soil Remediation and Treatment Criteria

Contaminant of Concern

Proposed Risk-Based Site Wide Remediation Criteria (mg/kg)

Proposed Treatment Criteria (mg/kg)

Major Risk Contribution

1,2,3-trichloropropane 0.5 0.5

1,4-dichlorobenzene 15 15

a-HCH (a-BHC) 30 < 2 aggregatea

b-HCH (b-BHC) 15 < 2 aggregatea

Benzene 5 5

DDX (DDT + DDE + DDD) 2000 < 2 aggregatea

Endosulfan II 100 100

g-HCH (g-BHC or lindane) 15 < 2 aggregatea

Hexachlorobenzene (HCB) 5 < 2 aggregatea

Minor Risk Contribution

1,2-dichloroethane (EDC) 700 700

Vinyl chloride 10 10

Chloroform 80 80

Carbon tetrachloride 10 10

Trichloroethene (TCE) 400 400

Tetrachloroethene (PCE) 5 5

Chlorobenzene 2500 2500

Toluene 200 200

Ethylbenzene 200 200

Xylenes 800 800

PAHs (BaP equivalent) 10 10

Bis(2-chloroethyl)ether 1 1

d-HCH (d-BHC) 1.2 < 2 aggregatea

Dieldrin 15 < 2 aggregatea

Mercury (as total organic) 75 75

NOTES: a = a higher aggregate based on best practice may be proposed if this is not practicable.

8.1.4 Contaminated Soil Characterisation

Characterisation of soil proposed to be excavated and treated is required to estimate emissions of dust and contaminants and associated risk during excavation, pre-treatment and thermal treatment. These emissions are the basis for assessing compliance with standards for ground level concentrations of priority contaminants and toxic contaminants, stack emission concentrations and associated human health risks.



February 2011 8-6

Assessment of potential emissions has been undertaken using worst case average concentrations for:

• ISZs 1a, 1b, 2, 5, 7, 8 and 9 (Tables 22 to 26 in the RAP);

• the Chester Hill stockpiles (Tables 15 and 16 in the RAP); and

• the SSF soil using investigation data from Areas A and C (no stockpile data are available and representative sampling is not possible).

These are below 95% UCL mean concentrations, but are considered suitable for the purpose of assessment given that the ISZs all have different contaminant suites. Assessment of potential emissions associated with excavation emission has been estimated assuming the same worst case average contaminant concentration for each excavation area and a separate worst case average contaminant concentration for the two Chester Hill stockpiles. Assessment of potential emissions associated with Feed Soil Building and the DTD plant have been calculated assuming the same worst case average contaminant concentration across the excavation areas, Chester Hill stockpiles and SSF as show in Table 8-3 . A mass weighted average concentration for all soil requiring treatment is also shown for comparison.



February 2011 8-7

Table 8-3 Contaminated Soil Characterisation for FS B and DTD

Contaminant of Concern Worst case average concentration for ISZs mg/kg

Worst case average concentration for Chester Hill stockpile mg/kg

Worst case average concentration for FSB and DTD plant mg/kg

Source – ISZ, Chester Hill Stockpile or SSF

Tonnes 22,575 2,818 42,391

Major Risk Contribution

1,2,3-trichloropropane 0.34 0.34 ISZ1a, 2, 8

1,4-dichlorobenzene 3.1 84 SSF

a-HCH (a-BHC) 140 140 ISZ1a, 2, 8

b-HCH (b-BHC) 123 123 ISZ1a, 2, 8

Benzene 0.54 0.54 ISZ9

DDX (DDT + DDE + DDD) 6740 6740 ISZ1a

Endosulfan II 943 943 ISZ9

g-HCH (g-BHC or lindane) 138 138 ISZ7

Hexachlorobenzene (HCB) 19 19 ISZ7

Minor Risk Contribution

1,1-dichloroethane (1,1-DCA)

1.87 1.87 CH1

1,1-dichloroethene (1,1-DCE)

1.01 1.01 CH1

1,2-dichloroethene (cis) 5.6 5.6 CH2

1,1,1-trichloroethane (1,1,1-TCA)

23.7 23.7 CH1

1,2-dichloroethane (EDC) 13.5 50 SSF

Vinyl chloride 3.4 3.4 ISZ1a, 2, 8

Chloroform 8.71 8.71 CH1

Carbon tetrachloride 23.5 23.5 CH1

Trichloroethene (TCE) 148 148 CH2

Tetrachloroethene (PCE) 6.4 6.4 ISZ7

Chlorobenzene 63 143 SSF

Toluene 8.9 8.9 ISZ1a, 2, 8

Xylenes 10 SSF

PAHs (BaP equivalent) 0.50 0.5 ISZ1a, 2, 8

Naphthalene 0.11 0.11 ISZ1a, 2, 8

d-HCH (d-BHC) 20 20 ISZ1a, 2, 8

Dieldrin 29 29 ISZ9

Mercury (as total organic) 3.2 1.2 ISZ7 NOTES: a = bulk sample average cf maximum average of 6,740 mg/kg.

b = weighted average by 2 cf maximum average of 27 mg/kg.



February 2011 8-8

8.1.5 Potential Impacts

Remediation would require excavation of contaminated materials from nominated ISZs on the site. Thus there is potential for contaminants on the Site to be transferred to surrounding soil during remediation works, however this potential also exists under the current site conditions. Soil in the SSF would be prepared for treatment within a building so potential for impacts from this source are considered to be minimal. Potential impacts, during both construction and operation, include sedimentation and erosion associated with earthworks and site establishment, construction of internal roads on the Site and sedimentation and erosion resulting in transfer of contaminants to surrounding soil. Site establishment, including construction of plant and treatment buildings, site offices, sheds, decontamination units etc. has potential impacts associated with soil erosion and sedimentation. Soil erosion and sedimentation could also potentially result from earthworks and construction during site establishment, stockpiling of treated materials and movement of heavy vehicles. Internal haul roads would be established on the Site to accommodate vehicular traffic associated with proposed works, where required. This has the potential to increase soil erosion and sedimentation during construction. Erosion and sedimentation can also be exacerbated by wind and rainfall, which can aid the mobilisation of sediment particles. The mobilisation of contaminated material through erosion and sedimentation during excavation also has the potential to transfer contaminants to the soil surrounding the ISZs. Disturbance of this soil during site establishment, earthworks and the movement of heavy vehicles has the potential to result in the mobilisation of potentially contaminated materials to low level or uncontaminated soil within the Site and surrounding area.

8.1.6 Environmental Safeguards

Mitigation and management measures would be implemented and maintained on the Site throughout the duration of works. These include sediment and erosion controls, controls to reduce dust and leachate generation and spill and incident management procedures. Sediment and erosion controls would be implemented and maintained on the Site throughout the duration of plant construction, excavation of contaminated materials and treatment works to ensure that contaminants are contained within the Site until treated. The implementation of sediment and erosion controls would also mitigate impacts associated with sediment-laden runoff being transported away from the Site and into the local stormwater system. Sediment and erosion control measures would include:

• installation of silt fences prior to any Site preparation or construction;

• installation of silt fences around areas such as treated soil stockpiles to prevent migration of mobilised sediments;

• stockpiles of treated soil, sand, or other material capable of being mobilised by water flow to be stored clear of any drainage line or easement, natural watercourse, or road surface;

• stabilisation of soil stockpiles to minimise dust generation;

• vehicular access shall be controlled so as to prevent tracking of sediment onto adjoining roadways;



February 2011 8-9

• dust minimisation and suppression measures during earthworks such as the use of water spray, or ceasing work if dust suppression methods become inadequate; and

• wheel wash facilities at the ISZs and FSB to minimise the spread of soil across the Site.

Sediment and erosion controls would also be implemented on internal haul roads to provide all weather access for vehicles, protect underground services, suit drainage requirements, minimise environmental impact and minimise transit times. If required, haul roads would be constructed using clean, imported materials, which might include crushed concrete, crushed brick and rock. Barriers and marker posts would be erected along haul road margins to prevent erosion of adjacent sections of the Site. There is also the potential for transfer of contaminants to surrounding soil through dust and leachate generation. Measures to minimise the transfer of contaminants through dust or leachate generation may include:

• Use of coating materials such as PVA spray;

• Non-odorous soil cover; and

• Polyethylene sheet covers. Spill and incident management procedures would be implemented for the duration of works. DTD Plant, buildings and decontamination units would be bunded and appropriate emergency response and incident management procedures would be in place on the Site at all times for the duration of the works.

8.1.7 Residual Impacts

The potential for contaminants to be further transferred to surrounding soil would be minimised through the implementation of mitigation and management measures, including sediment and erosion controls throughout the duration of the works to ensure that contaminants are contained within the Site until treated. Appropriate spill and incident management procedures would further ensure that environmental impacts are minimised.

8.1.8 Conclusion

The EA has identified that during Site establishment and excavation and/or treatment of contaminated soil, there are a number of issues to be considered. Provided that appropriate environmental safeguards such as sediment and erosion control devices, construction measures and spill and incident management procedures are implemented, the issues identified are not expected to be a significant restraint to the project.



February 2011 8-10

8.2 Groundwater and Surface Water


Groundwater

The Site lies within the catchment for Byrnes Creek, which is essentially a concrete lined drain that is a tributary of Prospect Creek. Byrnes Creek receives stormwater discharge from several other open concrete lined drains including one located to the north of the Site and another located in the industrial area to the south of Christina Road. Groundwater flow in the upper Bringelly Shale is likely to be localised and discharge directly to Byrnes Creek and associated tributaries. Groundwater flow in the lower Ashfield Shale is likely to represent the broad regional groundwater flow system and discharge to Prospect Creek. Water levels across the Site have been measured since 2000 in a number of field investigations and are detailed in the RAP. In general the variation in the groundwater elevation at most locations is less than 1 m over the 6 year period, and in all instances where the water level fluctuation has been greater than 1 m, it appears to be related to an anomalous measurement. The water table elevation reflects the regional and local topography and indicates that groundwater in the northern and western portion of the Site flows in a westerly direction and groundwater from the southern and eastern portion of the Site generally flows in a south westerly direction towards Byrnes Creek, where it is inferred to discharge. Several site investigations have appropriately delineated the vertical and lateral extent of groundwater impacts in on-site and off-site areas. As a result, five separate dissolved phase plumes have been identified at the site and have been determined to be associated with the ISZ’s and/or the presence of DNAPLs. Based on the findings of groundwater modelling (A.D. Laase, 2007), it was concluded that the groundwater contamination at the Site is static and is unlikely to migrate to Byrnes Creek due to the effects of retardation, matrix diffusion and biodegradation. In addition, a HHERA assessed the potential risk to human health of groundwater concentrations at the Site and in off-site areas. The only exposure pathway considered to be potentially complete was the inhalation of volatile chemicals from the top of the groundwater table from the migration of vapours through the overlying soils and into buildings, outdoor air and excavations. Based on the soil gas and flux emissions data, the assessment of inhalation exposure off-site indicated “a low and essentially negligible risk for offsite commercial premises that may located above inferred groundwater plumes 1, 2 or 3”. Consequently, the HHERA concluded that groundwater did not present a significant risk to human health at the Site or in off-site areas. Based on the groundwater data obtained at the Site, the findings of the groundwater modelling and the HHERA, AECOM concluded in the RAP that groundwater conditions did not represent a significant risk to human health or the environment. The RAP proposes that source removal be undertaken as identified in Section 8.1 .



February 2011 8-11

The RAP also details that the identified groundwater impacts at the Site and in off-site areas are likely to be present for a long period of time. Consequently, a groundwater monitoring program will be undertaken with an aim to:

• Monitor and confirm contaminant concentrations associated with the identified groundwater plumes in onsite and off-site locations;

• Assess possible changes to contaminant concentrations at the Site and in areas downgradient of the Site following the excavation works; and

• Facilitate contingency planning in the event that the groundwater plumes are found to migrate.

The specific detail of the monitoring works will be confirmed with the preparation of a Groundwater Monitoring Plan to be developed in consultation with the Auditor and DECCW. Based on the persistent nature of the identified contaminants present in groundwater at the Site, the monitoring program will need to be undertaken for a long-term duration. Further information on the Groundwater Monitoring Program can be found in the RAP (Appendix D ) and in the current groundwater monitoring protocol (Appendix O ).

Surface Water

Historically all surface water run-off from the Site was collected in open earthen drains and discharged to an open surface water drain (No 9 Branch Drain) to the south of Christina Road. These earthen drains were reportedly replaced with pipe drains in the early 1970s. The practice of off-site discharge of stormwater ceased in approximately 1990, at which time rainfall run-off from the Site was segregated into “clean” stormwater and potentially contaminated stormwater run-off from manufacturing areas. Clean stormwater is discharged to Byrnes Creek to the south. Run-off from the former manufacturing areas is retained on-site for testing prior to discharge.


Groundwater

Although unlikely, the proposed remediation works have the potential to transfer contaminants to the groundwater during the excavation of materials. It should be noted however, that the potential for groundwater contamination always exists while the contamination remains present at the site and that the proposed works will ultimately remove the potential for further groundwater contamination.

Surface Water

The proposed remediation works have the potential to impact upon surface water through the transfer of contaminants from materials to stormwater runoff, thus affecting the quality of runoff to surrounding areas. The proposed remediation works have potential impacts, during both construction and operation. Sedimentation and erosion associated with earthworks, site establishment and construction of internal roads on the Site have the potential to transfer contaminants to surface water runoff. Water quality could also be affected by increased sedimentation and erosion resulting in sediment laden runoff. Soil erosion and sedimentation could also potentially result from removal of vegetation, stockpiling of treated materials and movement of heavy vehicles.



February 2011 8-12


Excavation works associated with the proposed remediation are to be undertaken within an area which would be fully bunded to prevent contaminated runoff leaving the Site. Spill management and emergency response procedures would also be in place on the Site to deal with unexpected incidents. Spill management, plant, buildings and decontamination units would be bunded and appropriate emergency response and incident management procedures would be in place for the entire duration of works. This would minimise the loss of contaminants to both surface and groundwater. Excavation works would not encroach upon the watertable, therefore the potential for groundwater contamination is minimised. If water is encountered within an area during excavation works, it would be removed for treatment at the WTP. It is anticipated that some seepage water may accumulate in the excavation over the course of the proposed remedial works. All water collected on the Site will be treated on-site to a standard suitable for discharge to sewer or reused during the excavation, remediation and reinstatement works, where possible. Only uncontaminated rainwater from building roof areas would be permitted to flow to stormwater drains. All other runoff is considered potentially contaminated and treated as effluent. There is potential to capture stormwater for use for activities such as treated soil re-wetting and this option would be taken if detailed review shows that it is practicable. The objective of the remediation works is to remove the source of contamination, therefore removing the potential for further contamination. Sediment and erosion control measures, as discussed in Section 8.1.6 , would be implemented and maintained on the Site, particularly around stockpiles of material to minimise sediment laden runoff leaving the Site. Upon completion of the proposed remediation works, the site would be re-contoured and stabilised to ensure that local water quality impacts are minimised. The proposal includes a WTP to treat potentially contaminated water captured on-site. Water management on site is illustrated in Figure 7 . Mitigation and management measures would be implemented and maintained on the Site throughout the duration of works.


The potential for contaminants to be further transferred to surface and groundwater would be minimised through the implementation of mitigation and management measures, including sediment and erosion controls, throughout the duration of the works to ensure that contaminants are contained within the Site until treated. If water is during excavation works, it would be removed for treatment at the WTP. Appropriate spill and incident management procedures would further ensure that environmental impacts are minimised. Provided these measures are implemented, the potential residual impacts upon surface and groundwater are expected to be minimal.



February 2011 8-13

As the proposal involves remediation of land to remove existing contaminants, it would ultimately result in benefits to both surface and groundwater quality. Environmental safeguards would be implemented throughout the remediation project to ensure that surface and groundwater is protected from further contamination.

8.2.5 Conclusion

The EA has identified that during Site establishment and excavation and/or treatment of contaminated soil, there are a number of issues to be considered in relation to surface and groundwater. Provided that appropriate environmental safeguards such as sediment and erosion control devices, construction measures and spill and incident management procedures are implemented, the issues identified are not expected to be a significant restraint to the project. While the proposal does not involve the remediation of groundwater underlying the Site, the excavation and treatment of the soil would remove a potential source of groundwater contamination. Further, a long-term groundwater monitoring program has been proposed to continue examining the identified static plumes.

8.3 Air Quality


Air Quality

The current air quality environment in the vicinity of the Site is likely to be influenced by emissions from industry in the region and vehicles using the road network surrounding the Site. No relevant ambient air quality monitoring has been undertaken in the immediate vicinity of the Site, so the assessment of existing air quality at the Site and surrounds is based on data collected by the DECCW’s ambient air quality monitoring network in the Sydney metropolitan region. In the case of the Villawood Remediation Project, the nearest appropriate DECCW ambient monitoring site is located in Chullora. The Chullora air quality monitoring site is located in the grounds of the Southern Sydney TAFE, Worth St, Chullora. It is situated in the centre of the Sydney basin in a mixed residential and commercial area and is approximately 6 km to the east of the Site.

The assessment has included regional background pollutant data collected at the DECCW’s Chullora monitoring site in order to provide an assessment of cumulative impacts. Maximum hourly background concentrations were used from data monitored at this site in 2008 (for PM10 due to several dust storms in 2009) and 2009 (for NO2, SO2 and CO). A summary of these data are provide in Table 8-4 , below. There is currently no plant and equipment already operating at the Site. The other pollutants that are considered in this study are not common pollutants in the airshed and hence the existing concentrations of these pollutants can be assumed to be negligible.



February 2011 8-14

Table 8-4: Summary of monitoring data recorded at C hullora monitoring station (2008, 2009)

Pollutant Averaging Period

Unit 2 DECCW Criteria

Background Concentration

10 minutes µg/m³ 712 118.6

1 hour µg/m³ 570 82.9

24 hour µg/m³ 228 13.0

Sulphur dioxide (SO2)

Annual µg/m³ 60 2.3

1 hour µg/m³ 246 106.8 Nitrogen dioxide (NO2)


24 hour µg/m³ 50 39.1 Particulate Matter (PM10)

1


15 minute mg/m³ 100 5.4

1 hour mg/m³ 30 3.8

Carbon monoxide (CO)

8 hours mg/m³ 10 2.6

NOTES: 1 Data shown for 2008 - Data for 2009 period is not suitable for use as several dust storm hit

Sydney basin in 2009 period 2 Data converted from pphm to µg/m³ for NO2 and SO2 and ppm to mg/m³ for CO

Air Impact Assessment Criteria (criteria designed for use in air dispersion modelling studies and air quality impact assessments for new or modified emission sources) has been used in this assessment. The DECCW impact assessment criteria set for those pollutants relevant to the activities proposed for the remediation project have been obtained from the Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales (Approved Methods), which was revised by the DEC in 2005. These are shown in Table 8-5 . The Approved Methods provides guidance for the selection and configuration of air dispersion models, methodologies to be used to compile meteorological datasets and emissions data, and specifies the assessment criteria to be used to evaluate compliance.



February 2011 8-15

Table 8-5: DECCW Impact Assessment Criteria for SO 2, NO2, PM10, TSP, CO and HF

Concentration Pollutant

(ppm) (µg/m 3)

Averaging Period

0.25 712 10 minutes

0.20 570 1 hour

0.08 228 24 hours

Sulphur Dioxide (SO2)

0.02 60 Annual

0.12 246 1 hour Nitrogen Dioxide (NO2)

0.03 62 Annual

- 50 24 hour Particulate Matter (PM10)

(less than 10 micron in diameter) - 30 Annual

Total Suspended Particulates (TSP)

- 90 Annual

87 100,000 15 minutes

25 30,000 1 hour

Carbon Monoxide (CO)

9 10,000 8 hours

- 0.5 90 days

- 0.84 30 days

- 1.7 7 days

Hydrogen Fluoride (HF) a

- 2.9 24 hours Source: Table 7.1 Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales, NSW

DEC (August 2005).

• General land use, which includes all areas other than specialised land use. Specialised land use includes all

areas with vegetation sensitive to fluoride, such as grape vines and stone fruits.

Table 8-6: DECCW Impact Assessment Criteria for dep osited dust


Maximum Increase in Deposited Dust Level

Maximum Total Deposited Dust Level

Deposited Dust a

Annual 2 g/m2/month 4 g/m2/month

Source: Table 7.1 Approved Methods for the Modelling and Assessment of Air Pollutants in New South Wales, NSW

DEC (August 2005).

NOTES: a = Dust is assessed as insoluble solids as defined by AS 3580.101-1991 (AM-19).



February 2011 8-16

Table 8-7: DECCW Impact Assessment Criteria for tox ic air pollutants


(ppm) (µg/m 3)

Averaging Period

Cadmium (Cd) - 0.018 1 hour

1,2-Dichloroethane (EDC) 0.018 70 1 hour

Dioxins and Furans c - 2.0 x 10-6 1 hour

Trichloroethylene (TCE) 0.09 500 1 hour

Vinyl Chloride (VCM) 0.009 24 1 hour

Chlorine (Cl2) 0.018 50 1 hour

Chloroform (CHCl3) 0.18 900 1 hour

Chloromethane (CM) 0.9 1,900 1 hour

1,2-Dichloroethylene (DCE) 3.7 14,400 1 hour

Hydrogen Chloride (HCl) 0.09 140 1 hour

Mercury (organic) (Hg) - 0.18 1 hour

Mercury (inorganic) (Hg) - 1.8 1 hour

Methylene Chloride (DCM) 0.9 3,190 1 hour

Sulfuric Acid (H2SO4) - 18 1 hour

1,1,2 Trichloroethane (TCA) 0.18 1,000 1 hour Source: Table 7.2a and Table 7.2b Approved Methods for the Modelling and Assessment of Air Pollutants in New

South Wales, NSW Dec (August 2005).

NOTES: a = Toxic equivalent as defined in clause 29 of the Regulation. .

Table 8-8: DECCW Impact Assessment Criteria for odo rous air pollutants


(ppm) (µg/m 3)

Averaging Period

Tetrachloroethene (PCE) 0.52 3,500 1 hour Source: Table 7.4a and Table 7.4b Approved Methods for the Modelling and Assessment of Air Pollutants in New

South Wales, NSW Dec (August 2005).

It is noted that ambient air quality criteria only consider the inhalation exposure pathway. For some pollutants, other pathways are often the main contributor to carcinogenic risk. Thus for these pollutants, the DECCW requires a quantitative health risk assessment be conducted. Modelling of the emissions for a number of pollutants has been undertaken as part of the air quality impact assessment. As required by the DECCW, a quantitative health risk assessment has been carried out to assess the implications of the modelling results for public health (Section 8.6).



February 2011 8-17

Odour

In November 2006, DECCW released two documents entitled Technical framework and Technical notes for the Assessment and Management of Odour from Stationary Sources in NSW. These documents outline the DECCW’s proposed approach for the assessment of odour emissions, using a three-level system of odour impact assessment of increasing complexity and detail.

• Level 1 is a simple screening exercise to identify the potentially affected zone and site suitability for a proposed facility or expansion of an existing facility.

• Level 2 is a simple dispersion modelling procedure. A Level 2 assessment is to be undertaken as a minimum for any odour-emitting development for which an Environmental Impact Statement (EIS)/EA or EPA licence is required. A Level 2 assessment uses worst case meteorological data (this can be a synthetic dataset, i.e. the Metsamp data file included with AUSPLUME) and worst case odour emission rates. A Level 2 assessment is a conservative screening level assessment and if odour criteria are met, no further assessment is required. Failure to meet the design odour criteria, however, means that a more detailed and refined Level 3 assessment is required.

• Level 3 is a more refined, comprehensive dispersion modelling assessment. A level 3 assessment is to be undertaken when a Level 2 assessment has indicated non-compliance with the odour design criteria. A Level 3 assessment includes the use of hourly averaged site-specific meteorological data and a robust emissions data set.

Potential odour impacts from the Villawood Remediation Project were assessed as part of the air quality impact assessment using a comprehensive dispersion modelling study. However, due to the complexity with determining odour thresholds for the chlorinated organic compounds (and hence the confidence that can be assigned to the odour threshold data), it is probably more appropriate to consider this odour assessment as Level 1 or 2.

CASA

The Civil Aviation Safety Authority has a set of guidelines and notifications that are required to be adhered to because the Site is within 15km of the Bankstown Airport and the exit velocity in the stacks is likely to be greater than 4.2 m/s. Formal plume modelling assessments may need to be carried out for all stacks which will need to include at what height the exhaust speed will fall below 4.3 m/s once the final designs have been completed.


Air Quality

The following emission sources from the proposed remediation works have been identified for assessment:

• The stack venting treated air from the ECS on the FSB;

• The stack emitting treated air from the pollution control system of the DTD plant;

• Fugitive organic emissions and dust from excavation and handling of contaminated soil; and

• Fugitive dust emissions from activities involved in the project such as treated soil stockpiles, earth movement works on clean soil, and concrete breaking and handling activities.



February 2011 8-18

The excavation works would occur between the hours of 7am and 5pm for 6 days a week. However, air quality impacts have been assessed for 7 days a week to be conservative and assess for the complete set of annual meteorological conditions.

It is assumed that up to 500m3 of contaminated material could be moved in a day. There will be one 25 tonne excavator operating at the site for purposes of excavation, so only one excavation area would be open to the atmosphere at any given time. Therefore, organic emissions would only be concurrent from one open excavation area as well as the DTD stack and the FSB ECS stack. For the air quality assessment, the maximum predicted ground level concentrations have been compared for organic emissions for all open contaminated areas for all meteorological conditions in the annual dataset and presented the highest predicted concentrations at each receptor point on the modelled domain to provide the worst case assessment for organic emissions from open sources.

Typically, the FSB and the DTD will operate 24 hours a day, 6 days a week, however we have assessed impacts for operations 7 days a week.

There are also activities associated with clean soil, treated soil and concrete that may result in emissions of non-contaminated dust (i.e. without organic pollutants), which have been assessed in terms of air quality impacts for TSP, PM10 and dust deposition.

Based on the remediation schedule several source locations were identified and used as model inputs. All earth movement activities have been modelled as volume sources and emissions from DTD plant and FSB have been modelled as point (stack) sources. In quantitatively assessing air quality impacts from a proposed development at an existing industrial site, there are three components that need to be addressed:

• Air emissions from the proposed operations or new development itself;

• Air emissions from any plant and equipment already operating at the site; and

• Background pollutant concentrations from other emission sources in the regional airshed (i.e. other industries, vehicles, domestic sources, natural sources etc).

The cumulative impacts of these three contributing source groups need to be assessed on a pollutant-by-pollutant basis. For example, if the pollutants that are to be emitted by the proposed development are not emitted elsewhere at the site, then only the regional background levels need to be accounted for. If it is a pollutant not commonly found in the airshed, then the regional background levels may also be assumed to be negligible.

For this assessment, background pollutant concentrations for criteria pollutants, i.e. NO2, SO2, PM10 and CO are required. There is currently no plant and equipment already operating at the site. The other pollutants of concern to the study are not common pollutants in the airshed and hence the existing concentrations of these pollutants can be assumed to be negligible.

The modelling has included regional background pollutant data collected at the DECCW’s Chullora monitoring site in order to provide an assessment of cumulative impacts. Maximum hourly background concentrations were used from data monitored at this site in 2008 (for PM10 due to several dust storms in 2009) and 2009 (for NO2, SO2 and CO). For the other pollutants ambient concentrations have been assumed to be negligible.



February 2011 8-19

An inventory of predicted emissions from the FSB and DTD Plant has been compiled, including details for stack conditions and expected pollutant concentrations and discharge rates for both stack and fugitive emissions. Because the site remediation has not been contracted at this time and a thermal plant has not been nominated to undertake the treatment works, emissions from the treatment plant stack have been estimated using worst case parameters including maximum capacity of existing Australian treatment plants and minimum performance specifications for the off-gas treatment systems. This provides a conservative assessment of likely air quality impacts under normal operating conditions from the proposed remediation project. Details of emissions used in the modelling and modelling parameters are found in the Air Quality Impact Assessment Technical Report (Appendix H ). Conservative emission rates were also used as input data for atmospheric dispersion modelling. The atmospheric dispersion modelling results have been assessed against the air quality assessment criteria outlined in Section 8.3.1 above, to provide an air quality impact assessment for the proposed remediation project. The assessment criteria for Category 1 pollutants are applicable at the nearest existing or likely off-site sensitive receptors. Figure 11 shows the location of surrounding offsite sensitive receptors. The dispersion modelling study was undertaken using the AUSPLUME dispersion model, which is the approved dispersion model for use in most simple, near-field applications in NSW, where coastal effects and complex terrain are of no concern. The results of atmospheric dispersion modelling are presented for the pollutants in categories as outlined by the Approved Methods (DECCW, 2005) as follows:

• Category 1 includes the criteria air pollutants, i.e. SO2, CO, NO2, PM10, HF and TSP;

• Category 2 includes pollutants specified as toxic air pollutants; and

• Category 3 includes pollutants that were modelled but are not specified in the Approved Methods in categories one or two above.

Category 1 Pollutants

Predicted incremental concentrations due to the proposed Project at offsite sensitive receptor locations are presented in Table 8-9 . Contour plots for the project increment for Category 1 pollutants are presented in the Air Quality Impact Assessment Technical Report (Appendix H ). Cumulative impact of the criteria pollutants is included below. Preliminary assessment with initial proposed DTD plant stack parameters predicted exceedance of HF, PM10 and TSP criteria at surrounding offsite sensitive receptors. For these pollutants the stack height for the DTD plant was increased from the worst case 14.9 m to 30 m to test the potential impact at surrounding offsite sensitive receptors for these pollutants with a 30 m stack. Predicted concentrations for HF, PM10 and TSP presented in Table 8-9 are based on stack height of 30 m. Other stack parameters were held constant in this study. If further assessment confirms that the concentrations of HF, PM10 and TSP in the DTD plant exhaust are lower than the values used in this assessment, then it may be possible that the DTD plant could use a 14.9 m stack for the remediation. However, a modelling assessment would be required to assess potential impacts of these pollutants at a lower stack concentration if it were proposed to use a lower DTD plant stack height than 30m.



February 2011 8-20

Table 8-9: Predicted concentration of Category 1 po llutants at surrounding sensitive receptors from th e Project, 30 m DTD Plant stack

ID R1 R2 R3 R4 R5 R6 R7 R8 R9 R10


Unit DECCW Criteria

Residence at Miller Road




Villawood Detention Centre

Residence at Waldron Road

Abbott Park

Wentworthville Evening College

Leightonfield Train Station

A La Turko Food Industries

10 min µg/m³ 712 140 162 118 55 53 64 91 31 22 31

1-hour µg/m³ 570 98 113 83 39 37 45 64 22 16 22

24-hours

µg/m³ 228 37 40 28 8.8 11 11 22 5.4 3.8 7.7

SO2

Annual µg/m³ 60 2.7 2.7 1.8 0.91 0.95 1.1 2.0 0.68 0.50 0.72

1-hour µg/m³ 246 118 100 92 77 68 89 131 57 55 61 NO2

Annual µg/m³ 62 4.0 4.0 3.0 2.1 2.4 2.5 3.5 1.7 1.6 2.1

15 min mg/m³ 100 0.16 0.19 0.14 0.06 0.06 0.07 0.10 0.04 0.03 0.04

1-hour mg/m³ 30 0.12 0.14 0.10 0.05 0.05 0.06 0.08 0.03 0.02 0.03

CO

8-hour mg/m³ 10 0.07 0.07 0.05 0.02 0.02 0.02 0.05 0.01 0.01 0.02

24-

hours µg/m³ 2.9 1.3 1.5 1.4 1.3 1.5 0.97 1.0 1.4 0.72 1.1

7 days µg/m³ 1.7 0.74 0.86 0.54 0.44 0.57 0.53 0.59 0.43 0.40 0.62

30 days µg/m³ 0.84 0.44 0.39 0.29 0.22 0.31 0.51 0.49 0.23 0.25 0.33

HF1

90 days µg/m³ 0.5 0.34 0.39 0.33 0.23 0.26 0.31 0.31 0.20 0.18 0.24

24-hour µg/m³ 50 5.9 4.6 4.1 2.3 2.2 3.7 6.2 2.0 1.3 1.9 PM101

Annual µg/m³ 30 1.2 0.91 0.54 0.33 0.28 0.52 1.1 0.27 0.19 0.23

TSP1 Annual µg/m³ 90 1.2 0.79 0.35 0.16 0.10 0.33 1.1 0.12 0.09 0.10

Dust

deposition Annual g/m²/mon

th 2 0.10 0.06 0.02 0.01 0.01 0.02 0.08 0.01 0.01 0.02

NOTES: 1 HF, PM10 and TSP results are based on a 30m stack assumption.



February 2011 8-21

Sulphur dioxide (SO 2) Table 8-10 presents the predicted maximum SO2 concentrations (project increment and cumulative) for the offsite sensitive receptors assuming a 14.9 m stack for the DTD plant and 21.5 m stack for the FSB ECS stack. These results show that predicted concentrations comply with DECCW criteria for SO2 for all averaging periods. Table 8-10: Maximum predicted ground level SO 2 concentrations at any offsite sensitive receptors (µg/m³)

Averaging Period

DECCW Criteria

Background Project Increment

Cumulative Impact

10 minutes 712 119 162 281

1-hour 570 83 113 196

24-hours 228 13 40 53

Annual 60 2.3 2.7 5.0

Nitrogen dioxide (NO 2) Table 8-11 presents predicted maximum NO2 concentrations (project increment and cumulative) at any offsite sensitive receptors assuming a 14.9 m DTD plant stack and 21.5 m stack for the FSB ECS stack . These results show that predicted concentrations comply with DECCW criteria for NO2 for both 1-hour and annual averaging period. Table 8-11: Maximum predicted ground level NO 2 concentrations at any offsite sensitive receptors (µg/m³)

Averaging Period

DECCW Criteria


Cumulative Impact

1-hour 246 107 131 237

Annual 62 24 4.0 28



February 2011 8-22

Carbon monoxide (CO) Table 8-12 presents predicted maximum CO concentrations (Project increment and Cumulative) at any offsite sensitive receptors assuming a 14.9 m DTD plant stack and 21.5 m stack for the FSB ECS stack. These results show that predicted concentrations comply with DECCW criteria for CO for all averaging period. Table 8-12: Maximum predicted ground level CO conce ntrations at any offsite sensitive receptors (mg/m³)

Averaging Period

DECCW Criteria


Cumulative Impact

15 minutes 100 119 162 280

1-hour 30 83 113 196

24-hours 10 13 40 53

Hydrogen Fluoride (HF) No background data are available; therefore a cumulative assessment has not been conducted for HF. However, it can be assumed that the ambient HF concentration would be minimal. Based on this assumption and results presented in Table 8-9 it can be concluded that the project will comply with DECCW criteria for HF for all averaging periods. Particulate Matter Table 8-13 presents predicted maximum PM10 and TSP concentrations (project increment and cumulative) at offsite sensitive receptors. These results show that predicted concentrations comply with DECCW criteria for both PM10 and TSP assuming a 14.9 m DTD plant stack and 21.5 m stack for the FSB ECS stack . Table 8-13: Maximum predicted ground level PM 10 concentrations at any offsite sensitive receptors (µg/m³)

Parameter Averaging Period

DECCW Criteria


Cumulative Impact

24-hour 50 39 6.2 45.3 PM10

Annual 30 20 1.2 21

TSP Annual 90 49.91 1.1 51

NOTES: 1 Background TSP concentrations are calculated from background PM10 concentration assuming 39% of TSP is PM10



February 2011 8-23


The impact assessment criteria for individual toxic air pollutants are applicable at and beyond the boundary of the facility. The incremental impact (99.9th percentile, Level 2 assessment) for each pollutant due to the proposed operations at any offsite locations are presented in Table 8-14. Contour plots for the project increment for Category 2 pollutants are presented in Appendix H. It is noted that soil sampling data provided indicates a mercury hotspot in Zone 7 and none of the other zones indicated the presence of mercury. As a conservative approach, the model has assumed that all of the mercury emissions from the proposed Project will be organic mercury. Model predictions for a 14.9 m DTD plant stack show exceedance of DECCW criteria for organic mercury at offsite locations. Further modelling was conducted with a 30 m DTD plant stack and offsite mercury concentrations due to the Project are presented in Table 8-14 . Mercury emissions from the excavation activities in Zone 7 have also been modelled separately to find the maximum soil mercury concentrations that could be excavated while the DTD stack is operating. The results of that assessment indicate that predicted cumulative impacts (i.e. emissions from DTD plant, FSB ECS and excavation activities) would comply with DECCW criteria for organic mercury if soil mercury concentrations are at or below 25 mg/kg. In terms of complying with the DTD plant mercury stack emission limit and subject to the outcome of commissioning trials, the mercury contaminated soil would either be blended with other contaminated soil (not containing mercury),or if the stack standard could not be met it would be stabilised and landfilled. In future, if further soil analysis for Zone 7 is conducted and mercury concentrations in the soil are proven to be lower than the current indicated “hotspot” concentrations, then it is possible that the DTD plant could use a 14.9 m stack for the remediation. However, a model run would be required to assess potential mercury impacts at a lower feed soil concentration if it were proposed to use a lower stack than 30m.



February 2011 8-24

Table 8-14: Predicted maximum offsite concentration s for toxic air pollutants (listed in DECCW guideline)

Pollutants Unit DECCW Criteria Maximum Offsite concentration

(30m Stack)

CCl4 mg/m³ 0.012 0.007

Chlorobenzene mg/m³ 0.1 0.034

Mercury (organic) mg/m³ 0.00018 3.0E-05

Benzene mg/m³ 0.029 5.5E-04

PAH mg/m³ 0.0004 1.0E-07

Chloroform mg/m³ 0.9 0.0016

EDC mg/m³ 0.07 0.0013

TCE mg/m³ 0.5 0.036

Toluene mg/m³ 0.36 0.008

Xylene mg/m³ 0.19 1.7E-05

1 2 DCE mg/m³ 14.4 0.001

1 1 1 TCA mg/m³ 12.5 0.0085

Vinyl Chloride mg/m³ 0.024 0.017

HCl mg/m³ 0.14 0.12


These pollutants do not have defined DECCW criteria for air quality assessment. Therefore, assessment of these pollutants has been conducted using the guideline for toxic air pollutants (Level 2 Assessment). The predicted 99.9th percentile offsite concentrations for these pollutants are listed in Table 8-15 . Contour plots for the project increment for Category 3 pollutants are presented in Air Quality Impact Assessment Technical Report (Appendix H ). Note that all pollutants that were assessed in this study and do not have applicable air quality assessment criteria, have been assessed by GHD in the HHERA (GHD, 2010).



February 2011 8-25

Table 8-15: Predicted maximum offsite concentration s for toxic air pollutants (not listed in DECCW guideline)

Pollutants Unit Maximum Offsite concentration

DDX mg/m³ 5.50E-04

Naphthalene mg/m³ 7.0E-06

PCE mg/m³ 0.015

Endosulfan mg/m³ 8.0E-05

Dichlorobenzene mg/m³ 0.001

Dieldrin mg/m³ 2.4E-05

HCB mg/m³ 6.5E-05

Trichlorobenzene mg/m³ 6.5E-05

BHC mg/m³ 6.5E-04

1,1 DCA mg/m³ 4.4E-04

1,1 DCE mg/m³ 5.0E-04

Based on the results of the modelling study as described above, the maximum emissions from the proposed remediation are not predicted to have a significant impact on air quality in the surrounding area. It is also noted that this assessment has been based on the minimum performance specifications and they therefore represent potential maximum impacts. In addition, the proposed remediation operations would only exist for a temporary period until the remediation works are completed. When remediation is completed, emissions from the works will no longer exist and any volatilisation of chlorinated organic compounds from the existing Site will have been removed.



February 2011 8-26

Odour

Potential odour impacts associated with the proposed remediation project may be caused by the release of odours and vapours from the exposure of contaminated materials during excavation and handling. Odour was assessed by comparing predicted concentrations of modelled odorous compounds against reported odour thresholds, or detection limits. This analysis involves no odour sampling, so should only be relied on as a screening analysis. Although all the organic compounds have been assessed, it is possible that the modelling did not include other compounds or combinations of compounds that are ‘unknown’ but could exist at the Project site and may be responsible for objectionable off-site odour. Therefore there is a chance that the results presented here underestimate odour impacts. By definition one odour unit is the concentration of a compound (or a mixture of compounds) required for 50% of a population to detect its odour in air under controlled laboratory conditions. This definition leads to the assumption that the odour detection limit, or odour threshold, is equivalent to one odour unit, or:

1 ou ≈ odour threshold (µg/m³) There were 16 potentially odorous organic compounds (i.e. chlorinated organic compounds) modelled in this study. For 10 of these compounds, an appropriate odour threshold was researched in the available literature. It can be assumed that from the lack of data, the six compounds that do not have readily available odour threshold data are not particularly odorous. The maximum predicted GLC from modelling was scaled to find the peak concentration (nose-response time) and then compared to the corresponding threshold value. The result is an approximate odour concentration for each compound. The cumulative odour concentration can be estimated by the sum of each compound’s odour concentration. To satisfy any outstanding questions relating to odour, Thiess notes that the recommended guidance provided in the Technical Framework: Assessment and Management of Odour from Stationary Sources in NSW, November 2006 was not used to assess odour impacts. Thiess also notes that the DECCW also does not suggest using dynamic olfactometry to determine odour emissions where the source contains principal air toxic pollutants. Therefore, in the absence of such data, the cumulative odour impact has been assessed by comparing the maximum ground level concentrations with the relevant odour threshold. Using the maximum predicted GLC provides some conservatism about the peak odour concentrations used in this assessment. The resulting peak GLCs are shown in Table 8-16 . This ratio applies to tall wake free point sources and is a conservative approximation for volume, area and low stacks.



February 2011 8-27

Table 8-16: Predicted Peak Concentrations of Volati le Chlorinated Organic Compounds

Pollutant Maximum 1-Hour GLC

(mg/m³)

Peak GLC

(µg/m³)

Mean Odour Threshold (mg/m³)

Odour Concentration

(Max GLC / Mean Threshold)

Carbon Tetrachloride

3.54E-02 2.12E-01 1380.5 1.54E-04

Chlorobenzene 1.31E-01 7.84E-01 6.6 1.19E-01

Naphthalene 3.00E-05 1.80E-04 2.1 8.65E-05

Benzene 2.08E-03 1.25E-02 106.6 1.17E-04

PCE 5.36E-02 3.22E-01 32.0 1.01E-02

Chloroform 7.90E-03 4.74E-02 1582.2 3.00E-05

Dichlorobenzene 4.00E-03 2.40E-02 45.4 5.29E-04

TCE 1.86E-01 1.11E+00 25.0 1.51E-03

Toluene 2.86E-02 1.72E-01 0.5 4.02E-03

Xylene 1.80E-05 1.08E-04 317.7 3.51E-03

Total 0.14

To estimate odour concentration of a mixture of odorants by summing the individual ‘chemical odour units’ as above is subject to some uncertainty. However, research by Cometto-Muñiz et al. (2001) found that:

For both trigeminal endpoints (i.e., eye irritation and nasal pungency), the results showed that stimuli of relatively low detectability did show complete sensory agonism, whereas stimuli of relatively high detectability fell short of complete sensory agonism when compared with the detectability of the single substances. (Cometto-Muñiz et al. , (2001))

In other words, for a mixture of odorants at low concentrations (near or below odour threshold), the individual odorants appear to be additive in terms of odour strength. However, at somewhat higher concentrations, the resultant odour strength is less than the sum. For the current results, simple addition should provide a reasonable approximation. The total odour concentration resulting from this approach is 0.14 ou, which is below the odour threshold. When average odour threshold values are applied to maximum predicted GLCs, the results indicate that off-site odours from these emissions are unlikely to be detectable. In addition, the odour threshold for most of these compounds is well above the health/Occupational Health and Safety (OHS) exposure limits. Compliance with the OHS/air quality limits would mean that odour is not likely to be an issue.



February 2011 8-28

Based on early input from DECCW, it was requested that ground level concentration criteria as explained for individual odorous pollutants in the Technical Framework: Assessment and Management of Odour from Stationary Sources in NSW, November 2006 be used to ensure that the maximum off-site concentration is used in the odour assessment and that concentration is consistent with values used in the air quality assessment (where averaging periods are the same). The revised peak GLCs are shown in Table 8-17 . Table 8-17: Revised Predicted Peak Concentrations o f Volatile Chlorinated Organic Compounds

Pollutant

Maximum 1-Hour off-site GLC (mg/m³)

Peak 1-hour off-site GLC (µg/m³)

Mean Odour Threshold (mg/m³)

Odour Concentration (Max GLC / Mean Threshold)

Carbon Tetrachloride 1 0.007 0.042 1380.5 3.04E-05

Chlorobenzene 1 0.034 0.204 6.6 3.09E-02

Naphthalene 1 7.00E-06 0.000042 2.1 2.02E-05

Benzene 1 5.50E-04 0.0033 106.6 3.10E-05

PCE 2 0.015 0.09 32 2.81E-03

Chloroform 1 0.0016 0.0096 1582.2 6.07E-06

Dichlorobenzene 1 0.001 0.006 45.4 1.32E-04

TCE 1 0.036 0.216 25 6.80E-04

Toluene 1 0.008 0.048 0.5 1.23E-03

Xylene 1 1.70E-05 0.000102 317.7 1.51E-05

Total 0.04

NOTES: 1 US EPA (1992) Reference Guide to Odor Thresholds for Hazardous Air Pollutants Listed in the Clean Air Act Amendments 2 WHO (1984) http://www.inchem.org/documents/ehc/ehc/ehc31.htm

As was shown in Table 8-16 , despite constraints in the capacity to obtain odour data, it is considered that the approach used in this assessment provides a reasonable prediction for off-site odour impact. The predicted odour impacts for individual substances as shown in Table 8-17 are non-detectable (up to 0.04 OU, or 2% of DECCW criteria), and as such it appears reasonable to assume that DECCW odour criteria are unlikely to be exceeded due to the potential, combined total odour from site operations.



February 2011 8-29

Dust

Dust emissions from the construction phases of the project would not be expected to result in off-site nuisance impacts. The construction periods for dust generating activities are relatively short, where possible the existing network of sealed access roads will be used to transport contaminated soil to the treatment facility and the Site is compact. Dust mitigation measures would be specified in the Construction Environment Management Plan (CEMP) for the remediation project to minimise the potential for any emissions from construction activities. During operations, dust emissions from activities in the FSB will be contained, and air from the building will pass through the ECS. Wheel-generated dust from truck and machinery movements outside of the buildings would not be expected to cause nuisance because they would largely be on pavements and would be controlled by water sprays, if necessary.


During Construction

The construction phase of the project will be conducted over a short timeframe and it is not expected that any significant impacts will be experienced during the time that construction activities take place. However, the following mitigation measures should be observed during the construction phase of the FSB and the DTD plant, in order to minimise impacts as much as possible.

• Access to the site will be via existing sealed roadways only;

• Water will be used to suppress particles potentially generated during the erection of boundary fences, barriers and screens;

• Dust from land clearing activities will be controlled using water suppression, if necessary;

• Areas of disturbed soils will be minimised during the construction period;

• Water may be used to suppress dust emissions during dry windy periods (as required);

• The height from which dust generating material is dropped will be minimised;

• Loaded trucks carrying contaminated materials shall be covered at all times, unless the time taken to cover the trucks would exceed the travel time to transport the material from the excavation face to the FSB enclosure;

• The cutting/grinding of materials on site shall be kept to a minimum. Where cutting or grinding is necessary equipment and techniques to minimise dust will be used;

• Earthworks will be kept damp, especially during dry weather;

• Soil mounds will be treated with surface binding agents or sealed by seeding or surfacing with vegetation or covered with secured tarpaulins;

• Soil mounds will be damped as necessary;

• Potentially dusty materials will be handled as little as possible;

• Traffic movements will use the network of existing pavements where possible;

• Paved areas will be swept when necessary using a vacuum sweeper;

• Wheels of all site plant and vehicles will be cleaned so that mud is not spread on surrounding roads;



February 2011 8-30

• Exhaust emissions will not discharge straight at the ground;

• Construction plant and vehicles will be well maintained and regularly serviced. Visible smoke from plant during operation should be avoided. Defective plant will not be used;

• Engines will be switched off when vehicles are not in use and refuelling areas will be away from areas of public access;

• Loading and unloading will take place within the site;

• Any waste will be removed from site and disposed to an appropriately licensed waste facility; and

• A Construction Environment Management Plan would be prepared for the construction phase, specifically addressing measures to be implemented to minimise off-site dust emissions.

During Operation

Emissions management and mitigation measures for fugitive emissions (including odour) and point sources have been considered in the design of the proposed remediation works. The FSB is proposed to be completely enclosed and will operate so that air flows inwards through louvres and out of the building through the ECS. The ECS includes dust filters and activated carbon adsorption beds to control organic vapour emissions. Therefore, handling of contaminated material in the FSB will not generate significant emissions to atmosphere. The proposed excavation of contaminated zones will include sampling and validation of contaminant concentrations in soil. Contaminated zones would be excavated with reference to the soil sampling validation data to ensure that excavation rates do not cause volatile organic emissions that result in unacceptable air quality and/or health risks. For example, where there is a known contaminant ‘hotspot’, iterative dispersion modelling has been used to determine the maximum excavation rate for respective contaminant soil concentrations. When the validation data confirms the in-situ pollutant soil concentrations, a maximum excavation rate can be derived that would meet the air quality and health risk criteria based on modelling. If higher than expected soil concentrations are encountered, then the excavation rate for the delineated area for those soil validation results, can be slowed significantly to manage volatile organic vapour emissions (this principle is also effective for reducing odour, if it is encountered). In extreme cases, the excavation area could be enclosed in a temporary structure and captured air from within the temporary structure could be vented to the FSB where it would be treated by the FSB ECS. Emissions from the DTD plant are treated by a series of emissions control equipment prior to release to atmosphere. This includes a:

• Cyclone – gases from the rotary kiln pass through a hot cyclone to remove large particulate matter.

• Thermal oxidiser – the gas exiting the cyclone will be directed to a thermal oxidiser to destroy volatile organic compounds.

• Evaporative Cooler – the gas exiting the thermal oxidiser is partially quenched in a partly refractory lined evaporative cooler to minimise dioxin reformation and prepare the emissions for the baghouse, but above the temperature required to condense acid gases.



February 2011 8-31

• Baghouse – a pulse jet baghouse is used to capture particulate matter and metals. A particulate matter emission concentration of < 30 mg/Nm3 corrected to 11% oxygen is expected to be achieved. If required activated carbon may also be blown into the baghouse to coat the fabric filters, and assist with removal of Hg that is present in the feed soil. This need for the control technology will be known once commissioning trials have been completed, and the mercury hotspot on the site has been evaluated.

• ID fan – an induced draft (ID) fan is used to pull gases through the system and exhaust it to the scrubber.

• Acid Gas Scrubber – the gas exiting the ID fan is directed to a pipe quench and packed scrubber, which neutralises acid gases (i.e. HCl and SO2).

• Stack- The scrubber gas exhausts to the stack.

The thermal oxidiser (being the major piece of emission control equipment) will be designed to meet the requirements of best practice technology in terms of destruction efficiency and air pollutant emissions. Operation and control of the gas treatment system would be managed through monitoring of various key operating parameters, linked to alarm and control actions.


The proposed remediation project is not expected to result in any significant residual impacts associated with air quality, provided that emissions are kept below those modelled in the air quality impact assessment undertaken in respect of the proposal. The emission rates in this assessment are predominantly based on worst-case assumptions in order to provide a conservative assessment. Potential residual impacts associated with dust emissions during construction will be minimised through the implementation of environmental safeguards, and will be of a temporary nature. A monitoring program would be designed for the FSB and DTD Plant stacks to include measurement of the exhaust gas temperature, flow rate, oxygen concentration (DTD Plant only) and moisture content in order to enable the calculation of pollutant emission rates corrected to dry conditions at specified O2 contents as per agreed standards. Stacks would also be fitted with sampling port(s) in accordance with Australian Standards and safe access provided for stack sampling. An ambient monitoring program may also be conducted to ensure that fugitive emissions are controlled and unacceptable impacts are not experienced off-site.

8.3.5 Conclusion

Dispersion modelling undertaken for the proposed Villawood Remediation Project has demonstrated that under conservative pollutant emission rates and meteorological conditions, all pollutant concentrations are predicted to be below the DECCW assessment criteria for all sensitive receptors. Residual impacts associated with dust emissions will be of a minor and temporary nature, and are not likely to pose a significant constraint on the proposal.



February 2011 8-32

8.4 Noise

8.4.1 Introduction

Noise emissions from the Site will be subject to conditions of an Environment Protection Licence (EPL) issued by the DECCW. The Conditions within the EPL pertaining to noise will be negotiated with reference to the NSW Industrial Noise Policy (INP) and will be primarily concerned with the impact upon nearby residences. The nearest sensitive residential receivers are east along Waldron Road, east Miller Street, and the Villawood Detention Centre north of the site. The only non-residential sensitive receiver is Chester Hill High School, northeast of the site (Figure 12 ). All sensitive receivers are shielded to some extent by industrial buildings surrounding the site. Orica has elected to ensure that noise associated with the proposal, including construction and operational noise, is controlled so that the total noise from the Site meets the appropriate licence condition. In this regard, noise emissions at nearby residences should comply with appropriate criteria from the INP.

8.4.2 Existing Environment and Noise Criteria

The existing noise environment at the nearest residences is generally due to local traffic, and traffic generated by local industry. Criteria for Residential Receivers Noise criteria are shown in Table 8-18 . The daytime criteria are based on the Intrusiveness criteria of the INP. Evening and Night Time criteria are based on the amenity criteria of the INP. Most activities are considered operational, and assessed to the INP. A few activities described later will be considered as construction. These will occur during daytime hours only. Daytime construction criteria are based on the recommendations of the DECCW Interim Construction Noise Guideline. Table 8-18: Noise Criteria

Operation Construction

Day Evening Night Day

Location LAeq,15min

(dBA) LAeq,period

(dBA) LAeq,15min

(dBA) LAeq,period (dBA)

212 Waldron Rd 48 45 40 53

183 Miller St 51 45 40 56

190 Virgil 48 45 40 53

Epic Place - Detention Centre 48 45 40 53 NOTES: Where the noise source contains annoying characteristics, such as dominant low

frequency content, adjustment factors as per the INP apply.



February 2011 8-33

DECCW also requires that consideration be given to the potential for sleep arousal within nearby residential receivers. The primary sleep arousal criteria are given in Table 8-19 . Table 8-19: Sleep Disturbance Criteria

Receiver Number Receiver Name RBL Criterion, L A1,1min dBA

1 212 Waldron Rd 38 53 2 183 Miller St 38 53 3 190 Virgil 38 53 4 Epic Place - Detention Centre 39 54

Criterion for Industrial Receivers All industrial receivers within the area are subject to meeting a noise criterion of LAeq 70dBA, based on the INPs acceptable amenity levels. Criterion for Chester Hill High School The noise criterion at Chester Hill High School is that noise should not exceed 35dBA in the classroom, corresponding to an approximate level of 45dBA outside. Criterion for Recreational Areas Abbott Park is an active recreational area attracting a noise criterion of LAeq 55dBA (when in use) and is based on the acceptable amenity levels contained within the INP.


Construction and Operation

The remediation process is expected to take approximately 14 months to complete including site establishment, pre-treatment, treatment, validation, decommissioning and reinstatement. Most of the material will be treated on site and remain on site. From a noise point of view the operations are:

• Constant 24 hour operation of the PTB, DTD and WTP;

• Daytime operation of heavy equipment breaking concrete and excavating soil, then moving it to stockpiles.

• A concrete crusher operating in the later stages of the project.

• Most of the concrete will be broken up using an excavator. Little use is expected of hydraulic hammer attachments, though this cannot be ruled out.

Some noise sources could be considered as construction noise. Construction noise has a higher daytime criterion due to its shorter duration. The following will be considered construction:

• Construction and decommissioning of FSB, DTD and WTP;

• Any brief periods of hammering using rock hammers.

• The INP requires consideration of any prevailing meteorological conditions which could enhance noise levels at sensitive receivers for significant periods.



February 2011 8-34

8.4.4 Noise Modelling

The assumed sound levels of the equipment that will be used on site during the project are given in Table 8-20 . Table 8-20: Source Noise Levels

Plant Sound Power Level (dBA)

Sound Pressure Level at 7m (dBA)

Front End Loader 111 86 Smooth Drum Roller 107 82 Spoil, Materials or Concrete Truck 109 84 Truck-mounted Shotcrete Pump 106 81 Excavator or Bobcat 107 82 Concrete Cutter 109 84 30t Excavator operating with hydraulic hammer

122 97

Articulated Dump Truck (Moxi) 113 88 Handheld Jackhammer 113 88 Thermal Plant (Fan at 2m source height) 116 91 Thermal Plant (Mitigated Fan at 2m source height)

103 78

Thermal Plant (Plant at 10m source height) 104 79 Thermal Plant (Stack tip at 30m source height)

92 67

Water Treatment Pumps 101 76 Tracked Crusher 113 88

The operational scenarios described in Table 8-21 were modelled for noise impact. Table 8-21: Scope of Works for Noise Generating Act ivities in Stages

Stage of Works

Area Approximate Duration, weeks

Works Noise Sources in Model

1A G 1 Excavation. Concrete demolition and transport.

Excavator, 2 x Moxi

1B G 10 Construction of ECS and DTD. Treat contaminated material.

Not modelled as noise less than 1A

2 I, H, B

10

Demolish concrete, excavation and transport to PTB. Treat contaminated material.

Front end loader in PTB, Front end loader or bulldozer, excavator. DTD. WTP, 2 x haul truck

3 H, B, D, F, E, G

8

Demolish concrete, excavation and transport to PTB, Treat contaminated material

Front end loader in PTB, Front end loader or bulldozer, excavator. DTD. WTP, 2 x haul truck

4 G, H 13 Decon and dismantle PTB, DTD, ECS, WTP. Crush concrete.

Front end loader in PTB, Front end loader or bulldozer, excavator. DTD. WTP, 2 x haul truck, Crusher



February 2011 8-35

The INP requires consideration of meteorological conditions that could enhance noise propagation from the site for significant periods. Therefore the following conditions were modelled, based on analysis of meteorological data from Bankstown Airport:

• Still, isothermal (no wind, no temperature inversion);

• Still, 3°/100m temperature inversion for night tim e only;

• Isothermal, 3m/s winds WSW for evening only.

8.4.5 Assessment of Predicted Noise Levels

The predicted noise levels for daytime operations are given in Table 8-22 . Table 8-22: Predicted Operational Noise Levels, L Aeq,15min

Stage 1

Stage 2

Stage 3A Stage 4

Rec. No.

Receiver Name CriterionLAeq,15min dBA

Area G

Area I, B, H

Area E

Area D

Earthworks and crusher in Area G

Earthworks Area H with crusher in Area G

1 212 Waldron Rd 48 33 39 43 43 37 39 2 183 Miller St 51 31 41 34 33 34 40 3 190 Virgil 48 34 40 39 38 38 40 4 Detention Centre 48 49 42 47 45 49 41

The predicted levels comply with the noise criteria at all locations for all Stages of work, except at Receiver 4 during Stage 1 work. This is when work occurs closest to the Receiver 4 and a 2dBA exceedance is predicted. As the exceedance is only 2dBA, and occurs for only 1 week, it is considered only a marginal impact. The predicted noise levels for evening and night time operations are given in Table 8-23 . Because the noise continues at a constant level through the night, the determining criteria are the amenity criteria. No exceedances of the noise criteria (including the sleep disturbance criteria) are predicted at any location. Table 8-23: Predicted Noise Level, Evening and Nigh t Time, L Aeq,period dBA

Meteorological Conditions

Rec. No.

Receiver Name

Evening Criterion, LAeq,4hr dBA

Night Time Criterion, LAeq,9hr dBA

Isothermal, still

Calm, Tempature Inversion 3°/100m

Isothermal, Wind 3m/s WSW

1 212 Waldron Rd 45 40 34 38 39 2 183 Miller St 45 40 30 33 34 3 190 Virgil 45 40 36 40 40

4 Epic Place - Detention Centre

45 40 36 30 39



February 2011 8-36

Assessment at Chester Hill High School The noise criterion at Chester Hill High School is that noise should not exceed 35dBA in the classroom. The predicted noise level at the school is 35-40dBA, depending on the Stage of operation and the receiver location in the school. The typical noise reduction into a building with windows open is 10dBA. That is a predicted noise of 40dBA outside would give a noise of 30dBA inside if windows were normally open for ventilation. Hence the noise is predicted to comply at all locations within Chester Hill High School during all stages of operation. Assessment at Commercial and Industrial Neighbours At the commercial premises across Christina Road the predicted noise levels are always below 65dBA, which complies with the criterion. At industrial premises adjacent to the site, predicted noise levels will generally comply with the criteria. Some exceedances are predicted when the earthmoving equipment is within 20m of the facades. However the neighbouring facades are all masonry and only minor impacts are predicted.

8.4.6 Traffic Noise

Traffic to and from the site will be limited to deliveries, arrival of occasionally used equipment such as cranes, and the light vehicle traffic of staff. The site remediation strategy does not include movement of material onto or off the site. Typically less than ten heavy vehicles per day would enter and leave the site from Christina Road. . Considering the existing high volume of traffic, including heavy vehicles, on the local network, the addition of up to ten heavy vehicles per day, and the arrival and departure of staff, is predicted to increase traffic noise by less than 0.1dBA. Such a small increase (well below the 2dBA limit recommended by DECCW guidelines) is not measurable or perceptible, and no noise impact is predicted.

8.4.7 Vibration

The impact of vibration to sensitive receivers has also been assessed. Significant use of vibration generating equipment is not anticipated, but there may be some use of excavator mounted rock breakers during demolition phases. Vibration would not be detectable at residential receivers and no impact is predicted. Vibration may occasionally be perceptible within neighbouring commercial premises. The levels are not predicted to exceed the required guideline levels (with reference to the DECCW Guideline Assessing Vibration: ‘a technical guideline’ and British Standard 6472-1992) to the nearby industrial buildings. The risk of building damage (with reference to German Standard 4150-1999 Part 3) is considered low.



February 2011 8-37


Construction and Operation

The following general mitigation measures shall be considered in the detailed design and specification of the DTD Plant in order to achieve the required noise reductions.

• ECS and DTD Plant fans (discharge side) shall be designed to achieve the required noise emissions. Silencers may also be incorporated on the discharge. This will in turn reduce the noise from the stack tips and from the stack itself;

• ECS and DTD Plant fans and motors (intake and case radiated) shall be designed to achieve the required noise emissions. Fans and motors may also be encased within an enclosure to minimise noise;

• A flexible connection between the fan and ductwork shall be used in the DTD Plant stack. The connection would be encased to control break out noise.

• Ductwork, including the stacks shall be acoustically lagged if required. This shall be confirmed once operational, and retrofitted if needed.

The following additional safeguards would be implemented to mitigate noise emissions in respect of the project:

• Preparation and implementation of a Construction Noise and Vibration Management Plan (CNVMP) to ensure noise level criteria are met;

• Notification to all those impacted by works likely to cause excessive vibration or noise;

• Periodic noise and vibration testing should be undertaken during any activity associated with the proposed works that is likely to generate high noise and vibration levels; and

• Provision of a 24 hour community hotline.


Given that potential impacts with respect to noise and vibration are of a temporary and manageable nature, the construction and operation of the proposed DTD remediation facility is not expected to result in significant residual noise impacts. In considering the more sensitive residential receivers and adverse weather conditions that are typical of the Site, the predicted noise level exceeds the noise goals by only 2dBA at one location (the Detention Centre) for a brief period (less than two weeks). Noise impact would be minimised by siting of equipment in a way that shields this receiver whenever possible.

8.4.10 Conclusion

Noise generated from the proposed project would occur during both construction and operation. Upon implementation of the environmental safeguards, potential noise impacts are not anticipated to pose constraints to the construction and operation of the proposed remediation facility. A CNVMP should be developed and implemented to ensure noise level criteria are met.



February 2011 8-38

8.5 Hazards and Risk

8.5.1 Introduction

Community consultation has been undertaken as a part of the planning process for the proposed project, and hazard and risk has been highlighted as an area of potential concern. A PHA was consequently undertaken by Sherpa Consulting Pty Ltd (Sherpa) using the standard NSW DoP methodology. The objectives of the PHA were to:

• Develop a comprehensive understanding of the hazards, risks and adequacy of the safeguards associated with proposed remediation facility.

• Determine whether the risk levels associated with the project are acceptable when compared to appropriate criteria.

• Prepare a report that documents the identified hazards and risk assessment (in accordance with Hazardous Industry Planning Advisory Paper (HIPAP) no 6).

In accordance with standard PHA methodology, the PHA focuses on effects of potential accident or plant upset scenarios, i.e. acute exposure events. The PHA is appended in its entirety in Appendix K of this EA.


Due to the presence of a number of chemicals classified as Scheduled Chemical Waste (SCW) the contaminated soils are also SCW under the Chemical Control Order (CCO) issued under the Environmentally Hazardous Chemicals (EHC) Act. The contaminated soil is not a Dangerous Good (DG) under the Australian Dangerous Goods Code. The potentially hazardous incidents associated with the proposed facility were primarily identified during a workshop held as part of the Orica Hazard Study (HS) 1 and 2 for the project. The hazard studies were supplemented by a review of previous studies associated with other similar remediation projects using DTD technology, including the approved Car Park Waste Encapsulation (CPWE) remediation project at the Orica BIP site. The information was compiled into Hazard Identification and Risk Assessment Control (HIRAC) tables. The tables show the risk event, causes, consequences, likelihood and controls in place. The compiled information is contained in Appendix 3 of the PHA (refer Appendix K ). These scenarios included:

• Failures of the ECS for the Feed Soil Building, in the event of a power/mechanical failure, or failure of carbon beds adsorbing contaminants from exhaust air, resulting in release of contaminants to the air;

• Transport incidents (within the remediation site), resulting from loss of material from a truck transporting solid wastes due to vehicle accident or loss of load cover; and

• DTD Plant incidents, including incomplete treatment of contaminants due to DTD Plant malfunction, power failure, HCl scrubber failure, mechanical equipment failure, and internal explosions in gas-fired equipment. These may result in inefficient destruction and emission control, incomplete combustion resulting in unwanted by-product formation, OHS issues for operators, the release of hot relatively dilute gases and risks associated with an explosion on-site.

More detailed descriptions of each of the scenarios can be found in the PHA (refer Appendix K ).



February 2011 8-39

A qualitative assessment of the risks associated with the project was undertaken. Orica’s internal risk matrix was used to rank the risk associated with the identified hazardous incidents, and supplemented by quantitative calculations where additional detail was required. This approach is consistent with the Level 2 assessment described in the NSW DoP guidelines Multi Level Risk Assessment. The potentially hazardous incidents identified did not have the potential to have a significant effect (safety, health or environmental) outside the immediate incident area. No incidents were identified with an off-site (i.e. outside Orica property) fatality risk, or an acute injury effect in any off-site areas Air dispersion modelling predicts that plant upset scenarios will not cause levels of contaminants at sensitive areas (e.g. residential areas, primary schools etc) sufficient to cause injury. For a worst case scenario (HCl scrubber failure), HCl concentrations may reach levels sufficient to cause irritation in a small part of the residential area on Miller St under a very limited number of wind weather conditions and for a short duration only. The likelihood of this event is assessed as very low and below the irritation risk criteria given in HIPAP4. The risk to the environment from accident or process upset scenarios occurring at the proposed remediation facility is also regarded as low. As there are no off-site impacts at an injury or fatality level, and only one low frequency event with potential to cause irritation in a residential area, all quantitative risk criteria in HIPAP 4 by the NSW DoP are satisfied. The qualitative risk level is also in the ‘acceptable’ or ‘As Low as Reasonably Practicable’ band for identified issues with the potential to have an off-site impact when assessed against Orica’s corporate risk matrix. The risk level to surrounding land users from the proposed facility is therefore assessed as low.


For all the identified scenarios as shown in the hazard identification table in Appendix 3 of the PHA (refer Appendix K ) hardware and procedural safeguards are included in the design, which are aimed at reducing the likelihood and/or consequence of an incident. Key controls include:

• Sophisticated temperature control of the thermal oxidiser and rapid quench to maximise contaminant destruction efficiency and minimise unwanted by-product formation.

• Redundant systems to maintain function of key emission control equipment (cyclone, evaporative cooler, baghouse and acid gas scrubber) in the event of a utility failure (gas, water and power).

• Automatic isolation of contaminated soil feed to DTD Plant in the event of a plant upset and controlled shutdown sequence.

These controls would be supported by a management system which covers maintenance and periodic review of the controls to maintain their effectiveness. In addition, the proposal includes emergency response plans, fire protection equipment and stormwater and effluent control.



February 2011 8-40

A dedicated ERP for the remediation facility covering the FSB and DTD operations would be developed prior to commencement of operations. It is noted that the NSW OHS (DG Amendment) Regulations require that emergency services be consulted about emergency plans. Consultation with the Fire Brigade would be undertaken as part of the preparation of the remediation facility ERP. The remediation facility ERP would be based on the ERP in place at the Allied Feeds (Rhodes Peninsula) site and that developed for the similar CPWE remediation facility approved for the Orica site at the Botany Industrial Park. Fire detection and protection required by the Building Code of Australia and relevant Australian Standards will be provided. As the detail design phase of the project progresses, a detailed Fire Safety Study that satisfies the NSW DoP’s guideline HIPAP No 2 Fire Safety Studies would be prepared in respect of the project.


The PHA concluded that the project will not result in an off-site fatality risk, and therefore does not result in any societal risk contribution to the area from the Site. The hazardous incidents identified did not have the potential to have a significant effect (safety, health or environmental) outside the immediate incident area. No incidents were identified with an off-site (i.e. outside the remediation facility) fatality risk or an acute injury effect in any off-site areas, including residential. For a worst case scenario (HCl scrubber failure), irritation effects in a small part of the residential area on Miller St under a very limited number of wind weather conditions and for a short duration only could occur. The likelihood of this event is assessed as very low and below the irritation risk criteria given in HIPAP4. The risk level associated with the proposed facility is therefore considered to be very low, and all quantitative risk criteria suggested by the NSW DoP are satisfied. The risk level is also in the ‘acceptable’ or ‘As Low as Reasonably Practicable’ band for identified issues with the potential to have an off-site impact when assessed against Orica’s corporate risk matrix. Whilst any impact on the environment is undesirable, the main concern for risks to the biophysical environment from accident events is the potential effect on whole systems or populations. The potential environmental hazards associated with the project are due to the bio-accumulative properties of the chlorinated compounds in the waste or due to the small quantities of toxic by-products such as dioxins that could be produced in the thermal oxidiser.

The incident scenarios identified involving either a gas emission or an effluent / liquid spill had very limited impact area due to the relatively small quantities of contaminants and short incident durations. The risk to environment from accident or process upset scenario occurring at the proposed remediation facility is therefore regarded as low. As the design is still preliminary and a number of options are being investigated specific design recommendations have not been made. To ensure that additional risk reduction opportunities are identified and implemented as the design progresses, the following activities should be completed:

• Conduct a Construction Safety Study (which has been included in Conditions of Consent by the NSW DoP for previous development applications);

• Develop a Fire Safety Study (which has been included in Conditions of Consent by the NSW DoP for previous development applications);



February 2011 8-41

• Complete a HAZOP study once detail design is complete; and

• Ensure that the ERP for the facility is prepared, and that the Fire Brigade has the opportunity to provide input as required by the NSW DG regulations.

8.5.5 Conclusion

This EA has assessed the potential impacts pertaining to the management of hazards and risk of the proposal. The project will not result in any fatality risk (hence societal risk) or acute injury risks from the Site. The PHA indicates that the risks to surrounding land uses associated with the proposed remediation project would be low. The PHA and hazard study process highlighted a number of areas where potential risk levels to personnel working at the remediation plant may be relatively high. While this does not alter the study conclusions with respect to off-site land use planning risks, it is recommended that a more detailed risk assessment be completed to ensure that the operator’s duty of care obligations to employees under the NSW OHS Regulations are met.

8.6 Human Health Risk

In response to concerns regarding the potential impacts of the proposal on human health, a Human Health Risk Assessment (HHRA) was undertaken by GHD (Appendix I ). The overall objective of the HHRA is to identify, characterise and evaluate potential risks to human health associated with the operation of the proposed Orica Villawood remediation option. The focus of the HHRA is in areas surrounding the proposed process that includes adjacent residential areas surrounding the site (including Chester Hill High School located 500 m to the east).


The following land uses have been identified surrounding the site:

• North: immediately north is industrial land, with residential property about 500 m from the site boundary. Chester Hill High School is located about 500 m from the site boundary on the east side of Miller Rd;

• South: immediately south is industrial land, with residential property 700 m from the site boundary, south of Biloela Street;

• East: Abbott Park and residential properties located directly across Miller Rd; and

• West: industrial land up to Woodville Road.



February 2011 8-42

A human health and environmental risk assessment by URS (2007) and recently revised by URS in 2010 (Appendix G ) was conducted to derive remediation criteria for reuse of soil on the site and to identify the chemicals of potential concern (COPC) at the site. The COPC present in the proposed remediation zones were:

• VOCs

• Hexachlorobenzene;

• 1,2-Dichloroethane;

• Chloroform;

• Carbon tetrachloride;

• Trichloroethene (TCE);

• Tetrachloroethene (PCE);

• Chlorobenzene;

• 1,4-Dichlorobenzene;

• 1,2,3-trichloropropane;

• 1,1-Dichloroethane;

• 1,1-Dichloroethylene;

• 1,2-(cis)-Dichloroethylene;

• 1,1,1-Trichloroethane;

• Vinyl Chloride;

• MAHs

• Benzene;

• Toluene;

• Xylenes;

• OCPs

• a-HCH (a-BHC);

• b-HCH (b-BHC);

• d-HCH (d-BHC);

• g-HCH (Lindane);

• Dieldrin;

• DDX (DDT/DDD/DDE);

• Endosulfan II;

• Mercury;

• Naphthalene; and

• Carcinogenic Polycyclic Aromatic Hydrocarbons (Carc. PAHs). These chemicals were considered as part of the HHRA.


Potential human health impacts that may be associated with the proposed Orica Villawood remediation project have been assessed by evaluating the following:

• Emissions and exposures associated with construction of the FSB and DTD Plant that will be constructed adjacent to the SSF. During construction there is the potential for exposure to dusts that may be generated during this phase of the project.

• Emissions during operation of the proposed Orica Villawood remediation project – there is potential for emissions (dust and vapour) to air from the following sources:

- FSB stack venting treated air from the ECS on the FSB building;

- DTD Plant stack emissions;



February 2011 8-43

- Fugitive dust and vapour emissions during excavations of contaminated zones and Chester Hill Stockpile;

- Fugitive dust emissions during concrete removal and non-contaminated soil moving activities;

- Fugitive dust emissions from the treated soil stockpiles;

- Fugitive dust emissions from the treated soil reinstatement activities at the site.

• Emissions to air that may occur during abnormal operating scenarios.

Construction Impacts

A review of dust emissions was undertaken as part of the PAE (2010) Air Quality Impact Assessment (see Section 8.3 and Appendix H of this EA) which concluded that dust emissions from the construction phase of the project would not be expected to result in off-site nuisance impacts. As such, provided dust mitigation measures are implemented, there are considered to be no issues associated with the construction phase of the project that warrant further consideration in the context of human health impact.

Operation Impacts

Based on the proposed remediation process and control systems, there is the potential for the following exposures to emissions generated by the project:

• Inhalation exposures (acute and chronic) by workers in areas adjacent to the Orica Villawood site (north, south and west);

• Inhalation exposures (acute and chronic) by recreational users of Abbott Park located directly across Miller Road;

• Exposures by residents to emissions to air. Key issues are expected to be associated with inhalation exposures (acute and chronic) and potential multiple pathway exposures (chronic) to chemicals considered to be persistent and bioaccumulative and that may deposit onto and accumulate in soils and home-grown produce.

The HHRA draws upon the air quality modelling work done in respect of the proposal (see Section 8.3 and Appendix H of this EA) and as such addresses the potential human health risks at the key receptors modelled as part of the Air Quality Impact Assessment. The location of these receptors is shown in Figure 11 . The detailed HHRA (GHD, 2010) is presented in Appendix I . In addition data relevant to the following areas has also been used in the HHRA:

• Maximum on-site: maximum concentration estimated within the site boundary; and

• Maximum off-site: maximum concentration estimated for all areas located outside the site boundary, typically located on the boundary of the site. This receptor is also known as the Maximum Exposed Individual (MEI).

The concentrations (and deposition rates) estimated have been evaluated further in the HHRA with respect to potential acute (short-term) and chronic (long-term) health effects.



February 2011 8-44

The characterisation of risk associated with the operation of the proposed Orica Villawood remediation project has identified the following for the key receptors and pathways identified:

• Normal operation of the Orica Villawood remediation project:

- Short-term, acute, exposures associated with emissions to air derived from the proposed Orica Villawood remediation project only have been assessed. Impacts to human health associated with acute exposures in all areas surrounding the Site are considered to be low.

- The evaluation of long term, chronic, exposures has focused on potential inhalation exposure to chemicals of potential concern (COPCs) identified in air following emissions to air in residential areas (in particular north and east of the site. Exposure also considers deposition in surrounding areas followed by direct contact exposure by residents (soil ingestion, dermal contact with chemicals in soils, and ingestion of home-grown fruit and vegetables).

- The maximum off-site exposed individual (MEI) has been predicted to be located in the residential premises to the east of the site on Miller Road, next to Abbott Park.

- The total hazard index values for the MEI evaluated for all threshold Chemicals of Potential Concern (COPCs) fall well below 0.2. This indicates that the estimated intake associated with reasonable maximum exposures by all offsite receptor groups to emissions from the Orica Villawood remediation project, fall below the acceptable cumulative exposure levels for the COPCs.

- The total incremental lifetime cancer risk for the offsite MEI evaluated for all non-threshold COPCs associated with emissions from the Orica Villawood remediation project and cumulative exposures falls below the incremental risk level of 10-6 adopted as representative of acceptable risk as defined by DECCW.

- The primary COPC contributing to cancer health risk was DDX (81%), with nearly all of this through the consumption of home-grown produce, which is dependent on dust deposition rates. Exclusion of plant uptake and consumption from the estimate of risk resulted in an incremental cancer risk less than of 1 x 10-8, which is considered to be negligible.

- The evaluation of risk to human health associated with emissions during normal operation of the proposed Orica Villawood remediation project, including cumulative risks, is therefore considered to be low and representative of negligible risks.



February 2011 8-45

• Upset Operating Conditions:

- Short-term, acute exposures associated with emissions to air derived from worst-case upset condition identified from the proposed Orica Villawood remediation project only, have been assessed. Impacts to human health associated with acute exposures during such an event in all areas surrounding the Site are considered to be low.

- Due to the short duration of upset condition identified, no long-term exposure assessment was considered to be necessary.

- On this basis the evaluation of risk to human health associated with emissions during upset operating conditions (worst-case scenario) is therefore considered to be low and representative of negligible risks.

These calculated levels of risk are indicative of acceptable levels of risk for potential exposures to the proposed Orica Villawood remediation project as well as cumulative impacts.


The safeguards to be implemented in relation to human health risk are largely those associated with the control of fugitive emissions from the Site, as described in Section 8.3.3 and Section 8.5.3 of this EA. This includes the following:

• The construction and operation of the proposed Villawood remediation project would be undertaken using an appropriate OHSP for construction workers on the Site as well as long-term employees in the facility. The plan would include the preparation of safe work method statements to address specific activities as outlined within the PHA (Sherpa 2010) (see Appendix K );

• Operational procedures and controls noted in the PHA (Sherpa 2010) (Appendix K) would be followed; and

• Mitigation measures associated with construction and operation of the proposed Orica Villawood remediation plant noted within the Air Quality Impact Assessment (PAE 2010) (Appendix H ) would be followed.


The proposed remediation of the Orica Villawood site would result in some fugitive emissions during the excavation and treatment process. However, the mitigation measures to be implemented as part of the project, including those inherent to the design of the Plant, would ensure that these emissions do not pose an unacceptable risk to human health. The proposal would result in the remediation of land which is currently contaminated, thereby ultimately removing future risk to human health associated with the contaminants contained on the Orica Villawood site. Therefore, the proposal is considered to have a net positive residual impact in terms of human health risk.



February 2011 8-46

8.6.5 Conclusion

Impacts to human health associated with the construction and operation of the proposed Orica Villawood remediation project have been evaluated using a systematic approach as outlined in guidance provided by enHealth (2004). This includes the identification of key issues, evaluation and quantification of exposure, evaluation and quantification of hazards or chemical toxicity and the characterisation of risk. The assessment undertaken has indicated that potential exposures (including cumulative exposures) by residents, recreational users of areas surrounding the site and workers are negligible and representative of acceptable risks to human health.

8.7 Cumulative Impacts

Cumulative impacts on the environment can be considered on a project basis, taking into account each element on a locality or regional basis as well as taking into account the interacting impacts of other projects in the immediate locality and the region. The cumulative impacts of the proposed remediation project have been considered in relation to each identified environmental issue in Sections 8.1 to 8.6 and Section 9 of this EA and the cumulative impacts of the proposal especially with respect to air quality, noise, hazards and risks have been considered in each of the technical studies undertaken in respect of this proposal. As the potential impacts for each of the environmental factors considered are minimal with the implementation of appropriate mitigation measures as described in this EA, no significant cumulative impact is expected.



February 2011 9-1

9 ASSESSMENT OF NON-KEY ENVIRONMENTAL IMPACTS

Villawood is located in the north west of the Bankstown LGA in western Sydney. The Bankstown LGA covers an area of approximately 77 km2, comprising 4.476 hectares (Ha) residential land, 1,275 Ha recreational and park land, 1,109 Ha specials uses land, (schools churches, airport and railway land etc) and 871 Ha of industrial, commercial and business uses. Villawood is bounded by Miowera Road, Gurney Road and First Walk in the north, Miller Road in the east, the Hume Highway in the south and Woodville Road in the west. It is an established residential and industrial area, which was initially settled as pastoral land in the 1802s. Significant industrial and residential development occurred post the 1920s, with rapid growth in the immediate post-war years, aided by public housing construction and the establishment of a migrant hostel. The characteristics of the Villawood area are largely related to the significant amount of industry and commercial activities which occupy a significant part of the total land area. Major features of the area include Villawood Detention Centre, Thurina Park and two schools. The population of Villawood has declined slightly since the early 1990s, a result of lack of residential growth and declining average household size. The population of Villawood based on 2006 census figures was 3,143 comprising 1,529 males and 1,614 females (www bankstown.nsw. gov.au/facts and figures). In 2006, about 40% of the Villawood population were born overseas, and 60% were working age adults.

9.1 Social Impacts

The social impacts of a proposal relate to the effect that it may impose on people. They include how it may alter their way of life, the character, cohesion and demography of the community or their customs and values. Social impacts may be quantitative, such as the effects on employment or population, or they may be qualitative, such as effects on the amenity of the area, and the perception of the community towards the proposal. For this proposal, social impacts would relate mainly to amenity impacts such as visual, traffic and noise during construction and operation, impacts associated with hazards and risks and economic impacts related to future employment opportunities. Potential visual, traffic and economic impacts are discussed here and below. Potential noise impacts and hazards and risks are discussed in Section 8 under assessment of key impacts. The primary objective of the proposal is to remove contaminants existing within the site to a standard suitable for ongoing commercial / industrial landuse. This would provide social benefits related to:

• the prevention of further spread of contaminants to surrounding soil and groundwater;

• elimination of potential hazards associated with emissions to the environment from the Site;

• return of the land to a productive use, with associated employment opportunities; and

• subsequent improvements in the general amenity of the local area.



February 2011 9-2

The presence of a remediation workforce of 15 to 20 people could also result in direct and indirect benefits to the local. These social benefits are considered to outweigh the temporary potential impacts associated with the proposed works.

9.2 Visual Impacts

Visual impacts will largely be related to the presence of the DTD plant and associated treatment facility with 20 to 30 m high stacks for the duration of the project. Some additional structures would be required for remediation pre-treatment activities. However these would be no different to past, present and future building located on the site. Visual impact due to onsite soil excavation and handling would be lessened by the maintenance of patches of landscaping vegetation during the remediation. A brief report on potential visual impacts of the project is contained in Appendix L . Potential visual impacts associated with the proposal are likely to be minimal as the proposed remediation facility will be viewed in the wider context of the surrounding industrial and commercial landuses. The remediation area is surrounded by high commercial and industrial buildings on three sides so that excavation will be visible only from commercial premises on the southern boundary. This would be screened to some extent by existing mature vegetation on the western boundary eastern side, which will be retrained under the remediation plan. Potential residual impacts associated with the proposal include visual impacts associated with stacks and buildings on the Site and visual impacts associated with night time lighting for 24 hour operation. The visual impacts of the stacks and buildings will not be visually intrusive given the industrial nature of the Site and the stacks would be removed upon completion of works. Given that the residual impacts will be short lived and temporary and in most cases are unlikely to be perceptible, they are considered to be outweighed by the benefits of the proposed remediation works. The following safeguards have been identified in accordance with AS428-1997 to mitigate potential impacts and avoid the potential for offense to local visual amenity:

• Select suitable colours and materials for proposed structures in keeping with warehouses and factories of the local area to minimise reflectivity and contrast.

• Ensure lighting is directed away from sensitive receptors, is task specific with regard to illumination and incorporates shielding to reduce light spillage, glare and skyglow.

• Augment existing barriers to light spill in the south-east corner of the Site at identified locations.

• Assess proposed lighting installations for compliance with appropriate lighting and safety standards.

• Prepare and submit an application with Bankstown Airport Ltd to determine the type of safety lighting and/or marking required atop the proposed stacks or tall construction machinery, to mitigate against potential safety impacts for pilots.



February 2011 9-3

9.3 Traffic and Access

The Site is located in an area with a well developed network of major and minor roads designed to accommodate heavy commercial as well as light vehicle traffic. The main access into the site is from Christina Road and it is constructed to handle heavy vehicles. Site access and key traffic routes are shown in Figure 13 . The proposed project would require the use of public roads for:

• delivery of building materials and associated plant and equipment; • delivery to and removal of the of the DTD plant from the Site, probably from a

location within Australia; • delivery of fuel and consumables during the operation phase; and • work trips for around 15 to 20 employees during the construction and operation

phases.

Additional traffic generated by the proposed project would be largely internal to the site, which is more than large enough to deal with the remediation traffic movements. Traffic generated on public roads by the proposed remediation project would be small when compared with traffic generated by past and future commercial / industrial use of the site. In order to minimise potential traffic impacts on the community associated with the proposal, a Traffic Management Plan (TMP) will be prepared, which will address issues including site access, workforce car parking and unloading areas, and haulage routes. These would essentially be an extension of arrangements that have been in place for many years for industrial use of the site. Traffic volumes associated with the remediation project would be much less than that associated with the previous and future industrial land use. Potential residual impacts associated with the proposal include a minor increase in traffic but well below historical traffic volumes during industrial use of the site. Given that the residual impacts will be short lived and temporary and in most cases are unlikely to be perceptible, they are considered to be outweighed by the benefits of the proposed remediation works.

9.4 Flora and Fauna

This section identifies likely impacts of the proposed remediation project on flora and fauna, biodiversity, threatened species, communities or habitats. Several vegetation surveys of part or the entire site have been undertaken previously. The most recent was by Urban Bushland Management Consulting (May 2000) (Appendix M ), which is the basis of the site Bushland Management Plan (Orica Australia, September 2003). The Site has been largely cleared in the past and comprises disturbed land which is covered by roadways, building slabs, areas of fill, some patches of shrubs and mature trees planted for landscaping purposes, some isolated remnant native trees and an area of regrowth native vegetation along a drainage line on the western boundary. Areas of landscaping vegetation would be preserved consistent with the BCC’s Tree Preservation Order to the extent possible, consistent with the need to remediate the Site.



February 2011 9-4

Remediation areas would include remediation excavation areas, transport corridors and operation areas for treatment and handling. The excavation areas will be located according to the distribution of contamination on the site. Transport corridors will be located on existing sealed roads where possible. Operational areas will be located adjacent to excavation areas and the Secure Soil Facility. All vegetation within excavation areas would be removed. Immediately adjacent vegetation may also be compromised depending on its proximity and size. A single remnant naturally occurring tree identified in the north east corner of the site is likely to be located within or immediately adjacent Remediation Zone 7 and may therefore be removed to allow remediation to take place. Off road transport corridors and operational areas will be located to minimise destruction of mature plantings. The area of regrowth vegetation on undisturbed ground on the western boundary of the Site is not contaminated and will be protected from disturbance during the remediation works. The bank of clay fill about 4 m high on the eastern side of the regrowth vegetation will be excavated and reinstated during the remediation works. Any vegetation that has colonised this bank would be removed. Given the disturbed nature of and general lack of vegetation over the formerly developed part of the site, it is considered that:

• the remediation area does not support significant flora or fauna species; • the remediation works would not have a significant adverse impact on biodiversity;

and • the remediation works project would not significantly impact threatened species,

communities or habitats.

9.5 Heritage

There are no items on the Site that are listed by local government, state government of the National Estate Register as being of heritage significance. A due diligence assessment of aboriginal cultural heritage for the site by AECOM is contained in Appendix N . The assessment was based on a desktop review and of relevant data and archaeological survey reports for the project area and field inspection and mapping with reference to applicable DECCW (2009) guidelines. Information regarding the location and nature of Aboriginal objects/sites in the project area was obtained from:

• review of existing Aboriginal Heritage Information Management System (AHIMS) data for the Villawood project area;

• review of past archaeological survey reports for the project area; and

• review of aerial photography for the site dating from the early 1940s to the present. Previously recorded Aboriginal archaeological sites within 10 kms of the site were adjacent to the Georges River and the Duck River. No aboriginal archaeological sites were recorded within the remediation Site. A detailed assessment of the nearby Villawood Detention Centre in 2005 also failed to identify archaeological sites or areas of Aboriginal cultural heritage sensitivity. No aboriginal archaeological objects or sites were identified within the proposed remediation work locations during the field inspection. Contingency plans in the case that objects or remains of aboriginal cultural heritage are found during the remediation works are contained in Appendix N .



February 2011 9-5

9.6 Land Use and Services

The proposed project involves remediation of land in an established area of light industrial landuse. The proposed project is permissible in the zone and the end use is considered to be appropriate and efficient use of the land. On completion the land would be returned to industrial use. Potential impacts on surrounding landuses have been considered under Social Impacts above. Given the temporary nature of the proposed project and return of the remediated land to industrial landuse, the proposal is not expected to have significant adverse impact on surrounding landuses. The proposal would generate extra demand for potable and industrial water, power and gas during the construction and operational phases of the project. Demand for additional water and power would be small and would not interfere with the supply of these services to other users. Demand for gas would be large but within the capacity of the gas mains currently serving the area.



February 2011 10-1

10 STATEMENT OF COMMITMENTS

10.1 Introduction

In accordance with the Director-General’s requirements issued under Part 3A of the EP&A Act, the following draft Statement of Commitments (SoC) is provided. The SoC is in a draft form because it anticipates that it will be possible to comply with the DoP’s conditions of consent and the DCCW’s EPL for the project. The draft SoC states Orica’s environmental commitments and details on the environmental management and monitoring of the proposed project during its construction and operational activities. Orica commits to the preparation and implementation of the environmental management and monitoring plans and environmental mitigation measures detailed in the draft SoC for the proposed remediation works as detailed below.

10.2 Statement of Commitments

The SoC prepared in respect of the proposed remediation of the Villawood Site has been compiled on an issues basis and is informed by the issues prioritisation and impact assessment undertaken as part of this EA. The SoC has been written in a format which can be incorporated into any project approval issued to act as the conditions of that approval. Table 110-1: Statement of Commitments

Environmental Issue

Commitment

Statutory Requirements

1 Prior to the issue of an Environment Protection Licence (EPL) for the project, DECCW shall be provided with sufficient and appropriate documentation for a Technology Assessment to be undertaken by the DECCW in accordance with the National Protocol Approval/Licensing of Technologies for the Treatment/Disposal of Schedule X Wastes and the National Protocol Approval/Licensing of Commercial-Scale Facilities for the Treatment/Disposal of Schedule X Wastes. Orica shall construct and operate the development generally in accordance with the specification outlined in the Technology Assessment document provided to the DECCW, unless otherwise agreed by the DECCW. (Note that the TA Is plant specific).

Soil Remediation Requirements

2 Materials shall only be processed through the DTD Plant where those materials have matrices, contaminant constituents and contaminant concentrations which have been proven as acceptable for processing during Commissioning and Proof of Performance (CPoP) trials.

• Orica shall manage all materials and wastes containing Scheduled Chemical Waste (SCW) and Polychlorinated Biphenyls (PCBs) in accordance with the applicable Chemical Control Orders, or in accordance with a licence under the Environmentally Hazardous Chemicals Act 1985.(Note : dioxins and furans and PCBs are not compounds of concern from the site).



February 2011 10-2

Environmental Issue

Commitment

3 Orica shall treat all materials on the site that do not meet the Remediation Goals detailed in the Remedial Action Plan (RAP), and any scheduled wastes generated by the treatment process until the materials / wastes meet:

• A statistical average dioxin, furan and dioxin-like PCB WHO-TWQ of less than 1 µg/kg;

• An aggregate concentration of SCW constituents of less than 2 mg/kg;

• A PCB concentration of less than 2 mg/kg; and

• The Remediation Goals specified in the RAP.

Note : If the treatment criteria in the DGRs cannot be practically achieved due to technical or economic limitations, an alternative best practice standard would be proposed to DECCW for their approval.

Note : dioxins and furans and PCBs are not compounds of concern from the site.

Air Quality 4 Plant associated with the remediation works shall be selected and operated so that stack emissions are below the maximum allowable emission concentrations discussed in Section 8.3 of the Environmental Assessment (EA), or if that is not possible to an agreed best practice standard.

5 The application of best practice to minimise emissions to the maximum extent practicable, however low concentrations may be, will include:

• Excavating only one remediation areas at any time;

• Excavating at a slow rate;

• Minimising the exposed surface of contaminated soil during excavation;

• Covering exposed surfaces of contaminated soil at the end of each day;

• Minimising stockpiles of excavated contaminated soil;

• Covering loads during transport of contaminated soil;

• Undertaking pre-treatment of contaminated soil in an enclosure with an emission control system;

• Operating the emission control system noted above to minimize emissions from the building;

• Treating the contaminants in a plant with a high inherent destruction efficiency; and

• Operating the emission control system of the plant to maximise destruction efficiency of contaminants.



February 2011 10-3

Environmental Issue

Commitment

6 Feed soil preparation activities including crushing, screening and mixing shall be completely enclosed within the Feed Soil Building (FSB).

7 Orica shall design, construct, operate and maintain a ventilation system for the FSB so that air flow is drawn into the buildings and discharged via the emission control systems.

8 The thermal oxidiser (being the major piece of emission control equipment) shall be designed to meet the requirements of best practice in terms of destruction efficiency and stack emissions.

9 Air monitoring/air discharge point sources for monitoring will include the:

• DTD Plant exhaust stack; and

• FSB emission control system stack.

10 Orica shall prepare and submit a Commissioning and Proof of Performance (CPoP) Plan to DECCW for approval prior to commencing Operations on the site. The CPoP Plan shall provide a program to quantitatively confirm that that facility will meet the environmental performance described in the EA.

11 On approval of the DECCW Orica shall undertake CPoP trials in accordance with the approved CPoP Plan.

12 During CPoP trials, Orica shall undertake monitoring of parameters and compounds for sources below as required and within 28 days of completion of the commissioning trials shall submit a report DECCW analysing the results of monitoring during the commissioning trials and providing justification for the maximum concentration limits and reference conditions that will apply to the operation of the project.

• Monitoring of FSB and DTD Plant and emission control system components for specified flows, pressures and temperatures;

• Continuous monitoring of the FSB emission control system for parameters such as relative humidity, pressure, temperature and volatile organic compounds (VOCs);

• Continuous monitoring of the DTD Plant stack for flow rate, temperature, oxygen, oxides of nitrogen (NOx) and carbon monoxide (CO) concentrations (CO provides feedback on the efficiency of combustion in the thermal oxidiser); and

• Periodic discrete sampling of the FSB and DTD stacks for a range of combustion pollutants and/or contaminants.



February 2011 10-4

Environmental Issue

Commitment

13 During operation of the project, a monitoring program shall be designed for each of the FSB and DTD emission control systems and stacks. The monitoring programs shall include the parameters outlined above in Commitment 12.

14 The treatment plant stacks shall be fitted with sampling port(s) in accordance with the relevant Australian Standard and safe access provided for stack sampling.

15 An ambient monitoring program shall be conducted to monitor fugitive emissions from the treatment plant and open excavations to ensure that all site emissions limits are complied with.

16 Orica shall design, construct, commission, operate and maintain the DTD Plant to ensure that concentration of pollutants do not exceed maximum allowable discharge concentration limit specified in the EPL.

17 Orica shall design, construct, operate and maintain all stacks associated with the project in accordance with detail provided in this EA as well as good engineering practice in order to minimise the effects of stack tip downwash and building wake effects on ground-level air pollutant concentrations.

18 Orica shall not permit any offensive odour to be emitted from the remediation works beyond the boundary of the site, as defined under section 129 of the Protection of the Environment Operations Act 1997.

19 Orica shall design, construct, commission, operate, maintain and decommission the project in a manner that minimises or prevents dust emissions from the Site. Orica shall seek to ensure that the system is designed such that there are no visible dust emissions from the Site.

20 A Construction Environmental Management Plan (CEMP) shall be prepared in respect of the proposed remediation works detailing mitigation measures to be implemented during the construction period including:

• Access to the Site via existing sealed roadways only;

• Water (or other appropriate control measure) shall be used to suppress particles potentially generated during the erection of boundary fences, barriers and screens;

• Land clearing activities shall be controlled using water suppression where necessary;

• Areas of disturbed soil shall be minimised during the construction period;

• Water (or other appropriate control measure) shall be used to suppress dust emissions during dry windy periods (as required);

• The height from which dust generating material is dropped shall be minimised;



February 2011 10-5

Environmental Issue

Commitment

• Loaded trucks carrying contaminated materials shall be covered at all times;

• The cutting/grinding of materials on site shall be kept to a minimum. Where cutting or grinding is necessary equipment and techniques to minimise dust will be used;

• Soil stockpiles shall be treated with surface binding agents or sealed by seeding or surfacing with vegetation or covered with secured tarpaulins or other suitable material;

• Heavily used areas shall be covered, sealed or paved;

• Paved areas shall be swept when necessary using a vacuum sweeper;

• Wheels of site plant and vehicles shall be cleaned to minimise the spread of mud onto surrounding roads;

• Exhaust emissions from mobile plant shall not discharge straight at the ground;

• Construction plant and vehicles will be well maintained and regularly serviced. Visible smoke from plant should be avoided. Defective plant will not be used;

• Engines shall be switched off when vehicles are not in use and refuelling areas will be away from areas of public access; and

• Loading and unloading shall take place within the Site.

21 Waste removed from site will be disposed to an appropriately licensed waste facility.



February 2011 10-6

Environmental Issue

Commitment

Noise 22 The DTD Plant and associated plant shall be sourced / designed with the objective of achieving the noise goals set out in Orica’s EPL. The following general mitigation measures shall be considered in the detailed design of the plant in order to achieve the required noise reductions.

• Plant layout and orientation shall be designed to minimise noise impacts.

• ECS and DTD Plant fans to incorporate silencers and enclosures to achieve appropriate noise reductions. Specifically, an acoustic enclosure or silencer will be required on the DTD Plant fan as dictated by the Noise Modelling Assessment (Appendix J ).

• Solid barriers shall be incorporated, wherever reasonably practicable at noise sources at a height.

• Plant items shall be located at lower heights where reasonably practicable such that noise shielding from the FSB is maximised.

• A flexible connection may be used between the fan and ductwork in the DTD Plant stack. The connection may be encased to control break out noise.

• Ductwork, including the stacks shall be acoustically lagged if required. This shall be confirmed with measurement once operational and lagging retrofitted if needed.

Note: Details of the above measures and noise reductions achieved shall be provided to the Department of Planning (DoP) during the detailed design stage of the project.

23 Orica shall prepare a Noise and Vibration Management Plan (NVMP) in respect of the project addressing the following:

• Appropriate noise monitoring program for the project including details of periodic noise and vibration testing to be undertaken during activities deemed likely to generate high noise and vibration levels;

• Management of vibration during any use of piling rig and roller;

• Notification to all those impacted by works likely to cause excessive vibration and noise (e.g. if sheet piling is required); and

• Provision of a 24 hour community hotline to allow the local community to register complaints regarding noise at the Site.



February 2011 10-7

Environmental Issue

Commitment

24 Orica shall ensure that works on the Site are carried out in accordance with the following:

• All excavation operations shall be undertaken between the hours of 7.00am and 7.00pm from Monday to Saturday;

• All other works including stockpile management, maintenance of drainage and environmental control measures, and the maintenance of haul roads will be undertaken between the hours of 7.00am and 7.00pm from Monday to Saturday, unless prior approval has been granted by BCC;

• Operations undertaken within the FSB (screening, crushing, blending of stockpiled materials and feeding material to the DTD Plant) and the operation of the DTD Plant and FSB ECS may be undertaken 24 hours per day, seven days per week;

• All equipment and plant used on-site will be maintained in good order in accordance with manufacturers recommendations; and

• All construction vehicles will enter and exit the Site in accordance with the Site entry controls specified in the EA and RAP prepared for the project.

Social 25 An ongoing consultation program will be undertaken with the local community for the duration of the project. A Community Liaison Plan will be prepared for the project including the following key components;

• A record shall be prepared identifying all key stakeholders in the proposed remediation works. Over the course of the project, the record shall be updated regularly and will be used to document communications with key stakeholders and interested parties.

• Appropriate communications tools will be used to distribute information to identified stakeholders prior to establishment of works at the Site. The tools shall contain information relating to the proposed remediation works, a project program showing the anticipated duration of works, opportunities for key stakeholder participation and contact details for more information.

• Regular meetings, focusing solely on the remediation of the site, will be held to disseminate information on the progress of the works including information on incidents, issues and operational conditions, and be attended by technical specialists, where necessary, to address any specific concerns or issues that may arise. These meetings will be open for anyone to attend.



February 2011 10-8

Environmental Issue

Commitment

• Newsletters shall be prepared and distributed to key stakeholders to communicate project information. The newsletters shall provide an avenue for communicating specific information on the progress of the remediation works where appropriate. Feedback on the information shall be collected via the consultation methods described above.

• A dedicated 24-hour 1800 telephone number/service shall be established to answer queries on the project and to receive comments and shall be available throughout the duration of the project.

• A notice board shall be posted at the main site entrance containing information about the project and contact details.

Traffic 26 A Traffic Management Plan (TMP) shall be prepared for the project prior to site establishment and construction. The TMP shall include:

• The use of existing workforce car parking and heavy vehicle unloading areas within the Site;

• Designated haulage routes within the site for heavy vehicle movements;

• Designated haulage routes within the BCC LGA; and

• Compliance with designated speed limits and load limits specified for heavy vehicle routes.

Water and Soils 27 Orica shall apply all practicable measures to reduce the quantity of dirty water, and the concentration of contaminants contained in dirty water, produced as a result of site establishment, construction, operation and decommissioning works for the project.

28 Orica shall take all practicable measures to:

• Minimise soil erosion and the discharge of sediments and pollutants from the Site; and

• Reduce both the concentration of contaminants contained in dirty water and the total quantity of dirty water produced as a result of site establishment, construction, operation and decommissioning works for the project.



February 2011 10-9

Environmental Issue

Commitment

29 In relation to the management of the water cycle on the Site, Orica shall implement measures designed to ensure that:

• Stormwater from contaminated areas within the Site is transferred to the on-site water treatment plant associated with the project and is not permitted to contaminate clean areas of the Site;

• All contaminated water within the Site is collected and treated in an on-site water treatment plant, or disposed of off-site to a wastewater treatment facility lawfully permitted to accept such waste;

• Only uncontaminated rainwater would be permitted to flow to stormwater drains; and

• Water to be reused on the Site meets the criteria specified in the Environmental Management Plan developed in accordance with Commitment 43.

30 Orica shall ensure that material that is to be stockpiled on site is stabilised to prevent contamination, erosion or dispersal of the material.

31 With respect to the reuse of wastewater Orica shall ensure that:

• Wastewater/effluent is applied to the Site strictly in accordance with an approved Environmental Management Plan (EMP) as described in Commitment 43 with respect to water volumes, quantities and application areas;

• Reuse of contaminated water/effluent on site meets the requirements of NSW Health and WorkCover NSW as relevant;

• Contaminated water/effluent to be reused on site is tested and verified as safe for site workers and local residents, and will not contaminate clean areas.

32 In the event that wastewater from the Site is to be discharged to sewer, Orica shall establish a (or modify an existing) Trade Waste Agreement with Sydney Water Corporation, which will regulate the allowable wastewater discharges.

Hazards and Risks 33 Prior to the commencement of commissioning of the treatment plant (DTD Plant) as part of the Technology Assessment, Orica shall submit to the Director-General a full description of the treatment process, together with process flow diagrams and other relevant information at various points in the process, such as temperatures, pressures, flow rates and contaminants with their physical state.



February 2011 10-10

Environmental Issue

Commitment

34 Prior to the commencement of commissioning of the development, in accordance with an approved CPoP Program, the following documents will be prepared:

• an Emergency Plan for the development. The Plan shall be prepared in accordance with the Department’s publication Hazardous Industry Planning Advisory Paper No. 1 – Industry Emergency Planning Guidelines. The Plan shall be developed in consultation with relevant emergency services, community, neighbours and the DECCW;

• a Safety Management System, covering all parts of the project and any associated transport activities involving hazardous materials. The System shall clearly specify all safety-related procedures, responsibilities and policies, along with details of mechanisms for ensuring adherence to safety procedures. The System shall be developed in accordance with the Department’s publication Hazardous Industry Planning Advisory Paper No. 9 – Safety Management.

35 Orica shall successfully rehearse the Emergency Plan referred to under Commitment 34 of this Statement of Commitments on at least one occasion during the commissioning of the treatment plant or proof of performance trials. The rehearsal shall include a simulated response to a full-scale emergency at the development and shall involve relevant key stakeholders.

36 Prior to site establishment, appropriate Occupational Health and Safety (OH&S) and planning activities will be completed, documented and approved, where necessary. These activities include:

• Verifying the OH&S training of all employees and subcontractors scheduled to work at the Site;

• Medical examinations for all employees and subcontractors who are to work at the Site and are exposed to contamination;

• Documented attendance at an on-site safety induction briefing for all employees and subcontractors scheduled to work at the Site;

• Appointment of a Site Safety Officer (SSO);

• Provision of first aid and medical facilities and supplies at the Site;

• The procurement, provision and training in the use of PPE detailed in the OH&S Plan and works procedures;

• Completion of all quality assurance (QA) and maintenance checks on all electrical equipment, plant and tools to be used at the Site at the commencement of works. Scheduled ongoing checks will be performed on all plant and equipment brought on-site;



February 2011 10-11

Environmental Issue

Commitment

• Installation of decontamination units at the specified areas on the Site, as detailed in the OH&S Plan and the design drawings; and

• All activities required to provide a safe and healthy work environment for all personnel who work or visit the Site.

37 Prior to site establishment, WorkCover NSW shall be notified of the proposed commencement date for site works. WorkCover will be provided a copy of the OH&S Plan.

38 Prior to the commencement of construction on the Site, the following studies shall be prepared:

• a Fire Safety Study for the project, covering all aspects detailed in the Department’s publication Hazardous Industry Planning Advisory Paper No. 2 – Fire Safety Guidelines and the NSW Government’s Best Practice Guidelines for Contaminated Water Retention and Treatment Systems. The Study shall include a strict maintenance schedule for essential services and other safety measures. The Study shall be submitted for the approval of the Commissioner of the NSW Fire Brigades prior to submission to the Director-General;

• a Hazard and Operability Study (HAZOP) and Control Hazard and Operability Study (CHAZOP) of the project chaired by an independent, qualified person or team. The independent person or team shall be approved by the Director-General. The Study shall be carried out in accordance with the Department’s publication Hazardous Industry Planning Advisory Paper No 8 – HAZOP Guidelines;

• a Construction Safety Study for the project, prepared in accordance with the Department’s Hazardous Industry Planning Advisory Paper No. 7 – Construction Safety Standards.

39 The construction and operation of the proposed project shall be undertaken using an appropriate OH&SP for construction workers on the Site as well as long-term employees at the facility. The plan shall include the preparation of safe work method statements to address specific activities as outlined within the Preliminary Hazard Analysis (PHA) prepared for the proposal.

Completion of Works

40 Orica shall engage an independent site auditor accredited under the Contaminated Land Management Act 1997 to endorse the RAP and for the duration of the remediation of the site, ultimately providing ‘sign-off’ for the site audit statement.



February 2011 10-12

Environmental Issue

Commitment

Environmental Management

41 Standard operating procedures (SOPs) shall be developed for all plant items relating to the development, including but not limited to procedures for the handling of contaminated soils, operation of major process units and operation of pollution control equipment. The SOPs shall identify critical operating parameters for each item of plant, identifying appropriate operating levels for each parameter and indicating how these parameters will be monitored. Subject to confidentiality, copies of the Procedures shall be made available for inspection by the Director-General, the DECCW and the community on request.

42 Operation of the development shall be conducted strictly in accordance with the SOPs referred to in Commitment 41 at all times. SOPs shall be updated to reflect significant changes to operations that may occur from time to time. Orica shall periodically notify the Director-General and the DECCW of any update of the SOPs, indicating the scope and nature of the update.

Environmental Management Plans

43 Prior to the commencement of site preparation or construction works on the Site, an EMP shall be prepared to identify key issues and to provide a management strategy to effectively manage the environment for the duration of the project and the remediation activities considered to potentially have an adverse impact on the environment. The EMP will address the following key issues:

• Surface water management;

• Management of water in excavations;

• Air quality management including dust, gaseous emissions and odours;

• Noise management;

• Vibration;

• Waste management;

• Equipment operation; and

• Traffic control.

Environmental Reporting

44 Orica shall notify the DECCW and the Director-General of any environmental incident occurring during the project with actual or potential significant off-site impacts on people or the biophysical environment as soon as practicable after becoming aware of the incident. Orica shall provide full written details of the incident to the DECCW and the Director-General within seven days of the date on which the incident occurred. Orica shall make a copy of the report available for public inspection on request.



February 2011 10-13

Environmental Issue

Commitment

45 If Orica identifies, through monitoring or otherwise, an exceedance of environmental or safety limits specified in this SoC or the EPL for the Site, Orica will take all necessary steps to cease and prevent the recurrence of the exceedance (subject to safe shutdown procedures). Unless the exceedance can be rectified within a reasonable period of time, Orica shall notify the Director-General and the DECCW of the cause of the required shutdown and identify additional measures to be applied to address the cause of the exceedance and identify additional measures to be applied to address the cause.

46 Orica shall, throughout the life of the project, prepare and submit to the Director-General and the DECCW, a Monthly Performance Report. The Report shall review the performance of the development against the relevant requirements set out in this SoC and the EPL and shall include:

• All monitoring data collected for the development during the month;

• A copy of the complaints register for the month and how these complaints were addressed and resolved;

• Identification of any non-compliance with the conditions of approval or the EPL; and

• Details of additional measures to be implemented to address any non-compliance with the conditions of approval or the EPL.



October 2010 11-1

11 RESIDUAL RISK ANALYSIS

11.1 Approach

The Residual Risk Analysis for the proposed project is based on a process adapted from Australian Standard AS 4369:1999 Risk Management, as well as environmental risk tools developed by other organisations. The process is qualitative and is based on the Residual Risk Matrix shown in Table 11-1. Residual Environmental Risk is assessed on the basis of the significance of environmental effects of the proposed project and the ability to confidently manage those effects to minimise harm to the environment. The significance of environmental effects is given a numerical value between 1 and 5 based on the receiving environment, the level of understanding of the type and extent of impacts, and community response to the environmental consequences of the project. This enables both the actual and perceived impacts to be considered. The manageability of environmental effects is similarly given a numerical value between 1 and 5 based on the complexity of mitigation measures, the known level of performance of the safeguards proposed, and the opportunity for adaptive management. The numerical value allocated for each issue is based upon the following considerations:

Significance of Effects

5. Extreme

Undisturbed receiving environment; type or extent of impacts unknown; substantial community concern.

4. High

Sensitive receiving environment; type or extent of impacts not well understood; high level of community concern.

3. Moderate

Resilient receiving environment; type and extent of impacts understood; community interest.

2. Minor

Disturbed receiving environment; type and extent of impacts well understood; some local community interest.

1. Low

Degraded receiving environment; type and extent of impacts fully understood; uncontroversial project.



October 2010 11-2

Manageability of Effects

5. Complex Complicated array of mitigation measures required; safeguards or technology are

unproven; adaptive management in appropriate. 4. Substantial Significant mix of mitigation measures required; limited evidence of effectiveness of

safeguards; adaptive management feasible. 3. Straightforward Straightforward range of mitigation measures required; past performance of

safeguards is understood; adaptive management easily applied. 2. Standard Simple suite of mitigation measures required; substantial track record of effectiveness

of safeguards; adaptive management unlikely to be required. 1. Minimal Little or no mitigation measures required; safeguards are standard practice; adaptive

management not required, The numbers are added together to provide a result which provides a ranking of potential residual effects of the project when the safeguards identified in this EA are implemented. Table 11-1 demonstrates the Residual Risk Matrix. Table 11-1: Residual Risk Matrix

Manageability of Effects Significance

of

Effects 5

Complex

4

Substantial

3

Straightforward

2

Standard

1

Minimal

1

Low

6 (Medium)

5 (Low/Medium)

4 (Low/Medium)

3 (Low)

2 (Low)

2

Minor

7 (High/Medium)

6 (Medium)

5 (Low/Medium)

4 (Low/Medium)

3 (Low)

3

Moderate

8 (High/Medium)

7 (High/Medium)

6 (Medium)

5 (Low/Medium)

4 (Low/Medium)

4

High

9 (High)

8 (High/Medium)

7 (High/Medium)

6 (Medium)

5 (Low/Medium)

5

Extreme

10 (High)

9 (High)

8 (High/Medium)

7 (High/Medium)

6

(Medium)



October 2010 11-3

11.2 Analysis

The analysis of residual environmental risk for issues related to the proposed project is shown in Table 11-2 . This analysis indicates the environmental risk profile for the proposed project based on the assessment of environmental effects, the identification of appropriate safeguards, and the SoC shown in this EA. Table 11-2: Risk Profile

Issue Significance Manageability Residual Risk

Air Quality 3 3 Medium (6)

Noise and Vibration 2 3 Low/Medium (5)

Social 2 2 Low/Medium (4)

Land Use 1 2 Low (3)

Traffic 2 2 Low/Medium (4)

Water 2 3 Low/Medium (5)

Soil 2 3 Low/Medium (5)

Hazard and Risk 2 3 Low/Medium (5)

Flora and Fauna 1 1 Low (2)

Heritage 1 1 Low (2)

Visual 1 2 Low (3)

Economic 1 1 Low (2) The above residual risk analysis indicates that the proposed remediation facility presents an overall low to medium risk in relation to each of the identified environmental issues, provided that the recommended mitigation measures are implemented. Whilst there are some low to medium residual risks associated with the project, the risks associated with not undertaking the project and leaving the land in its contaminated state are considered to far outweigh potential risks associated with the remediation works.



February 2011 12-1

12 PROPOSAL JUSTIFICATION AND CONCLUSION

The proposed remediation would provide numerous benefits associated with the destruction of contaminants from the Site. Substantial environmental benefits would result from the remediation, as well as numerous social and economic benefits including the cleanup of contaminated material, and the return of the site to a productive use, compatible with the commercial/industrial zoning. The proposal would therefore have resultant benefits for the local and wider community and the environment, as well as for present and future generations. These benefits can be maximised through a careful consideration of the principles of ESD in all aspects of the remediation project, in particular the detailed design of the plant. As such, Orica is committed to a meaningful consideration of the full range of environmental values and outcomes in relation to the project, including both the direct outcomes in terms of the removal and destruction of contaminants from soil, emission of contaminants to air, and the less direct outcomes such as implications for broader environmental issues such as climate change through the emission of greenhouse gas. Orica acknowledges that the best outcome for the project is one which strikes a delicate balance between all relevant environmental values consistent with the underlying principles of ESD.

12.1 Project Justification

The Director-General’s EARs issued for this project require justification for the project to be provided, having regard to biophysical, economic and social considerations together with the principles of ESD. The environmental impact assessment of the proposal undertaken in this EA, and in particular in Sections 8 and 9 has addressed biophysical, economic and social considerations.

12.1.1 Biophysical

The potential for biophysical impacts associated with the proposed project has been assessed in Section 8 of this EA and includes examination of the following impacts seen to be of key significance to the proposal:

• Air quality;

• Water quality; and

• Soils. An air quality assessment was undertaken in respect of the proposed works, which concluded that the works would not result in a significant increase in emissions from the Site. While there is currently no unacceptable risk to human health from the abovementioned emissions, the remediation works would result in the removal of the existing contaminants which are the source of the emissions from the soil. The proposal would therefore result in a direct improvement in air quality to off-site residential and recreational receivers, and off-site industrial workers associated with emissions from the Site. However, the proposed remediation works could potentially result in other types of emissions on the Site, including:

• Dust during earthworks; and

• Emissions from the DTD Plant.



February 2011 12-2

As described in Section 5 and 8.3 of this EA, earthworks associated with remediation are not considered to dramatically increase dust emissions as a result. Emissions from the DTD Plant are also assessed in detail in Section 8.3 of the EA and were predicted generally to comply with relevant standards and would not result in significant environmental harm or unacceptable human health risk. It is important however, to consider the relationship between destruction of organics in the soil and the potential for volatilisation of mercury and its subsequent emission to air. A key consideration in determining the final operating temperature of the rotary dryer, will be the balance between the destruction of organics and the volatilisation of mercury, as well as the volume of greenhouse gases produced, which increases with increasing soil treatment temperature in the rotary dryer. A similar situation exists for the thermal oxidiser. Orica will review these issues in the Technology Assessment for the project, and consider how to balance these competing factors in determining the operating parameters for the plant. The project has the potential to result in impacts on water quality through the transfer of contaminants to both the surface and groundwater during excavation of the contaminated material from the Site. Similarly with soils, the potential exists for the transfer of contaminants to soils surrounding the Site through sedimentation and erosion during excavation. Provided the environmental safeguards outlined in Section 8.1 and 8.2 are implemented, there are not expected to be residual impacts associated with water quality and soils. The proposed works would ultimately remove a potential source for water and soil contamination, consequently preventing future ongoing contamination. The assessment of the impact of the proposed project on each of the biophysical elements of the environment has concluded that, provided identified management measures and monitoring systems are implemented to mitigate potential impacts, the proposed works would not have a significant impact on the biophysical environment. As required by the Director-General’s EARs for the project, environmental mitigation, management and monitoring requirements have been compiled and summarised into a SoC, which is provided as Section 10 of this EA. The project is therefore justifiable in terms of the biophysical elements of the environment.

12.1.2 Economic

The economic impacts of the proposed works are largely related to employment generation and the return of the land to productive use. The construction phase of the project is likely to generate in the order of 45 jobs, whilst the remediation works would require 25 to 30 additional employees, with subsequent direct and indirect benefits for the local economy. The proposed remediation works would allow the Site to be returned to productive use such as future redevelopment for industrial purposes, thus representing orderly and efficient use of the land. Given these benefits, the proposed project is justifiable on economic grounds.



February 2011 12-3

12.1.3 Social

The potential social impacts of the proposed works have been assessed in Section 9.1 of this EA, and include consideration of a wide range of issues, including the following key issues:

• Noise; and

• Hazards and risk. Other social or cultural issues assessed as part of this EA include impacts on visual amenity heritage, land use and traffic. A number of these issues interrelate with the biophysical and economic impacts of the project, where, as described above, it has been concluded that the project would not have a significant impact provided identified mitigation measures are implemented, and that the proposal is justifiable on biophysical and economic grounds. The noise impact assessment undertaken in respect of the proposal indicates that the proposed works are not likely to result in significant impacts, provided appropriate mitigation measures are implemented. Mitigation measures such as fitting silencers to plant equipment can result in significant acoustic reductions which would ensure that any impacts are not significant. Further, the community would be kept informed of significant noise events and when they might occur throughout the duration of the project such that the impacts of the events are minimised. A PHA and HHIA have been undertaken in respect of the proposal and conclude that the works represent a low risk in terms of hazards and do not pose an unacceptable risk to human health. Further, the removal of the contaminants existing on the Site would have significant benefits to the local and wider community through the further reduction of risk due to hazard and harm to the surrounding environment. The proposed works are therefore not considered to have significant adverse impacts with respect to social impacts on the community, provided design and management measures are implemented in accordance with the SoC. The project is therefore justifiable on social grounds.

12.2 Ecologically Sustainable Development

The term ‘ecologically sustainable development’ (ESD) was introduced by the Commonwealth Government in June 1990 and is defined as:

‘Using, conserving and enhancing the community’s resources so that ecological processes, on which life depends, are maintained, and the total quality of life, now and in the future, can be increased. (ref: Ecologically Sustainable Development: A Commonwealth Discussion Paper)’

ESD Working Groups were subsequently established and involved representatives of government, industry, environment, union, welfare and consumer groups. The ESD Working Groups developed a series of policy directions and recommendations which provided the foundation for development of the National Strategy for Ecologically Sustainable Development. The National Strategy for Ecologically Sustainable Development was endorsed by the Council of Australian Governments in December 1992. In addition, the Intergovernmental Agreement on the Environment (IGAE) was signed in 1992 by Federal and State Governments, Territories and the Australian Local Government Association, promoting intergovernmental cooperation.



February 2011 12-4

ESD is a concept now firmly entrenched in NSW environmental legislation and government policy. The concept of ESD has been given legal definition in NSW by the Protection of the Environment Administration Act 1991 (NSW). Section 6(1)(a) of that Act requires the DECCW which was established by the Act, in its role in protecting, restoring and enhancing the quality of the environment in NSW, to have regard to the need to maintain ESD requiring the effective integration of economic and environmental considerations in decision making processes. Schedule 2 of the EP&A Regulation establishes four guiding principles to assist in achieving ESD, as follows:

• The precautionary principle – namely, that if there are threats of serious or irreversible environmental damage, lack of full scientific certainty should not be used as a reason for postponing measures to prevent environmental degradation.

• Inter-generational equity – namely, that the present generation should ensure that the health, diversity and productivity of the environment is maintained or enhanced for the benefit of future generations.

• Conservation of biological diversity and ecological integrity – namely, that conservation of biological diversity and ecological integrity should be a fundamental consideration.

• Improved valuation and pricing of environmental res ources - namely, that environmental factors should be included in the valuation of assets and services, such as polluter pays, full life cycle costing, and utilising incentive structures/market mechanisms to meet environmental goals.

The EPBC Act also identifies a fifth principle for consideration in environmental impact, namely:

‘Decision making processes should effectively integrate both long term and short term economic, environmental, social and equitable considerations.’

These five principles are interrelated and need to be considered both individually and collectively as part of determining whether or not a project would be consistent with the principles of ESD in Australia.

12.2.1 Precautionary Principle

Orica has taken on board the ‘precautionary principle’ for the proposed remediation works, as represented by the identification and consideration of a range of potential remediation options with the final option selected on the basis of its suitability for the specific remediation requirements of the site, proof of performance and effectiveness, and its potential environmental impacts. The project is for the remediation of contaminated land which would result in environmental improvements not only for the Site itself but also for surrounding areas. Orica’s commitment to this principle is further demonstrated through its ongoing commitment to environmental sustainability in the development of the detailed design of the DTD Plant, where sustainability will be a key consideration in the determination of operating parameters for specific components of the plant such as the thermal oxidiser and the rotary dryer. In the case of these plant components, Orica will be seeking to optimise outcomes for the removal and destruction of contaminants in soil, emissions of toxic pollutants to air and emission of greenhouse gas to air from the combustion of fossil fuel, while complying with the treatment and emission targets of the DECCW and the Stockholm Convention, which it should be noted were developed prior to climate change being recognised as a serious environmental issue.



February 2011 12-5

Further, the identification of potential impacts to the environment through environmental studies undertaken as part of this EA has enabled the proposed project to be designed to minimise significant environmental impacts, and has allowed environmental safeguards to be developed to manage potential impacts.

12.2.2 Intergenerational Equity

The principle of ‘intergenerational equity’ requires that decisions made by the present generation would not result in a degradation of the environment for future generations. Of importance to this principle is the need to consider not only the direct environmental impacts of the proposal, but the less direct and perhaps broader environmental impacts of the proposed remediation works. Whilst many of these are positive, such as the health and environmental benefits of the removal of contaminants, and the return of the land to productive use, equal consideration must be given to the implications of certain aspects of the project, such as those relating to natural resource use and climate change. The proposed works will require the consumption of fossil fuels (largely in the form of natural gas) for the operation of the DTD Plant with subsequent implications in terms of greenhouse gases and climate change. This issue is discussed in greater detail in Section 12.3 of the EA. Balancing outcomes for competing issues of removal and destruction of contaminants and greenhouse gas emissions from the combustion of fossil fuels is important in optimising the overall sustainability of the project and in achieving consistency with the principle of intergenerational equity. Orica is committed to minimising the greenhouse gas emissions from the DTD Plant through the detailed plant design and selection of operating parameters for the rotary dryer and thermal oxidiser. This will be done while considering other, equally important environmental outcomes such as DECCW emission concentration limits and the requirements of the Stockholm Convention, noting that these were developed at a time when greenhouse gas emissions and climate change were not an issue. In consideration of the above, and that the proposed remediation works would result in the destruction of contaminants with subsequent environmental benefits, the project is considered to provide benefits to both present and future generations and meets the principle of ‘intergenerational equity’.

12.2.3 Biological Diversity and Ecological Integrity

The principle of ‘biological diversity and ecological integrity’ requires a full and diverse range of plant and animal species to be maintained and conserved. The potential impacts of the proposed remediation works on flora and fauna has been taken into consideration as part of the EA. Inspection of the Site found the land to be clear of trees with the exception of a naturally occurring tree on the north western fence line that may require removal for the proposal. The area of regrowth vegetation on undisturbed ground on the western boundary of the Site is not contaminated and will be protected from disturbance during the remediation works. Any replanting would be undertaken on completion of the remediation works. The EA of the Site concludes that the remediation areas do not support significant flora or fauna species and that the works would not have a significant adverse impact on biodiversity. The proposed remediation works involve the destruction of contaminants with subsequent benefits for ecological integrity and biodiversity.



February 2011 12-6

12.2.4 Valuation and Pricing of Environmental Resources

The IGAE and POEO Act require improved valuation, pricing and incentive mechanisms to be included in policy making and program implementation. In the context of environmental assessment and management, this would translate to environmental factors being considered in the valuation of assets and services. Integration of environmental and economic goals is a key principle of ESD, which can be measured undertaking a cost-benefit analysis, that is, by measuring the costs of proceeding with a project against the benefits arising from the project. Given the different values placed on different elements of the environment, and the various components of the environment, it is difficult to assign a monetary value against the environmental costs and benefits associated with a project. In recognition of this, the approach adopted for this project is the management of environmental impacts through appropriate safeguards, and to include the cost of implementing recommended safeguards in the total cost of the project. Orica would implement the environmental safeguards outlined in this EA to minimise potential environmental impacts resulting from the proposed remediation works. In addition, Orica is seeking to ensure that equal consideration is given to all relevant environmental outcomes in relation to the project and that, throughout all aspects of the project a balance is achieved between all relevant environmental outcomes, such that no one outcome is achieved at the expense of another. This is of particular relevance in the detailed design of the DTD Plant which must balance treatment and emissions targets for competing contaminants, as well as an overall need to optimise environmental sustainability in the achievement of these outcomes.

12.2.5 Decision Making Process

The proposed project requires approval under Part 3A of the EP&A Act 1979. An assessment of the short, medium and long term impacts of the proposed activity, taking into account the principles of ESD is described in this EA. The SoC provided in Section 10 , forms the environmental mitigation, management and monitoring requirements for the proposed remediation works. The project approval process prescribed under Part 3A of the EP&A Act and subsequent environmental management frameworks ensure that decision making and monitoring of the project would be undertaken in an integrated manner, having regard to relevant issues associated with the project within its context.

12.3 Climate Change and Greenhouse Effect

The Greenhouse Effect involves certain gases, known as greenhouse gases, capturing heat radiated from the earth and re-radiating heat back to the earth. The thermal balance that is known to control earth’s climate is maintained by this mechanism, and is influenced by the steadily increasing concentrations of certain greenhouse gases such as carbon dioxide (CO2), with other greenhouse gases including methane, ozone (O3), NOx and Chloro-fluorocarbons (CFCs).



February 2011 12-7

Anticipated greenhouse emissions for the project based on a preliminary mass and energy balance for the DTD Plant plus emissions from other plant and equipment for the project are:

• CO2 – estimated to be 6,579 tonnes

• CH4 – estimated to be 13 tonnes

• NOx – estimated to be 5.9 tonnes. CO2 emissions from electrical consumption is estimated at a further 400 tonnes. In 2007, Australia’s total greenhouse gas emissions were 597.2 million tonnes (Mt) CO2-e including Article 3.3 land use, land use change and forestry (LULUCF) categories. The estimated 2008 greenhouse gas emissions are 518 Mt CO2-e and show that Australia is on track to meet its Kyoto obligations. This is largely due to a significant reduction in greenhouse emissions associated with land use change. The amount of CO2 estimated to be produced by the proposed remediation facility therefore represents an increase of 0.001% on the total greenhouse gas emissions and as such is considered to be negligible. Further, this increase will be temporary as works on the Site will cease and the Plant will be decommissioned once remediation is complete. Nevertheless, Orica is committed to minimising greenhouse gasses emitted as a result of the remediation project as much as possible through the detailed plant design and selection of final operating parameters for certain components of the plant. Overall, the construction and operation of the proposed upgrade works as a whole is not expected to contribute significant levels of greenhouse gases, and would not therefore have a significant impact on the greenhouse effect.

12.4 Consequences of Not Proceeding

Should the project not proceed, the contaminants contained within the Site would remain with the following potential consequences:

• Further breakdown of contaminants leading to potential release into surrounding soil and groundwater;

• Possible spread of contaminants off-site;

• Legacy of contamination left for future generations; and

• Limited use of prime industrial land. The above consequences are considered serious enough to outweigh the potential residual environmental impacts of the remediation proposal and to justify the proposed works being undertaken.



February 2011 12-8

12.5 Conclusion

The potential impacts of the proposal have been discussed and assessed throughout this EA and mitigation measures have been identified to minimise these potential impacts. In all cases examined, the potential impacts of the proposal are considered to be acceptable provided that appropriate mitigation and management measures are implemented and maintained for the duration of the project. The consequences of not proceeding are identified in Section 12.4 above and are considered serious enough to outweigh the potential residual impacts associated with proceeding with the proposal. The proposal is therefore considered justifiable on biophysical, economic and social grounds and is considered to be consistent with the principles of ESD. The benefits of the project are such that the proposal is considered to be in the interests of the local and wider community and the public in general.



February 2011 13-1

13 REFERENCES

AECOM, 2009. Combined Validation Report, 127 Orchard Road, Chester Hill, NSW. Report S4093317_CombinedReport_14July09.

AECOM, June 2010. Remedial Action Plan, 2 Christina Road Villawood.

AECOM, 18 June 2010. Due Diligence Assessment of Proposed Orica Villawood Remediation Project at 2 Christina Road Villawood, NSW.

AECOM, July 2010. Visual Assessment of Proposed Orica Villawood Remediation Project at 2 Christina Road Villawood, NSW.

A.D. Laase Hydrologic Consulting, June 2007. Groundwater Flow and Contaminant Transport Modelling

American Conference of Governmental Industrial Hygienists, 1992. Threshold Limit Values and Biological Exposure Indices for 1991 – 1992.

ANZECC and NHMRC, 1992. Australian and New Zealand Guidelines for the Assessment and Management of Contaminated Sites.

Australian and New Zealand Environment and Conservation Council (ANZECC), 1994a, National Strategy for the Management of Scheduled Waste.

ANZECC, 1994. National Protocol Approval Licensing of Commercial-scale Facilities for the Treatment/Disposal of Schedule X Wastes, Australian and New Zealand Environment and Conservation Council, Canberra.

ANZECC, 1996a, HCB Waste Management Plan.

ANZECC, 1996b, PCB Management Plan.

ANZECC and the Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ), 2000, Australian and New Zealand Guidelines for Fresh and Marine Water Quality.

Bannerman, S.M., Hazelton, P.A., 1990. Soil Landscapes of Penrith 1: 100,000 Sheet. Soil Conservation Service of NSW, Sydney.

CH2M Hill, 2004. Additional Stage 2 ESA. January 2004

CH2M Hill, 2005a. Conceptual Site Model. Reference 32177. April 2005

CH2M Hill, 2005b. Preliminary Report (Draft Version) Voluntary Investigation - Part 1A – Groundwater and Soil. September 2005

CH2M Hill, 2007a. Pharmaceuticals Site, Villawood under Building Investigation (Reference 359640.T1.02). May 2007

CH2M Hill, 2007b. Validation Report Pharmaceuticals Site, Christina Road, Villawood (Reference 359640.T1.01). June 2007



February 2011 13-2

Contaminated Soil Monograph Series (CSMS), 1991, 1993, 1996 and 1998 and enHealth, 2002. The Health Risk Assessment and Management of Contaminated Sites.

CMJA, 2006. Site Audit, 2 Christina Road, Villawood – Section 4D Audit. Ref: J1196.2R-rev0. August 2006

CT DEP, 2000. Calculating the 95% Upper Confidence Level. Bureau of Water Management. Permitting, Enforcement and Remediation Division. October 5

DECCW, 2007. Guidelines for the Assessment and Management of Groundwater Contamination Department of Environment and Conservation, March.

DECCW, 2008. Waste Classification Guidelines. June.

Department of Mineral Resources (DMR), 1980. A Guide to the Sydney Basin. Ed Chris Herbet. Department of Mineral Resources, Geological Survey of NSW. Bulletin 26.

Doherty, J., 1999. PEST Model-Independent Parameter Estimation. Watermark Numerical Computing, 1st Edition.

Doherty, J., 2004. PEST Model-Independent Parameter Estimation. Watermark Numerical Computing, 5th Edition.

Domenico and Schwartz. 1998. Physical and Chemical Hydrogeology.

ENSR/AECM, July 2007. Environmental Assessment for Remediation of Car Park Waste Encapsulation, Botany Industry Park.

Freeze, R A & Cherry, J A, 1979, Groundwater. Prentice Hall, USA.

GHD, September 2010. Air Health Risk Assessment, Report for Orica Villawood Remediation Project.

HLA, 2005. Phase 1 Remedial Investigation, 2 Christina Road Villawood. Report S4056125_RPTFinal_22Dec05.

HLA, 2006a. Phase 2 Remedial Investigation, 2 Christina Road Villawood. Report S4060632_RPTFinal_30Aug06.

HLA, 2006b. Remedial Technology Assessment (Soil), 2 Christina Road Villawood. Report S4066001_RTA_Final_22Dec06.

HLA, 2006c. Remedial Technology Assessment (Groundwater), 2 Christina Road Villawood. Report S4066001_RTA_Final_22Dec06.

HLA, 2007. Phase 3 Data Gap Investigation, 2 Christina Road, Villawood. Report S4075424_RPTFinal_31May07.

HLA-ENSR, July 2007. Remedial Action Plan, 127 Orchard Road, Chester Hill, NSW 2162. Report S4034508_Final_RAP_July07.

Laase, 2007. Groundwater Flow and Contaminant Transport Modelling. 10 July 2007



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