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INFORMATION REGARDING ENVIRONMENTAL AUDIT REPORTS August 2007 VICTORIA'S AUDIT SYSTEM An environmental audit system has operated in Victoria since 1989. The Environmenf Profecfion Acf 1970 (the Act) provides for the appointment by the Environment Protection Authority (EPA Victoria) of environmental auditors and the conduct of independent, high quality and rigorous environmental audits. An environmental audit is an assessment of the condition of the environment, or the nature and extent of harm (or risk of harm) posed by an industrial process or activity, waste, substance or noise. Environmental audit reports are prepared by EPA- appointed environmental auditors who are highly qualified and skilled individuals. Under the Act, the function of an environmental auditor is to conduct environmental audits and prepare environmental audit reports. Where an environmental audit is conducted to determine the condition of a site or its suitability for certain uses, an environmental auditor may issue either a certificate or statement of environmental audit. A certificate indicates that the auditor is of the opinion that the site is suitable for any beneficial use defined in the Act, whilst a statement indicates that there is some restriction on the use of the site. Any individual or organisation may engage appointed environmental auditors, who generally operate within the environmental consulting sector, to undertake environmental audits. The EPA administers the environmental audit system and ensures its ongoing integrity by assessing auditor applications and ensuring audits are independent and conducted with regard to guidelines issued by EPA. AUDIT FILES STRUCTURE Environmental audit reports are stored digitally by EPA in three parts: the audit report (part A), report appendices (part B) and, where applicable, the certificate or statement of environmental audit and an executive summary (part C). A report may be in colour and black-and-white formats. Generally, only black- and-white documents are text searchable. Report executive summaries, findings and recommendations should be read and relied upon only in the context of the document as a whole, including any appendices and, where applicable, any certificate or statement of environmental audit. AUDIT REPORT CURRENCY Audit reports are based on the conditions encountered and information reviewed at the time of preparation and do not represent any changes that may have occurred since the date of completion. As it is not possible for an audit to present all data that could be of interest to all readers, consideration should be made to any appendices or referenced documentation for further information. When information regarding the condition of a site changes from that at the time an audit report is issued, or where an administrative or computation error is identified, environmental audit reports, certificates and statements may be withdrawn or amended by an environmental auditor. Users are advised to check EPA's website to ensure the currency of the audit document. PDF SEARCHABILITY AND PRINTING EPA Victoria can only certify the accuracy and correctness of the audit report and appendices as presented in the hardcopy format. EPA is not responsible for any issues that arise due to problems with PDF files or printing. Except where PDF normal format is specified, PDF files are scanned and optical character recognised by machine only. Accordingly, while the images are consistent with the scanned original, the searchable hidden text may contain uncorrected recognition errors that can reduce search reliability. Therefore, keyword searches undertaken within the document may not retrieve all references to the queried text. This PDF has been created using the Adobe-approved method for generating Print Optimised Output. To assure proper results, proofs must be printed, rather than viewed on the screen. This PDF is compatible with Adobe Acrobat Reader Version 4.0 or any later version which is downloadable free from Adobe's Website, www.adobe.com. FURTHER I NFORMATION For more information on Victoria's environmental audit system, visit EPA's website or contact EPA's Environmental Audit Unit. Web: www.epa.vic.clov.au/envaudit Email: [email protected] 1 of 48
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Environmental Audit Report - EPA Victoria · FLUOR DANIEL GTI Ill1 I II 111 Ill I Ill Ill STATUTORY ENVIRONMENTAL AUDIT REPORT FORMER HADFIELD PRIMARY SCHOOL, GLENROY, VICTORIA Prepared

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Page 1: Environmental Audit Report - EPA Victoria · FLUOR DANIEL GTI Ill1 I II 111 Ill I Ill Ill STATUTORY ENVIRONMENTAL AUDIT REPORT FORMER HADFIELD PRIMARY SCHOOL, GLENROY, VICTORIA Prepared

INFORMATION REGARDING ENVIRONMENTAL AUDIT REPORTS August 2007

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

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

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

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

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

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

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

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

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

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

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

This PDF has been created using the Adobe-approved method for generating Print Optimised Output. To assure proper results, proofs must be printed, rather than viewed on the screen.

This PDF is compatible with Adobe Acrobat Reader Version 4.0 or any later version which is downloadable free from Adobe's Website, www.adobe.com.

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

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

Email: [email protected]

1 of 48

Page 2: Environmental Audit Report - EPA Victoria · FLUOR DANIEL GTI Ill1 I II 111 Ill I Ill Ill STATUTORY ENVIRONMENTAL AUDIT REPORT FORMER HADFIELD PRIMARY SCHOOL, GLENROY, VICTORIA Prepared

FLUOR DANIEL GTI

Ill1 I II 111 Ill I Ill Ill

STATUTORY ENVIRONMENTAL AUDIT REPORT FORMER HADFIELD PRIMARY SCHOOL, GLENROY, VICTORIA

Prepared for:

R e m Pty Ltd C/- Tartaglia & Associates Pty Ltd

PO Box 156 ASCOTVALE VIC 3032

11 November 1997 Our Ref: M6496

Prepared by:

FLUOR DANIEL GTI (AUSTRALIA) PTY LIMITED

WritterdSubmitted by:

’ yL Peter Mi -b I$

ictoria & Tasmania A Accredited Environmental Auditor (Contaminated Land)

3261 6-1 -A - ..

I

FLUOR DANIEL GTI (AUSTRALIA) PTY. LTD. A.C.N. m 931 057

Email: [email protected] Unit 8, 177 Beavers Road, Northcote Vic. 3070 Australia Telephone: (03) 9482 3266 Fax: (03) 9482 1414

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TABLE OF CONTENTS

1 . INTRODUCTION & BACKGROUND .................................................................................. 1

1.1 Purpose of Audit ............................................................................................................... 2

1.2 Site Descnption ................................................................................................................. 3

1.3 Information Obtained Prior to Engagement of Auditor ................................................... 4

. .

1.4 Background Geology & Hydrogeology ........................................................................... 4

2 . SITE HISTORY & POTENTIAL CONTAMINANT SOURCES & RECEPTORS ........ 6

2.1 Site History ....................................................................................................................... 6

2.2 Potential Contaminant Sources and Types ....................................................................... 6

2.3 i’otential Human and Environmental Receptors of Contamination ................................ 7

3 . ENVIRONMENTAL ASSESSMENT AND RESULTS ....................................................... 8

4 . SCREENING CRITERIA ....................................................................................................... 14

5 . CONCLUSIONS ....................................................................................................................... 16

6 . REFERENCES & STATEMENT OF LIMITATIONS ...................................................... 18

ST.4TEMENT OF EWRONMENTAL AUDIT

APPENDICES

Following Page 18

APPENDIX A .......................................................................... Copies of Certificates of Title

APPENDIX B ..................................................................... FDGTI “Site Observation Form”

APPENDIX C

APPENDIX D

...................................................... Beveridge Williams Report . March 1997

............................................................................. AD1 Report . October 1997

9 FLUOR DANIEL GTI

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1. INTRODUCTION & BACKGROUND

This statutory environmental audit report has been prepared by Fluor Daniel GTI's Mr Peter

Mirkov who is a Victorian Environment Protection Authority (EPA) appointed Environmental

Auditor (Contaminated Land). Mr Mirkov was appointed as Environmental Auditor on the 7th

January 1997 under the Environment Protection Act 1970.

It is understood that Rexrun Pty Ltd are the legal owners of the subject property. The subject

propem consists of nine separate titles as follows:

Volume 71 19, Folio 1423630, Lots 60 to 65 of Subdivision No. 13016, Crown

Portion Two, Parish of Will Will Rook, County of Bourke, Municipality of

Morekind

(3) Volume 7171, Folio 1434104, Lots 66 and 67 of Subdivision No. 13016, Crown

Poriicln Twc.. Parish of Will Will Rook, C o m ~ y of Bourke, Municipaiity of

k i o r e h d 4

(c) '~'ohiie: 7171, Folio 1434105, Lots 68 and 69 of Subdivision No. 13016, Crown

Pwtim Two, P x k h of -Will Will Rook, County of Bourke, h4unicipality of

i \ ; iOX!ad

(d) Volilrne 7171, Fdio 1434103, Lots 70 and 71 of Subdivision No. 13016, Crown

Portioli Two, Parish of Will Will Xook, County of Bourke, Municipality of

Moreimd

Volunie 7171, Folio 1434097, Lots 72 to 74 of Subdivision No. 13016, Crown ' Portion Two, Parish of Will Will Rook, County of Bourke, Municipality of

(e)

Moreland

&I Vollmie 7171, Folio 1434110, Lots 75 and 76 of Subciivisior, No. 13016, Crown

Portion Two, Parish of Will Will Rook, County of Bourke, Municipality of

Moreland

(a, Volume 8102, Folio 085, Lots 77 and 78 of Subdivision No. 13016, Crown

Section 2, Parish of Will Will Rook, County of Bourke, Municipality of Moreland

Our Re$ Mi5496 Page I of I8 I1 November 1997

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(h) Volume 7395, Folio 1478994, Lots 79 to 83 of Subdivision No. 13016, Crown

Portion Two, Parish of Will Will Rook, County of Bourke, Mmicipality of

Moreland

(i) Volume 7171, Fo!io 1434059, Lots 84 to 89 of Subdivision No. 13016, Crown

Portion Two, Parish of Will Will Rook, County of Bourke, Municipality of

Moreland

All titles relating to the former Hadfield Primary School as detailed above are zoned as

Residential C. Copies of all titles are included as Appendix A of this audit report.

1.1 Purpose of Audit

M i Sam Tartaglia of Tartaglia & Associates Pty Ltd, who is acting on behalf of Rexrun Pty Ltd,

in a letter dared 18th July 1997 requested that Mr Mirkov complete a statutory envircinmental

audit of the subject site. The audit was requested to satis@ local authority rcquirenients of the

Municipality of Moreland. The Municipality of Moreland requested that a statutory

environmental audit be completed and a Certificate or Statement of Environmental Audit be

issued prior to them grmtin2 a development approval for the subject property. The proposed

developmeat consists of 30 residential dwellings. as designated by the 3C Lot munbers of

subdivision plm LPI3016, a copy of which is included in Appendix A.

I '

- ..*

. . ,

The audit report under Section 57AA of the EPA Act is required to address:

(a) an evaluation of the environmental quality of the relevait segment of the

environment; and

(3) an assessment of whether any clean up is required to that segment of the

enviroiment; and

. . (c) if any clean up is necessary, any recommendation relating to the canying out of

. thecleanup.

When evaluating the above the audit must have regard to:

(a) any gilidelines issued by the Authority for the purposes of this section; and

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(3) the beneficial uses that may be made of the relevant segment of the environment;

and

(c) any relevant State Environment Protection Policy or Industrial Waste Management

Policy.

Environmental assessments undertaken prior to the engagement of Mr Mirkov as auditor

revealed the presence of various contaminants in site soils that were above background

concentration levels. Rexrun Pty Ltd have requested that an environmental aEdit of the subject

land be undertaken with a view to obtaining a Certificate or Statement of Environmental Audit.

1.2 Site Description

The subject site was inspected by Mr hlirkov on the 5th August 1997. Duing thc inspection of

the site Vir Mirkuv recorded relevant site features on a “Site Oxervatiorr Fozn”. a copy of

which is iiicl~ded as Appendix B of this audit repon. The princip!e findings of the site

inspection were as fob!lms:

(9’ the site is rectanguiar in s k q e and roughly 250 metres by 75 metres in pian area;

.(it) school buildings in the western half of the site were fenced off and were in h e

precess of being demolished. The buiidings comprised a mix ofdmber and brick

s4rt:ctures with steel and ceramic roofs;

(iii) three heating oil underground storage hlks (USTs) were present at !lie site, m e in

the central portion of the site facing Bedford Street, and two others in the central

and western central pzrt of the site. These later two USTs were filled by remote fi!l

points situated along Exeter Street whilst the former was directly filled;

(it9 a footba!! oval was present on the eastern portion of the site, facing East Street;

(v) exposed surfaces were grassed in the football area and around the perimeter of the

fermer school, elsewhere concrete and bitumen pavements were present;

(vi) the site was totally surrounded by residential properties;

Our Ref: MU96

/

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(vii) the site was generally flat;

(viii) there was no visible evidence of mass filling;

The school and all features within it are generally about 40 years old. Other site details are

presented in Appendix B. For ease of reference the site has been divided into three zones as

follows:

Zone 1: oval

Zone 2: UST areas

Zone 3: General School Yard & Buildings

1.3 Information ObtaiHed Prior to Engagement of Auditor

Prior to the engagement of Mr Mirkov as auditor the former site owner (The Department of

Education) had engaged Reveridge Williams & Co Pty Ltd to undertake a ‘-Site History

Assessment” and a “Contamination Assessment” of the subject site. The scope of the work and

the results of both of these investigations are summarised in a report efititied “Contamination . X’

c Assessment, Hadfield Primary School, Exeter Street, Glenroy” dzted March 1997. r? copy of

this report is included as Appendix C of this audit report.

1.4 Backgroud Geology & Hydrogeology

Based on available published geological maps and on information in Appendix C die site is

expected to be underlain by Tertiary aged sedimentary soil (silt, sand and minor gravel) of the

Eocene period which is in turn underlain by interbedded shale, mudstone and greywacke of the

Upper Silurian (Dargile Formation).

Based on Rural Water Corporation Groundwater Bore records obtained from nearby sites it is

expected that groundwater will be present at depths of typically more tha? 6 metres below

ground level. The groundwater is expected to be of a quality unsuitable for drinking, due to

likely salinity in excess of 3,000 mg/litre, but potentially suitable for use in irrigation or stock

watering, although such beneficial uses in an urban environment are considered unlikely. .

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There are no surface water bodies neighbouring the site which could be impacted by either

surficial water discharges from the site or groundwater discharges froin beneath the site.

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2. SITE HISTORY & POTENTIAL CONTAMINANT SOURCES & RECEPTORS

2.1 ' Site History

Based on a historical review of the site as detailed in Appendix C the site history consists of the

follouing:

prior to about 195 1 site was vaczint znd may have been used for general

fanning;

by 1960 primary scliool had been built

by 1979 additional school buildings constructed

by 1988 little change from present

. - 2.2 Potential Contaminant Sources and Types

Based on the background site history and on observations made at the site poteiitial sources of -2 , .- - contamination comprise petroleum hydrocarbons associated with the heating oil USTs: possible

contaqjnants imported within shallow filling at the site and general construction activiQ

associated wid1 ihe school (possible heavy metals in paints, asbestos sheeting etc). The

following are considered potential contaminants:

e metallic elements;

e pi>lyCyC! ic aromatic hydrocarbons (PAHs);

e petrcleum hydrocarbons (IPHs);

volatile petroleum hydrocarbons (BTEX - benzene, toluene, ethyl-benzene &

xylene);

0 oxygenated hydrocarbons;

e fumigants;

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. .

halogenated'aliphatic hydrocarbons;

halogenated aromatic hydrocarbons;

0 organochlorine pesticides; and

PCBs.

\

2.3 Potential Human and Environmental Receptors of Contamination

Based on the gathered background information it is anticipated that exposure to potential

contaminants froin site soils or groundwater may be through:

9 human contact (long term residents) with swficial soils;

0 hiian worker contact (short tenn construction activity) with surficial and ssb-

surface soils or groundwater;

plant andor stock impact through use (animal ingestion or plant imgation) of

groundwater;

vapour impact on human residents oi construction workers and/or uptake of

vapour contaminants by plants; and

0 micro-organisnis and other life matter in soils.

The major receptors at potential risk from site contaminants would thus appear to be:

(i) construction workers and residents who may be in contact with contaminated soils;

(ii) soil vapour hazards which may form into confined spaces; and

(iii) extraction and use of groundwater for irrigation and/or stock watering use.

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,

3. ENVIRONMENTAL ASSESSMENT AND RESULTS

The environmental assessment of the site was undertaken initiaiiy by Beveridge TA‘ikiiiis & Co

Pty Ltd on the 4th March 1997 (see Appendix C) and then by AD1 Limited over the period 20th

August 1997 to 8th October 1997. A copy of the summw of all investigations undertaken by

AD1 is included in Appendix D.

The initial investigations undertaken by Beveridge Williams & Co Pty Ltd included a site

history assessment and sampling of soils at 10 specified locations; one in the oval: three around

the school yard and six around the USTs. Samples from these ten locations were taken at near

surface levels (typically 0.2-0.3 metres) and at 0.5-1.0 metre depths. Fourteen samples from

these ten locations were selectively analysed for a “full EPA screen” and consisted of:

Our Re$ M6496

pi-1

Sulphate

Total Cyanide

Heavy Metais

Total Petroleum Hydrocarboiis (TPH)

Monocyclic aromatic hydrocarbons (benzene, toluene, ethylbenzene and xylene or

BTEX)

Volatile halogenated orgarics

Polycyclic aoinatic hydrocarbons (PAHs)

Chlorinated hydrocarbons;

Polychlorinated biphenyls

Organochlorine pesticides

Phenols

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The site was subdivided into 3 zones as detailed previously ((1) oval, (2) USTs and (3) school

yard). Once the statutory audit was initiated AD1 were requested to undertake additional

sampling of shallow soils to supplement the samples taken and analysed by Beveridge Williams

& Co Pty Ltd. Initially 15 shallow (typically 0.1 metre depth) hand auger excavations were

undertaken in a grid pattern across the site (refer to the AI)I report in .Appendix D (their

Appendix G)). These grid samples were then composited into five samples for laboratory

analyses for the presence of heavy metals, PAHs and OCPs whilst individual samples were

further analysed for BTEX and TPHs (refer to Table 4 in Appendix D for all results).

The maximum concentrations of each of the compounds as reported by the laboratory fiom both

the Beveridge Williams & Co Pty Ltd ar,d lrutial AD1 work are summarised in the following

tzble.

The Quality Assurance and Quality Control during the execution of these initial assessments

consisted of a minimwn cjf 1 in 10 blind field duplicates (samples sent to the same laboratoiyj

for the AD1 work and at least 1 in 10 laboratory duplicates along with batch spikes for both

assessments. Examination of the QNQC data indicztes acceptable levels of control, for both

spike recovery percentages and RPDs between field duplicate samples.

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MAXIMUM DETECTED CONTAMINANT CONCENTRATIONS IN SOIL

COMRTNED BEVERIDGE WILLIAMS AND INITIAL AD1 DATA

Benzene <O. 110.5

<0.1/0.5 Toluene

Ethylbenzene

Xylene

I --

I -:O. 110.5 I

TPH (c6-CQ) a 0

TPH(C,,-C,,) 320

TPH (C1&8) 970

--

L--

I pH (C2R-C36) I

Total P.4Hs W c : 1

Individual PAHs <0.5<0.1

Halogenated HCs <OS

I

I

Arsenic

Cadmium

Chromium

16 Copper

Nickel 25

Lead 17

I I

I

-- Zinc 34

- Total Cyanide <5

Phenols <o. I

<1

Indiv. OC Pesticides <o. 1

Chlorinated Hydrocarbons <o. 1 I

Note: A = Beveridge Williams Report

all

all

all

- all

BH 107"

BH 107"

all

all

all

all"

BH101"

all

BHlOI"

BH102"

BH 102"

Comp2"

-

-

BH 102"

all"

all"

all'

allA

all" -

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Due to the presence of petroleum hydrocarbons in the IJST or Zone 2 areas (samples BH107 and

BH108 from the Beveridge Williams report and H9, H14 and H16 from the AD1 report) further

field investigations were requested by the auditor. The work scope and results of these additional

investigations are summarised in the AD1 report in Appendix D. These investigations were

aimed at obtaining a greater degree of confidence in the presence and possible distribution of

petroleum hydrocarbons ~ 4 t h i r i and surrounding the three UST areas.

. _

This expanded work scope was completed by AD1 and included the excavation of potentially

contaminated soils surromding all three USTs. Excavations continued until either non-

detectable laboratory conditions were achieved or until no further excavations were deemed

a

necessary. The three UST areas were designated as Cells 1, 2 and 3 in the AD1 report (refer to

Appendix D for details). Excavated contaninated soils were classified in accordance with €PA

guidelines for contaminated material and were removed off-site to licensed landfills d e r

appropriate pemd t documentatioii. At the completion of excavations validation samples were

taken of the walls and base of each ex-cavation and the maximum results for each cell xe

surrmarised in the table below.

-

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VALIDATION TEST RESULTS - USTS

CONCENT?dTIONS IN SOIL

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Benzene

Toluene

Ethylbenzene

Xylene

TFH (c6-c9)

TPH (clo-c,,)

p H (clS-c28)

TPH (c28-c36)

Benzene

Toluene

Ethylbenzene

Xylene

TPH (c6-&)

TPH (clo-Cl4)

TPH (C1s-C2s)

taken at 3.5 metre

<o. 1

<o. 1

<o. 1

<o. 1

a 0

a 0

4 0

<o. 1

1.2(3.5m1)

1.9(3.5m1)

7.3(3.5mi)

j7(3.jm1)

1600(3.5m1)

3800(3 .Sm')

<50

<o. 1

<o. 1

<o. 1

<o. 1

e 0

a 0

depth

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Validation sampling and analysis fiom the final trench excavation along each of Cell 1 and Cell

2 product lines indicated all BTEX and TPH compounds to be non-detectable (see validation

samples H44, H45 and H59, H60 in Appendix D for product line trenches fiom Cells 1 and 2

respectively).

Due to the presence of TPH compo'unds at and near the base of Cell 2 it was requested that two

boreholes be drilled adjacent to the Cell 2 excavation so that the status of deeper soillbedrock

contamination could be evaluated and that the groundwater status could be assessed. Two

boreholes were drilled, one to the west of t$e excavation and another to the north of ?he

excavation.

The western borehole was drilled to i! total depth of 8 metres and soil samples were taken at 3

and 8 metre depth for laboratory analysis. Both saniples returned non-detectable TPH and BTEX

with the exception of the 8 metre deep sample which contained 540 pprn of TPH (C1&J.

The nortlieni borehole was ct-illecl tg a total depth of 9.5 metres and due to the presence of

moisture at depth a groudwater monitoring well -was installed in this borehole. Soil saiples

from 6.5, 8.0 and 9.5 metres were taken for laboratory TPH and BTEX analyses. All samples

had non-deteckble BTEX. Tne 8 an 9.5 metre deep soil samples contained 650 ppm and 720

ppm of TPH respectively (in the Cl0-C& hydrocarbon range). A sample of groimdwater was

taken from this northern monitoring well arid analysed for TPH, R E X , lead, pH and total

dissolved solids (TDS). The resdts indicate non detectable BTEX, 212.3 ppm TPH, con

detectable lead, a pH of 7.3 and a TDS of 10,000 ppm.

..

Our Re$ M6496 Page 13 of 18

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4. SCREENING CRITERIA

When evaluating the suitability of a site for occupancy in a residential setting the Australian &

New Zealand Guidelines for the Assessment and Management of Contaminated Sites (ANZECC

and NHMRC 1992) have been used. These guidelines detail a limited list of contaminant

concentrations below which no adverse impact should be noticeable to human health or the

environment. The list of contaminants is relatively restricted and reference is made to the use of

“Dutch B” guidelines in the ANZECC document. ‘Where a contaminant guideline for sensitive

site development is not listed in the ANZECC guidelines the Dutch B guidelines have been used

as a screeiling criteria. It is noted that all laboratory detection limits were set at or below the

ANZECC and Dutch B guideline concentrations.

r -. The following table details the coniaminants in soils that have exceeded these guidelines at the

site:

TFFI (C6-C40j 5457 m a g in sample H37 from a depth of 3.5 metres in Cell 2

(exceeds r h t d i B of 1,000 m a g )

Xylene 7.3 mgkg in sample H37 (exceeds Dutch B of 5 mgkg)

I The following table details t!!e contaminants in groundwater that have exceeded these guidelines

at the site:

TPH (c6-c40) 212.3 mg/litre‘in sample from north of Cell 2

(exceeds Dutch B of 0.2 mgllitre)

These results indicate that there are soils zit depths of typically in excess of 1-2 metres in the

immediate vicinity of Cell 2 that contain petroleum hydrocarbons and xylene at concentrations

above the ANZECC/Dutch B guidelines. Groundwater in this area also contains petroleum

hydrocarbons at concentrations in excess of the ANZECClDutch B guidelines.

PID headspace screening of soil samples taken throughout the excavation exercise have revealed

generally low Volatile Organic Compounds (VOCs) in the soils analysed. This is consistent with

the laboratory test results which indicate the absence of BTEX compounds and low c&9

concentrations.

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103% RECYCLED PAPER 5) FLUOR DANIEL GTI

I .

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Field and Laboratory Q N Q C analyses were performed throughout the AD1 validation work. A

summary of the QNQC data is presented in their report which is duplicated as Appendix D of

this report. The level of QNQC is considered sufficient in terms of characterisation of soil and

groundwater conditions at the site.

Our Re) M6496 Page I5 of 18 I1 November 1997

FLUOR DANIEL GTI I m h RECYCLED PAPER

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5. CONCLUSIONS

Based on the data gathered and reported by Beveridge Williams and AD1 and the ‘work .

completed during this audit the following conclusions are made:

0 there is shallow soil contamination (greater than 1-2 metres depth) in the

immediate vicinity of Cell 2 at the site at concentrations exceeding the published

ANZECC and NHMRC guidelines;

0 the contamination in soils is present as non-volatile hydrocarbons (mostly medium

to heavy total petroleum hydrocarbon fractions);

0 there is petroleum hydracarbon impact to the groundwater table (at depths of about

8-9 metres) beneath the area encompassing Cell 2, the impact is present as TPH

only.

The extefit of the groundwater contamination has not been determined, however is likely to be

restricted to the immediate area of Cell 2. The groundwdter has a TDS of 10,000 ppm which

classifies it as having potential fdwe beneficial uses for “stock watering” or “industry” only

(according to the EPAV Draft Groundwater SEPP).

The extent of soil contamination associated with Ceii 2 is restricted to depths generally greater

than 1-2 metres and does not extend laterally beyond the boundaries of Lots 85 and 87 of

LP 130 16 (as shown in Appendix D).

Due to the above conditions the site does not merit the issue of a Certificate of Environmental

Audit. The presence of the detected contamination in site soils and groundwater of Lots 85 and

86 could be consistent with a proposed residential development subject to the following

conditions:

(0 any soil excavations deeper than 1 metre will need to be managed in accordance

Our Re$ MU96

with EPA Bulletin No. 448 “Classification of Wastes” (1995). The principal

requirement is that any constri.ction activity will take into consideration the

potential contamination status of soil at depths greater than 1 metre;.

Page I 6 of 18

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(ii) groundwater beneath the site (at depths of about 8 to 9 metres) is potentially a

heneficid soi_~rr.e nf water for industrial or stock watering purposes and the

presence of contamination in the groundwater has impacted the ability to exploit

these beneficial uses. Groundwater should not be extracted from beneath the site

for these beneficial uses; and

The possible presence of the groundwater contamination on all other lots associated with this

audit could be consistent with a proposed residential development subject to the following

condition:

(i) any proposed groundwater extraction for industrial use or stock watering would

need to be further evduated to assess if these beneficial uses have been affected.

Our Re$ M6496 Page17of18

lapb RECYCLED PAPER

I I Norember I99 7

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6. REFERENCES & ST-4TEMENT OF LIMITATIONS

EPAV “Guidelines for Environmental Auditors (Contaminated Land) - Conducting

Environmental Audits on Land” - Publication No. 474, October 1995

EPAV “Classification of Wastes” - Publication No. 448, September 1995

EPAV “ Draft State Environment Protection Policy (Groundwaters of Victoria)”, Publication

No. 288, October 1994

ANZECC & NHMRC “Australian & New Zealand Guidelines for the Assessment &

Managenent of Contaminated Sites”, January 1992

This report represents a review of data and information (together, “Information“) relating to the subject

property of this report. The Information was obtained not by Fluor Daniel GTI but from other sources

and contacts, some of whom may be noted in the report. Fluor Daniel GTI has not been able to verify

the accuracy or completeness of the Information, and Fluor Daniel GTI expressly disclaims and takes no

responsibility for the Information.

1 he ana!yses, evaluations, opinions and conclusions presented in this report are based on the

Infomiation, and they could change if the Information is in fact inaccurate or incomplete.

Fluor Daniel GTI will not update the report and has not taken into account events occurring after the

time its review was conducted.

Any person who relies on this report does so at their own risk.

FLUOR DANIEL GTI (AUSTRALIA) PTY LIMITED

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.

t

SECTION 57AA

STATEMENT OF ENVIRONMENTAL AUDIT

I, Peter Mirkov of Fluor Daniel GTI (Australia) Pty Ltd, a person appointed by the Environment Protection Authority (“the Authority”) under the Environment Protection Act 1970 (“the Act”) as an environmental auditor for the purposes of the Act, having:-

1. been requested by Rexrun Pty Ltd to issue a certificate of environmental audit in relation to the land identified as (Volume 71 19 Folio 1423630 (Lots 60 to 65), Volume 7171 Folios 1434104,1434105, 1434103, 1434097 and 14341 10 (Lots 66 to 76 collectively), Volume 8102 Folio 085 (Lots 77 and 78), Volume 7395 Folio 1478994 (Lots 79 to 83) and Volume 7171 Folio 1434059 (Lots 84, and 87 to 89) of Subdivision No. 13016 of Crown Portion 2, Parish of Will Will Rook, County of Bourke, Municipality of Moreland (“the site”) which is owned by Rexrun Pty Ltd;

2. had regard to, amongst other things, -

(i) (ii) (iii)

guidelines issued by the Authority for the purposes of Section 57AA of the Act; the beneficial uses that may be made of the land at the site; and relevant State environment protection policies/industrial waste management policies, namely ANZECC & NHMRC 1992 “Guidelines for the Management & Assessment of Contaminated Sites” and EPAV Publication Nos. 288 (1994), 448 (1995) and 474 (1995), in making a total assessment of the nature and extent of any harm or detriment caused to, or the risk of any possible harm or detriment which may be cause to, any beneficial use made of the relevant segment at the site by any industrial processes or activity, waste or substance (including any chemical substance); and

3. i

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

HEREBY STATE that I am of the opinion that the site is Potentiallv contaminated because possible future beneficial uses of groundwater from beneath the site (depths greater than 8 metres) as industrial or stock water may have been detrimentallv affected. Accordingly, I refuse to issue a Certificate of Environmental Audit for the site in its current condition due to the possible presence of contaminants in the groundwater which possibly precludes the use of the site for possible future beneficial uses. I further hereby issue a Statement of Environmental Audit and state that the site is suitable for residential purposes subject to the following conditions being adhered to (these are to be read in conjunction with the site audit report dated 1 1 November 1997):

(1) any proposed groundwater extraction (from depths of in excess of 8 metres) for industrial use or stock watering would need to be further evaluated to assess if these beneficial uses have been affected.

DATED; bD@C Signed:

ENVIRONMENTAL R (CONTAMINATED LAND) V “

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~~

~ 7 ~ x 7 n n n r n a v n v m n n n m m n m r n n T A n m 4 nrrn AI\ v Inuirivihir I r n u I LL I IWIA AL 1 IY IU

SECTION 57AA

STATEMENT OF

I, Peter Mirkov of Fluor Daniel GTI (Australia) Pty Ltd, a person Protection Authority (“the Authority”) under the Environment environmental auditor for the purposes of the Act, having:-

1.

2.

3.

been requested by Rexru land identified as (Volu 142103, 142097 and 142 Volume 7395 Folio 1478 Subdivision No. 13016 of Crown Portion 2, Parish of Moreland (“the site”) which is owned by Rexrun

had regard to, amongst other things, -

(i) guidelines issue (ii) the beneficial u (iii) relevant State e

policies, namely ANZECC &

completed an environme Act, a copy of which ha een sent to the Autho ky. r/”d P

HEREBY STATE that I a p t h e opinih that the h e is potentiallv contaminated because possible future beneficial uses of ound&& from bene& the site (depths greater than 8 metres) as industrial or stock water ed. Accordingly, I refuse to issue a Certificate of

ition due to the possible presence of contaminants in f the site for all possible future beneficial uses. I udit and state that the site is suitable for residential

eing adhered to (these are to be read in conjunction with

action (from depths of in excess of 8 metres) for industrial use be hrther evaluated to assess if these beneficial uses have

DATED;

MINATED LAND)

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ENVIRONMENT PROTECTION ACT 1970

SECTION 57AA

STATEMENT OF ENVIRONMENTAL AUDIT

I, Peter Mirkov of Fluor Daniel GTI (Australia) Pty Ltd, a person appointed by the Environment Protection Authority (“the Authority”) under the Environment Protection Act 1970 (“the Act”) as an environmental auditor for the purposes of the Act, having:-

1. been requested by Rexrun Pty Ltd to issue a certificate of environmental audit in relation to the land identified as Lots 85 and 86 of Subdivision No. 130 16 of Volume 7 17 1, Folio 1434059 in Crown Portion Two, Parish of Will Will Rook, County of Bourke, Municipality of Moreland (“the site”) which is owned by Rexrun Pty Ltd;

2. had regard to, amongst other things, -

(i) (ii) (iii)

guidelines issued by the Authority for the purposes of Section 57AA of the Act; the beneficial uses that may be made of the land at the site; and relevant State environment protection policies/industrial waste management policies, namely ANZECC & NHMRC 1992 “Guidelines for the Management & Assessment of Contaminated Sites” and EPAV Publication Nos. 288 (1994), 448 (1995) and 474 (1995), in making a total assessment of the nature and extent of any harm or detriment caused to, or the risk of any possible harm or detriment which may be cause to, any beneficial use made of the relevant segment at the site by any industrial processes or activity, waste or substance (including any chemical substance); and

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

HEREBY STATE that I am of the opinion that the site is contaminated because possible future beneficial uses of groundwater from beneath the site (depths greater than 8 metres) as industrial or stock water has been detrimentally affected and because soil contamination is present at depths in excess of I metre. Accordingly, I refuse to issue a Certificate of Environmental Audit for the site in its current condition due to the presence of contaminants in soils and groundwater at concentrations which possibly precludes the use of the site for all possible future beneficial uses. I further hereby issue a Statement of Environmental Audit and state that the site is suitable for residential purposes subject to the following conditions being adhered to (these are to be read in conjunction with the site audit report dated 11 November 1997):

(1) any soil that is excavated from depths greater than one metre from the site, for the currently proposed development or in the future, will need to be managed in accordance with EPA Bullet No. 448 “Classification of Wastes” (1995); and groundwater beneath the site (depths.greater than 8 metres) is potentially a beneficial source of water for industrial or stock watering purposes and the presence of contamination in the groundwater has impacted the ability to exploit these beneficial uses. Groundwater should not be extracted from beneath the site for these beneficial uses.

(11)

DATED: 1x1 ji/q3 Signed:

ENVIRONMEN L: AUDITOR (CONTAMINATED LAND)

U ‘.

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A

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Stututory Environmental Audit Report Former Hadfield Primary School Exeter Street, Glenroy, Victoria

I II

Ill

Our Re$ Ma96

111 II II 111 11111 11111 1111 111111 1111 11111 I111 1111

11111 11111 lllIIllllIlllll111llll1111111 llll1111

-

APPENDIX A

Copy of Certificate of Title

3261 6-1 -A I

11 E.'ovenrter 1997

FLUOR DANIEL GTI I I J X RECYCLED PAPER

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,

TARTAGLIA & ASSOCIATES Legal Practitioners & Consultants

Sam Tartaglia LL.B. 231 Union Road Ascnt V d e 30332 P.O. Box I56 Ascot Vale 3032

Telephone: (03) 9326 I455 Facsimile: (03) 9326 1499 DX 32158 Moonee Ponds

Your Ref:

Our Ref: ST:EM

25 July 1997

The Manager Fluor Daniel GTI (Australia) Pty Ltd Unit 81 177 Beavers Road NORTHCOTE VIC 3070

Attention: Peter Mirkov

Dear Sir

RE: HADFIELD PRIMARY SCHOOL/EXETER STREET

We refer to telephone conversation between our Mr Tartaglia and your Mr Peter Mirkov on Thursday 24 July 1997.

We enclose copies of the following:-

1. Plan of Subdivision. 2. Titles.

Yours faithfully, TARTAGLIA & ASSOCIATES

Per:

Encl:

EM25713 27 of 48

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F 0 C 3 n L.. h

28 of 48

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k.

,1.‘* \“v GRGED PI; 72.72 W 11.64lL dlom. 0‘90

ln ln

W z 0 N

w r 4:

GRATED P I T 5 72.051L dlorn. 0.23

<..,

NOTATIONS

LEVELS SHOWN THUS +‘*ARE TO THE AUSTRALIAN

P L A N O F LEVELS CERTIFICATION BY SURVEYOR

I certlfy that thls plan correctly represents the levels o f -+res on llth June 1997.

ORIGINAL SCALE 1:800

U d 8 0 8 16 24 3 2

LENGTHS ARE I N METRES HEIGHT DATUfl VIDE MflB BENCHMARK 1791 RL 75.L18.

E-l DRAINAGE AND SEWERAGE EASEMENT

N (NORTH) INDICATES DIRECTION OF PIPE

KEARNEY & TYRRELL PTY. LTD. LAND SURVEYORS

194 Keilor Rood, Essendon North 7091 Phone: 9 9 7 9 1666

COUNTY BOURKE . . . . . . . . . . . . . . . . . . . . . . . . .

Licensed Surveyor PARISH WILL WILL ROOK - - THE LAN0 IN THE SURVEY IS SHOWN ENCLOSED BY CONTINUOUS THICK LINES

NUMBER OF SHEETS IN THIS PLAN: I NUMBER OF THIS SHEET: I

LAST PLAN REF: LOTS 60-89 ON LP13016

.I Fax: 9379 7576 DISK 167-JM 29 of 48

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U

'c,

% 9 ...

UNDER THE "TRANSFER OF LAND ACT 1928."

Alex Ad&: of 54 High Street Kew Manufacturer is - - - - - - - - - - - - -

red on the map i n the margin being Lots 84 t o 89 (both inc lus ive) 6n ~ l a n of ----

Subdivision No.13016 lodged i n the Uff ice of T i t l e s and being part of Cronrn ----- , .

Portion Two h r i e h of : N i l 1 W i l l Rook County of Bourke - - - - - - - - - - - - -

I

I

j

ENCUMBRANCES REFERRED Tk$ 1 /

,. h. -_- -. 4 .r o.p/

4TREET : I

E X E T E R

30 of 48

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' \ i

. ..

c

. . . . . ,

31 of 48

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-> / I : , I

V I C T O R I A . - ' I

r t i f i tah . UNDER THE "TRANSFER OF LAND ACT 1928."

Leonel la Marchesani o f 26 Methven S t r e e t Eas t Brunswick Married Woman i e - --

, m / f i ~ ~ z e u ~ * in

red and b l u e on t h e map i n the margin being Lots 60 t o 65 (both i n c l u s i v e ) on P lan

of Subdiv is ion No.13016 lodged i n t h e O f f i c e of T i t l e s and being p a r t o f Crown .---

P o h i o n Two County of Bourke - - - - - - - - - - - - --

/L a t /i- /Zyd

>

ii r a r i s h of Will W i l l Rook

I 3 5 :

B ~ D F O R D STQEET

1 I-

.. . .: ' . , : : . .:

. ., dr8idan1 Rqiafrar of Tiflu.

ENCUMBRANCES REFERRED TQ?,-o.- - . ;.. . . ,.I./ \$; > --e.-:., .: . . . ;/ ' . A s t o the land coloured b lue --- TI= EASEMENTS ( I f any) e x i s t i n g over t h e same by

v i r t u e o f S e c t i o n 212 of t h e T r a n s f e r o f Land --

x&?'<J.i.i'' 9

c

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-" -the land compriaed herein.

c

? I

. ..

I 3 i'

, :.

I

D

i

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i I ..

in 3

Urs Regis& Book

V I C T O R I A . --

UNDER THE "TRANSFER OF LAND ACT 19.28."

P o r t i o n Two P a r i s h of 'Jill Y i l l Rook County of 3ourke - - - - - - - - - - - --

f

4

4

I i

1 i I

I I I I I

h v) Q

I

34 of 48

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i

. ..

f i

i , t ' . c

35 of 48

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Entered in the Regislei B O O ~

nRBcBNA1 w n a r - a r . ~ n n b d

P!OT TO BE TAKEN FROM Vol. 1 0 ?, Fol. I! (F 5 THE OFFICE OF TITLES ....

V I C T O R I A

UNDER THE “TRANSFER OF LAha ACT 1954”

P e t e r C e c i l prevr o f 15 Vihitehead S t r e e t Corowa New South Wales Salesmen is -

- - - - - - _ _ _ _ now the of an Estate in Fee-simple subject to the Encumbrances noffied hereunder in

proprietor - - - - - - - - - - - - - - - - - - - -

gfl th a t piece of Land, deheated and coloured red on the nap i n the ----

~ a r g i n be ing Lots 77 and 78 on Plan of Subdiv is ion Iro.13016 lodged in the O f f i c e of-

T i t l e s end being p a r t s o f Crown Sec t ion 2 P a r i s h of \‘!ill W i l l Rook Covnty of Bourke

I

. . Dated the T h i r t i e t h day of De ce mb er . ..

thousand nine hundred and fif ty-five.

-*4L7- / P

Asidant Reqislror

ENCUMBMNCES REFERRED TO

J 15.

. - e

\

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i

. . . . . . . .. 4: .: .'..;.

,. . . . , ... . . . ... A- .. ' ., . . . . , . . .

: c.

. .

, * '

'. ,.'

. .

37 of 48

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V I C T O R I A .

t .. -

UNDER THE "TRANSFER OF LAND ACT 1928."

*

r e d and b lue on t h e map i n t h e margin being Lots 75 and 76 on Plan of Subdivision

No.13016 lodged i n t h e O f f i c e of T i t l e s and being p a r t of Crown Por t ion Two -----

P a r i a h of Y i i l l W i l l Rook County of dourke - - - - - - - - - - - - - - - - - - - - i

L

As t o t h e l and coloured b lue -- THE - EASEMF,NTS ( i f any) e x i s t i n g over t h e , s m e

by v i r t u e of S e c t i o n 212 of t h e Transfer O f -- Land Act 1928 - - - - - - - - - - - - - - - -

'

c EXETER .STREET

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...

i

..

L

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' U

' Z - 3 0

.i V I C T O R I A .

UNDER THE "TRANSFER OF LAND ACT 1928."

John Richard : v i l l i a m H!$?$I of 283 Sussex S t r e e t Merlynston Crematorium Attendant is

r e d and b l u e on t h e map i n the margin being L o t s 72, 73 and 74 on Plan of subdiv is ion - -

. . No.13016 lodged i n t h e u f f i c e of T i t l e s and being par t of Crown Port ion Two &,ish of - r W i l l W i l l Rosk County of bourke - - - - - - - - - - - - - - - - - - - - - - - - - - z - -

I

c

r"

,

<

* BEDFORO JTREET

ENCUMBRANCES REFER RED^% .'+' \.:e.= A s t o t h e land colour2d blue -------- THE --- EASFXFXiTS ( i f any) e x i s t i n g over t h e same

by v i r t u e of Sec t ion 212 of the Transfer of --

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.......... ..... ._ ..... _ ..

I

... ..I.: :' i.. . . . . . . .

li

i ;

. -

I _

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UNDER THE "TRANSFER OF LAND ACT 1928."

Sam Adler of 80 Brunswick Road E a s t Brunswick Elec t - ic ian i s - - - - - - - -

r e d and b lue on t h e map i n t h e margin being Lots 70 and 71 on Pldn of Subdivis ion

No.13016 lodged i n t h e O f f i c e of T i t l e s and being p a r t of Crown Fort ion Two ----- 7

:. ' P a r i s h o f . Xi11 Vi11 Rook County of Bourke - - - - - - - - - - - - - - - - - - - -

i

BEDFORD 6TRE.E-l- I

/ " EN C U M 6 R A N C ES REFERRED TOXh,,

\!,To?/ As t o t h e land coloured b lue - - - THE EASEMENTS ( i f any) e x i s t i n g over t h e same --- by v i r t u e of S e c t i o n 212 of t h e T r a n s f e r of --

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Page 43: Environmental Audit Report - EPA Victoria · FLUOR DANIEL GTI Ill1 I II 111 Ill I Ill Ill STATUTORY ENVIRONMENTAL AUDIT REPORT FORMER HADFIELD PRIMARY SCHOOL, GLENROY, VICTORIA Prepared

............

- - - - - “ - c . - r . . ~ ....... .... ....

.......

- - ___-

...

. . .

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... , . .

V I C T O R IA. - rtifittth? Df

UNDER THE "TRANSFER O F LAND ACT 1928."

Ernes t Adler of 80 Brunswick Road East Srunswick r;ngineer is - - - - - - - --

r e d and blue on t h e map i n t h e margin being L o t s 66 and 69 on Plan of Subdivis ion

I -2 i . 5 i % ! - a "

No.1316 lodged i n t h e o f f i c e of T i t l e s and being p a r t of Crown Por t ion Two '.

P a r i s h of Will ' N i l 1 Rook County of Bourke - - - - - - - 2. - - - - - - - - - - -

----

f

' u -0 - . .. - s

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Page 45: Environmental Audit Report - EPA Victoria · FLUOR DANIEL GTI Ill1 I II 111 Ill I Ill Ill STATUTORY ENVIRONMENTAL AUDIT REPORT FORMER HADFIELD PRIMARY SCHOOL, GLENROY, VICTORIA Prepared

---------- I

. -_-

e

:i.

1

. . . . - t

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Page 46: Environmental Audit Report - EPA Victoria · FLUOR DANIEL GTI Ill1 I II 111 Ill I Ill Ill STATUTORY ENVIRONMENTAL AUDIT REPORT FORMER HADFIELD PRIMARY SCHOOL, GLENROY, VICTORIA Prepared

VI C T 0 R IA. - rtifitah? -of

UNDER THE “TRANSFER OF LAND ACT 1928.”

Rose Adler of 80 Brunswick Road East arunswick Clerk is - - - - - - - - - - -

r e d and blue on t h e map i n t h e margin being Lots 66 and 67 on Plan of Subdiv is ion

\j No.13316 lodged . i n t h e Uff ice of T i t l e s and being p a r t of Crown Por t ion Two ---- 5 - v

Parish of : , S i l l : H i l l Hook Countjr of nourke - - - - - - - - - - - - - - - - - - - - - b c ? < ; 2 j 3 - u

As t o t h e land co loured b l u e --------- THE EASEMENTS (if any) e x i s t i n g over t h e same

by v i r t u e of S e c t i o n 212 of t h e T r a n s f e r of - - Land Act 1928 - -,: - - - - - - - - - - - - -

/(,*.;;,

c

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i 1

, L

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