R8000 NEW AIR COMBAT CAPABILITY (NACC) FACILITIES PROJECT ... · 1. The former Fuel Farm – surface soils down to about 0.2m impacted by Benzo(a)pyrene, PAH and PFOS 2. Northwest

LEND LEASE BUILDING PTY LIMITED | ABN 97 000 098 162

R8000 NEW AIR COMBAT CAPABILITY (NACC) FACILITIES PROJECT, RAAF BASE WILLIAMTOWN

CONTAMINATED SOIL & WATER MANAGEMENT PLAN 9/12/2015 | Revision No: 8

Plan Revision Status

Date Revision (in numbers)

Purpose and Summary of Amendments Reviewed by Approved by

19/09/2014 1 Initial Draft

15/10/2014 2 For Construction

14/11/2014 3 Incorporate SEM comments and outcome of additional internal QA review

16/01/2015 4 Include requirements from Dept of Defence Environmental Clearance Certificate

13/04/2015 4 Quarterly Review. No changes

13/07/2015 5 Quarterly Review. Added responsibilities column

13/10/2015 6 Updated to include the Spoil Management and Groundwater Management requirements

18/11/2015 7 Draft for Comment

9/12/2015 8 Final – Issued for use

*Note that all printed paper/hard copies of this document and related procedures are uncontrolled. The controlled copy of this document is found either in Project Web, within the Project Management Plan section, or other project specific database/server approved by the Regional EHS Manager.

CONTAMINATED SOIL & WATER MANAGEMENT PLAN Page 3 of 40

LLB ISSUE: 8 ISSUE DATE: 9/12/2015 Rev

CONTAMINATED SOIL & WATER MANAGEMENT PLAN

1. Scope: This Contaminated Soil & Water Management Plan describes:

the extent of known contamination within the NACC Project Area,

mitigation measures to minimise the potential for the Project’s construction activities to cause soil or water contamination

It should be noted that this is not a Remediation Action Plan for pre-existing contamination on the Base, and only relates to management of pre-existing contamination where it is touched by the Project’s activities.

The NACC Project is made up of the following areas (See Figure 1):

NW Runway

EO Stores and Access Roads

NACC Precinct

SE Runway

Figure 1 – NACC Project Areas



2. Objective: Identify known areas and sources of contamination in the NACC Project Area (see Fig 1 above).

Develop appropriate measures to minimise and control potential human health or environmental impacts during

construction.

Provide a structured approach to the management of any unexpected contamination encountered during construction activities.

Provide guidance on the classification and stockpiling or disposal of any contaminated material that cannot be re-used on site (consistent with NSW EPA classification guidelines.)

3. Context RAAF Base Williamtown has been in constant use as a military airbase since the 1940’s, with a range of activities including fuel storage, aircraft operations and maintenance and firefighting training activities conducted on the Base for much of this time.

The Contamination Assessment (Coffey 2012) carried out for the Project Environmental Impact Assessment reviewed previous land use, existing contamination reports and took a number of soil and water samples across the NACC Project Area (see Figure 1) to assess soil and water contamination within the Project footprint.

The assessment identified three potential areas of contamination in soil within the NACC Project Area:

1. The former Fuel Farm – surface soils down to about 0.2m impacted by Benzo(a)pyrene, PAH and PFOS

2. Northwest Runway – soil down to about 0.2m impacted by Benzo(a)pyrene and PAH

3. Explosive Ordinance Area - soil down to about 1m impacted by Benzo(a)pyrene and PAH.

The assessment also identified elevated iron at 8 locations across the project area and PFOS in groundwater in the area in front of the Air Traffic Control Tower, and adjacent to Taxiway Echo leading up to the Engine Run-Up Bays.

More recent studies carried by URS (URS 2015) have identified perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA) contamination at a range of concentrations in soil and groundwater across areas of the Base, including areas of the NACC Project Area.

To manage the potential human health risks and environmental impacts from the reported potential to encounter contamination during construction, the following measures have been put in place:

1. Develop a Contaminated Soil and Water Management Plan –

This document fulfils this requirement

2. Engage a specialist Environmental consultant to provide independent contamination testing and advise upon appropriate management practices–

Environmental Earth Sciences (EES) have been engaged by Lendlease to fulfil this role.

3. Put in place quality systems and controls to manage implementation of the management plan.

The Lendlease Building Environmental Health and Safety system under which the project is managed is Certified to ISO 9001:2008; ISO 14001:2004; AS/NZS 4801:2001; OHSAS 18001:2007. Soil and groundwater testing is being carried out by NATA accredited laboratories.

To continue to better understand and manage the project’s contamination risks, ongoing soil and water testing is being carried out across the NACC Project Area.

Soil:

The project requires stripping of topsoil under pavements and buildings in order to provide a suitable engineering base for these structures. It is expected that between 100mm and 300mm of topsoil will be removed across the NACC precinct, NW Runway and SE Runway works. It is estimated that 122,500m3 of topsoil will be generated. This material is generally not suitable for use as engineering fill on the project.

A further 22,000m3 of subsoil will be excavated from the NACC precinct area to enable construction of buildings, structures and pavements

In-situ soil testing is being carried out by EES for the for bulk excavation areas across the project. To date (EES 2015a) over 400 soil samples have been collected and tested for chemicals of concern. This testing is ongoing and will be completed in advance of all bulk earthworks.

Excess soil generated from trenching and piling works will be stockpiled and tested for contaminants of concern.

Where testing shows soil meets the Soil Reuse Criteria (see Section 5) this material will be reused on site.

Material exceeding the Soil Reuse Criteria will be retained on site in a Defence approved stockpile location for subsequent decisions on treatment, disposal or reuse to be made by Defence. Stockpiles of material exceeding the Soil Reuse Criteria will be set-up with appropriate leachate and erosion controls to prevent pollution.

Soil that classifies as Hazardous or Special Waste under NSW EPA Waste Classification Guidelines will be disposed of to an appropriately licenced waste facility consistent with all relevant NSW EPA requirements and

http://www.defence.gov.au/id/williamtown/Documents.asp



approvals.

Testing data is being used to plan excavation, stockpiling, reuse and disposal of material, to manage environmental and human health concerns.

Water:

The NACC Facilities Project at RAAF Base Williamtown sits atop the Tomago Sandbeds Aquifer. Hunter Water extract water from areas of this aquifer for drinking water supply, however the two pumping stations closest to the Base, Pump Stations 7 and 9, have not been used to supply drinking water since 2014 and 2009 respectively, and were both isolated from the drinking water network in 2014 as a precaution (Hunter Water Corporation 2015)

The water table under the Base rises and falls in response to rain events, but consistently sits at 1m to 2m below ground level across much of the site. In some areas, especially after rain the water table reaches the ground surface causing standing water and waterlogged areas.

In some areas it will be necessary to dewater excavations in order to construct elements of the NACC project.

Lendlease’s consultants EES are conducting groundwater testing ahead of dewatering activities to identify chemical contamination in order to plan construction and dewatering, and water discharge / disposal so as to manage environmental and human health risks.

To date (EES 2015b) groundwater testing has identified no man-made groundwater contaminants, with the following exceptions:

PAH’s (fluoranthene, pyrene and benzo(a)pyrene) detected in a groundwater sample associated with

an unexpected hydrocarbon contamination find to the north west of the Air Traffic Control Tower, in

the location of the new JSF Precinct taxiway (EES 2015c)

Very low levels of PFOS and PFOA have been identified across some project areas. Hotspots with

higher levels of PFOS and PFOA have been identified associated with the Fire station training area,

the Trade Waste facility and a disused fire training pit on the western side of the runway.

Groundwater testing by EES is ongoing across the NACC Project Area.

Where extracted groundwater meets Water Discharge Criteria (see Section 5), it will be discharged on the base for reinfiltration back into the ground. Where groundwater does not meet the Water Discharge Criteria it will be treated onsite to meet the appropriate criteria before discharge, or tankered off site to an appropriately licenced liquid waste facility.



4. Risks: Chemicals of Concern:

1) Perflourinated Compounds (PFCs)

Aqueous Film Forming Foam (AFFF) has been widely used around the world for firefighting operations and training. Historic formulations of AFFF used on the Base between 1970 and 2008 contained concentrations of the PFCs, perfluorooctane sulfonate (PFOS) and perfluorooctanoic acid (PFOA). Studies in the early 2000’s indicated a potential for these chemicals to accumulate in the environment and suggested potential environmental and health concerns, and as a result Defence switched to a low PFOS / PFOA firefighting foam and introduced procedures to limit discharges of these chemicals to the environment and reduce occupational exposure for Base personnel.

PFOS and PFOA are both very stable chemicals that do not break down in the environment and can persist for a long time both in the environment and in humans. PFOS and PFOA are 'emerging contaminants' and while extensive research into the possible health impacts of these chemicals is ongoing both in Australia and overseas, there are currently no conclusive links to health impacts (http://www.defence.gov.au/id/williamtown/FactSheets.asp).

A report of PFC contamination levels on and around RAAF Williamtown has been produced (URS 2015) for Defence and was published in September 2015. The report noted low level PFOS / PFOA contamination across wide areas of the project site. It also identified locations where PFOS and PFOA contamination in soil and water that may be encountered by NACC construction activities.

Testing by EES has confirmed and refined our understanding of the location and concentration of these contaminants in soil and water in our work area. These results are summarised below in Table 2 and Figures 2, 3a and 3b. Note that Figure 2 includes all potential areas of contamination risk ie not just PFOS.

Lendlease has sought expert independent advice from the NACC environmental consultant, Environmental Earth Sciences (EES) on appropriate health and safety management strategies with regard to worker exposure to PFOS/PFOA contamination.

Environmental Earth Sciences (EES 2015e), have provided the following PFOS / PFOA Threshold Concentrations below which EES consider there to be no human health risk from worker occupational exposure. They have also advised that the primary routes of entry into the body of these chemicals are orally (eating/ drinking), or through the skin, they are not volatile so vapours are not considered to present a significant health risk.

Table 1 Human Health Threshold Concentrations - for worker occupational exposure only

Contaminant Soil ** Water **

PFOS 90 mg/kg 18 µg/L

PFOA 240 mg/kg 36 µg/L

6:2 FTS 900 mg/kg 456 µg/L

** These calculations are based on Dept of Defence Contamination Directive #8 (DCD#8) guidelines, and have taken a conservative approach that assumes worker exposure to contamination for 8 hours/day for 240 days/year for 30 years.

When working in areas of contamination that are above the Threshold Concentration, occupational exposure risk is managed by the use of heightened PPE and personal hygiene processes. For details of the appropriate PPE and hygiene measures see Sections 8.3 and 8.5 below.

Note: Threshold Concentrations relate to worker health considerations only and do not protect from leaching into groundwater. These Threshold Concentrations should not be used as environmental protection guidelines. For Environmental Acceptance Criteria see Section 5 below.

Monitoring to date has found only one area within the NACC Project Area where the PFOS / PFOA levels exceed the Human Health Threshold Concentrations above. That location is an area to the south of the Air Traffic Control Tower and Fire Station, in the location of the new stormwater line construction required under the NACC scope of works. All other

http://www.defence.gov.au/id/williamtown/FactSheets.asp

http://www.defence.gov.au/id/williamtown/Documents.asp



areas are considered to present low human health risk from worker PFOS / PFOA exposure.

2. Hydrocarbon contamination

BTEX (benzene, toluene, ethylbenzene, and xylenes) compounds are some of the volatile organic compounds (VOCs) found in petroleum derivatives such as petrol, aviation fuel and diesel. Benzene is a known carcinogen. Toluene, ethylbenzene, and xylenes have harmful effects on the central nervous system. BTEX are known to be volatile and will form vapour under certain conditions, therefore vapour inhalation is the most likely exposure route for these compounds.

PAH (Polycyclic Aromatic Hydrocarbons) are typically created through incomplete combustion of products like coal, oil, gas, or garbage. They are generally not volatile; however their presence presents a dermal contact and ingestion hazard and can be managed through controlled exposure, groundwater management and PPE if necessary. Generation of dust from exposed surfaces should be minimised during construction activities to prevent exposure to airborne contaminants.

Benzo(a)pyrene (BaP) is one type of PAH. Potential BaP exposure to workers is directly related to the possible pathways that the chemical can enter the body. Due to its high molecular weight and low solubility and volatility, the only pathways requiring consideration are ingestion and dermal contact (and possibly dust inhalation for soots). A safe BaP criteria for commercial/ industrial workers for exposure to pyrogenic residue (includes coke, ash, clinker, slag) is around 500 mg/kg. This is based on a pathway specific dermal contact criteria of 600 mg/kg and ingestion criteria of 2,000 mg/kg. The dust inhalation pathway is insignificant.

Of greater concern would be PAH chemicals collectively known as gas condensates (tar, benzol, naphtha oil, ammoniacal liquor, creosote, pitch) and particulates (soot). The greatest level of risk to exposure of workers to BaP in gas condensates and soots is ingestion, with a pathway specific criterion of 200 mg/kg. The pathways specific criterion for dermal contact is 600 mg/kg, while dust inhalation is not a significant pathway (overall criteria is 150 mg/kg)

3. Naturally occurring arsenic in soils

Tomago sand beds are known to contain naturally occurring arsenic which is generally associated with pyrite (iron sulphide). Exposure of pyrite through excavation or dewatering can result in the liberation of arsenic into the groundwater. Oxidation of pyrite can also occur as the water table fluctuates and the soils can sometimes have elevated naturally occurring arsenic concentrations

Summary of potential contamination areas and associated work areas.

Table 2 below lists the main construction areas and describes the planned construction activities in these areas with potential to be impacted by contamination.

Figure 2 shows the relationship between the areas of work and potential contamination described in Table 2.

Table 2. Work areas and potential to encounter contamination.

Main Work Area Activities Potential Chemicals of Concern Comments

Explosive Ordinance (EO) Stores Topsoil Stripping. Excavation for services and drainage

No chemical contamination identified in this area to date.

Groundwater testing ongoing as required associated with dewatering activities.

NACC Precinct (inc. stormwater line)

Topsoil Stripping. PFOS / PFOA in soil Manage as per Contaminated Soil Control Measures – Section 8.3



Localised PAH and BaP contamination (topsoil) in existing EO stores area. (4)

Material has been tested and classified in-situ. Material identified as exceeding the appropriate Soil Reuse Criteria will be segregated and where free of PFCs disposed of to appropriately licenced waste facility, where PFCs are present the material will be either stockpiled on site, or if directed by Defence, waste classification sought from NSW EPA followed by disposal to appropriately licenced waste facility.

Hydrocarbon contamination associated with Former Fuel Farm (2)

Testing is ongoing in this area, specific EHS management measures to be developed for this area pending the outcome of this testing. Excavation and disposal of this material is to be under the guidance of the Project Environmental Consultant and subject to NSW EPA classification.

Tar drum – unexpected find (12) Excavation and disposal of this material is to be under the guidance of the Project Environmental Consultant and subject to NSW EPA classification.

Excavation for services and drainage PFOS / PFOA (Soil and water) (3) Manage as per Contaminated Water Control Measures – Section 8.5 and Contaminated Soil Control Measures – Section 8.3

Hydrocarbon contamination associated with Former Fuel Farm (2)

Testing is ongoing in this area, specific EHS management measures to be developed for this area pending the outcome of this testing.

Tar drum – unexpected find (12) Excavation and disposal of this material is to be under the guidance of the Project Environmental Consultant

Unexpected finds See Unexpected Contamination Procedure (Appendix A)

Excavation for construction of storage tank

PFOS / PFOA (Soil and water) Manage as per Contaminated Water Control Measures – Section 8.5 and Contaminated Soil Control Measures – Section 8.3



Construction of construction Access Rd Relocation of remediated Rifle range stop butt – potential for lead contamination (5)

This stop butt has been remediated, remediation reports are available

Demolition of existing Explosive Ordinance Structures

Various See Hazardous Materials inspection report completed for these buildings

SE Runway Topsoil Stripping. PFOS / PFOA in soil Manage as per Contaminated Soil Control Measures – Section 8.3

Excavation for services and drainage PFOS / PFOA (Soil and water)

Manage as per Contaminated Water Control Measures – Section 8.5 and Contaminated Soil Control Measures – Section 8.3

Localised BaP contamination in topsoil (11)

Material has been tested and classified in-situ. Material identified as Hazardous Waste to be excavated for treatment and disposal under guidance of project Environmental Consultant and subject to NSW EPA waste classification.

Unexpected finds See Unexpected Contamination Procedure (Appendix A)

NW Runway Topsoil Stripping. Localised PAH in topsoil (1) Ongoing testing to improve understanding of contamination is this area

Excavation for services and drainage PFOS / PFOA (Soil and water) Manage as per Contaminated Water Control Measures – Section 8.5 and Contaminated Soil Control Measures – Section 8.3

Unexpected Finds See Unexpected Contamination Procedure (Appendix A)

Services through existing Base. Excavation for services and drainage Not expected to impact known contamination areas

Unexpected Finds See Unexpected Contamination Procedure (Appendix A)

The bold numbers in Table 2 relate to the potential contamination areas shown in Figure 2.



Figure 2 Potential Areas of Contamination



Environmental Earth Sciences (EES), the Projects Contamination Consultants, have produced a plan showing the inferred concentration of groundwater PFOS contaminant within the NACC Project Areas. Figure 3a shows the inferred PFOS concentrations in the NACC Precinct Area and Figure 3b shows the inferred PFOS concentration in the SE Runway area. To date testing has shown no PFOS groundwater contamination in the NW Runway area.

It should be noted that the displayed concentrations are inferred based on collation of as many data points as available at the time of drafting to provide as much accuracy and detail as possible. It is noted that the data collated to prepare the figures was collected at different times and by different groundwater sampling methods. These differences were noted upon the figure by presenting the data points with different colours as noted within the legend.



Figure 3a Inferred Groundwater PFOS Distribution – NACC Precinct



Figure 3b Inferred Groundwater PFOS Distribution – SE Runway area



5. Soil and Water Acceptance Criteria

Taking into account:

the National Environment Protection Council’s National Environment Protection (Assessment of Site

Contamination) Amendment Measures 2013 (No. 1) (NEPC 2013);

the National Health and Medical Research Council Australian Drinking Water Guidelines and

the ANZECC Australian and New Zealand Guidelines for Fresh and Marine Water Quality 2000,

the Projects’ Environmental Consultants (EES 2015d Appendix B) devised Soil Reuse Criteria (Table 3) and Water Discharge Criteria (Table 4) to inform the criteria in this plan

Onsite Soil Reuse

Table 3 Soil Reuse Criteria

Land Use Scenario

Analyte Units Residential Industrial Sensitive areas

PFCs*

PFOS mg/kg 6 50 No Detection

PFOA mg/kg 16 240 No Detection

6:2 Fluorotelomer sulfonate (6:2 FtS)

mg/kg 60 900 No Detection

PAHs

Naphthalene mg/kg 3 9NL 170

Benzo(a)pyrene mg/kg - - 0.7

Sum of 16 PAHs mg/kg 300 4000

Benzo(a)pyrene TEQ 3 40 -

BTEX

Benzene mg/kg 0.5 360NL 50

Toluene mg/kg 160 560NL 85

Ethylbenzene mg/kg 55 64NL 70

Xylenes mg/kg 40 300NL 105

TRH

>C6 - C10 Fraction mg/kg - 700 -

>C6 - C10 Fraction minus BTEX (F1)

mg/kg 45 950NL 180

>C10 - C16 Fraction mg/kg - 1,000

>C10 - C16 Fraction minus Naphthalene (F2)

mg/kg 110 560NL 120



>C16 - C34 Fraction mg/kg - 2,500 300

>C34 - C40 Fraction mg/kg - 10,000 2,800

Heavy metals

Arsenic mg/kg 100 3,000 100

Cadmium mg/kg 20 900 -

Chromium mg/kg 100 3,600 320

Copper mg/kg 6,000 240,000 170

Lead mg/kg 300 1,500 1,100

Nickel mg/kg 400 6,000 80

Zinc mg/kg 7400 400,000 200

Mercury mg/kg 40 730 -

OCP

Hexachlorobenzene (HCB)

mg/kg 10 80 -

Heptachlor mg/kg 6 50 -

cis-Chlordane mg/kg 50 530 -

Endrin mg/kg 10 100 -

Endosulfan (sum) mg/kg 270 2000 -

4.4`-DDT mg/kg - - 180

Methoxychlor mg/kg 300 2500 -

DDD + DDE + DDT mg/kg 240 3600 -

Aldrin + Dieldrin mg/kg 6 45 -

OPP

Clorpyrifos mg/kg 160 2000 -

PCBs

PCBs mg/kg 1 7 -

* Soil Reuse Criteria for PFCs adopted are in accordance with DCD #8 Department of Defence, Defence contamination directive #8 interim screening criteria: consistency of toxicology or ecotoxicology based environmental screening levels for PFOS, PFOA, 6:2 FtS. Directive Version 1 dated May 2015. Soil Reuse Criterion adopted for PFOS is in accordance with Interim Screening Levels and Management

Options outlined in “Guidance for Managing Perfluorooctane Sulfonate (PFOS) and Perfluorooctanoic Acid (PFOA) Contamination at Commonwealth Sites ( Deliberative DRAFT ONLY for discussion) - Interim Policy Framework - Department of Environment Aug 2015”.

No soil containing PFC levels over residential levels outlined within DCD #8 will be reused.



The project will amend these values, and actions in accordance with any further policy guidance should

Defence advise during construction.

For soil reuse criteria, in general the following has been applied (See EES 2015d Appendix B for details):

Residential criteria is equivalent to HIL-A, HSL-A;

Industrial criteria is equivalent to HIL-D, HSL-D, Management Limits; and

Sensitive areas criteria is equivalent to EILs, ESLs for residential public open space (assuming

coarse textured soil).

Defence will provide a Land Use Scenario map, developed by their Environmental Consultants, showing where soil of each reuse category can be reused or stockpiled on the Base. This map will be appended to the plan when it is available. In the interim Defence will advise on a case-by-case basis appropriate locations for soil reuse or stockpiling based on the soils Reuse Criteria classification.

The soil reuse criteria provided in Table 3 above should be applied in the following way:

any values less than or equal to the relevant soil reuse criteria are considered acceptable for

reuse or stockpiling within corresponding land use areas;

any values exceeding the criteria will require either: o risk assessment to determine site-specific values by the Project Environmental

Consultant; o placement of relevant soil in a less conservative land use scenario area; o treatment to lower the level of contamination to below the soil reuse criteria; o stockpiling in stockpile locations approved by Defence, with erosion and leachate

controls appropriate to the contaminant type(s) o disposal as waste (to an appropriately licenced waste facility).

Onsite Water Discharge

Table 4 Water Discharge Criteria:

Analyte/ Receptor Unit Water discharge Criteria

Perflourinated Compounds

PFOS µg/L 0.2

PFOA µg/L 0.4

6:2 FTS µg/L 5.0

Nutrients/ Ions

Ammonia (as NH3-N) mg/L 0.9A

Nitrate (as NO3) mg/L 10.6^

Nitrite (as NO2) mg/L 3

Fluoride mg/L 1.5

Dissolved Metals/ Metalloids

Aluminium mg/L 0.055

Arsenic mg/L 0.01

Cadmium mg/L 0.0002H

Hexavalent Chromium mg/L 0.001

Copper mg/L 0.0014H

Lead mg/L 0.0034H

Manganese mg/L 0.5

Nickel mg/L 0.011H

Zinc mg/L 0.008H



Mercury mg/L 0.0006

TPH/ TRH

TRH C6-C10 µg/L 150D

TRH >C10 µg/L 600D

MAHs

Benzene µg/L 1

Toluene µg/L 800

Ethyl-benzene µg/L 300

Total Xylenes µg/L 550

HACs (aliphatic)

Vinyl chloride µg/L 0.3

cis-1.2-Dichloroethene µg/L 70U

Trichloroethene (TCE) µg/L 20W

Tetrachloroethene (PCE) µg/L 50

The data in Table 4 has been derived for a range of relevant receptors, beneficial uses and chemicals of concern for groundwater and surface waters based upon potential receptors for the site.

Given the potential range of relevant receptors and beneficial uses with regard to groundwater at the site, the water discharge criteria adopted for the purpose of this plan have been based on selection of the most conservative values across the two most applicable scenarios set out by EES. As such the criteria in Table 4 are set at the criteria for freshwater ecosystems, or for drinking water guidelines protective of human health, whichever is the lower.

The water discharge criteria provided in Table 4 above should be applied in the following way:

any values less than or equal to the criteria are considered acceptable for discharge,

any values exceeding the criteria will trigger either

o further assessment by the Project Environmental Consultant giving consideration to the

most relevant receptor, or.

o treatment to lower the level of contamination to below the discharge criteria ; or

o disposal as waste (to an appropriately licenced waste facility).

Important - no water is to be discharged offsite, either overland or to stormwater drains or sewers.

Offsite disposal as waste

Where soil or water is found to be unsuitable to reuse or discharge on site, it will be classified using NSW EPA Waste Classification Guidelines.

Once classified soil or water will be disposed of at appropriately licenced waste facilities.

It should be noted that currently there are no waste classification guidelines for PFOS and PFOA. As such material containing these chemicals requires specific case by case classification from NSW EPA.

To classify soil the EPA has indicated that they will require tests for leachability (TCLP) in addition to total PFOS / PFOA concentrations.



6. Key Legislation / Standards / Guidance

Federal

Environment Protection and Biodiversity Conservation Act 1999

Defence Contamination Directive #8 Interim Screening Criteria : Consistency of Toxicology or Ecotoxicology based Environmental Screening Levels for PFOS, PFOA, 6:2 FTS There are no national or state recognised guidelines or limits for appropriate handling or disposal of PFOS / PFOA contaminated soil or water. In the absence of national guidelines Defence have published interim screening guidelines for use on Defence sites. These guidelines are based on industry collaboration and current understanding. Where PFOS / PFOA concentrations exceed the screening levels, a risk assessment carried out by appropriately qualified specialists is required to set site specific criteria.

State

While state legislation does not apply to Defence activities, Defence aims to be good environmental stewards and comply with State government legislation and policies to the extent that these do not conflict with Commonwealth legislative obligations or compromise operational objectives or capability.

NOTE: State Legislation does apply to Activities carried out outside of Defence land.

Protection of the Environment Operations Act 1997;

Contaminated Land Management Act 1997

NSW EPA Waste Classification Guidelines 2014

It should be also noted that currently no state limits or guidelines exist for disposal of waste contaminated with PFOS or PFOA. As such specific approval will be required for disposal of this material from the NSW EPA. EPA advice is that in order to make a determination on classification of PFOS / PFOA contaminated waste, in addition to the standard waste classification testing they will require total and leachable (TCLP) PFOS /PFOA analysis results.

7. Site Control Measures:

Given the history of the site and previous waste management practices there is the potential to encounter contaminated soil or water across any area of the Base, as such in addition to the specific controls described below, suspected contamination finds will be managed via the Unexpected Contamination Procedure as outlined in Appendix A



8.0 Control Measures

The following control measures will be applied to the NACC Project’s activities to control and mitigate the environmental and health risks identified in Section 4, and manage compliance with the legislation, standards and guidelines identified in Section 6

.Control Measures Timing Methodology Responsibility Monitoring and Reporting Performance Measure

8.1 Design

Design the project and identify construction methods that will minimise exposure of contaminated materials.

Design phase NACC precinct, South East and North East runway construction will be constructed on fill, minimising requirement for excavation of potentially contaminated materials.

CM Impacts, Hazards and Risk Assessment

Design minimises disturbance of contaminated material

Minimise exposure of known contamination

Prior to construction

Where identified contamination presents significant risk to the environment or health, if possible, the design will be changed to avoid disturbance or exposure of the contamination.

CM Design reports Minimise exposure of contaminated materials

8.2 Planning / General

Source independent contamination advice and recommendations from a qualified contamination specialist.


A qualified independent environmental consultant will be engaged to conduct testing and provide advice on contamination issues.

CM Environmental Consultant Environmental Earth Sciences (EES) contract and reports

Environmental Consultant engaged

Identify areas of contamination within the NACC Project Area


Sampling and Analysis Plan (SAP) will be developed by the project Environmental Consultants for the NACC Project Areas based on NSW EPA sampling and analysis guidelines and industry best practice.

Consistent with the SAP Soil and water testing will be conducted by qualified environmental consultants in advance of construction to identify any contamination, type, locations and levels.

CM / Environmental Consultant (EES)

Contamination Assessment Report (Coffey 2012)

Sampling and Analysis Plan

Ongoing testing and reports by EES

Sampling and Analysis Plan

Contamination identified and recorded

Record and communicate known areas Prior to Potential contamination risks have been mapped and provided as part of this plan

CM / Environmental Contamination Maps

Contamination Assessment

Known contamination risks




of contamination.

construction (See Section 4)

Where possible, subject to Defence operational restrictions, use physical demarcation to identify areas of contamination.

Consultant (EES) Report

Specialist consultant reports

communicated.

Contamination Maps enlarged and posted in site office

All site personnel will be trained in the requirements of this plan.

At all times Site induction, toolbox talks, pre-starts and targeted training.

Specific training will be provided to site personnel with responsibilities for contamination and waste management.

Ongoing toolbox talks will be delivered to relevant personnel and will detail issues arising from inspections and proactive measures to minimise contamination impacts.

CM Training and induction records All personnel attend site induction.

Toolboxes and training delivered as required.

Plan work to manage known contamination

At all times Work in areas of known contamination will be planned with the location, depth and nature of the contamination as a prime consideration.

A qualified environmental consultant will provide guidance on appropriate controls to manage environmental risk and occupational exposure.

Where the consultant’s advice recommends it, the environmental consultant will supervise work in contaminated areas.

CM/SM/ Environmental Consultant (EES)

Work Method Statements


Work planned and conducted to minimise risk of contamination exposure

Contamination management measures from this plan will be included in relevant activity or area specific Safe Work Method Statements (SWMSs).

CM/SM/ Subcontractor Safe Work Method Statements

Site Inspections

Methods to minimise risk of exposure of contaminated material recorded and communicated




A site specific Erosion and Sediment Control Plan (ESCP) will be developed for earthworks areas to minimise erosion and control eroded sediments to prevent off site migration of potentially contaminated material.

SM/ Subcontractor ESCP Controls to minimise exposure or spread of contaminated material recorded and communicated

Track soil movement across the project to minimise risk of cross contamination of previously uncontaminated areas.

During earthworks

Spoil movement will be tracked across the project.


Soil tracking report.

Soil placement shown to be consistent with requirements of this Plan

Manage chemical and fuel storage and use onsite to prevent new contamination of soil and groundwater.

At all times See the Hazardous and Dangerous Goods Management Plan for details of chemical storage and use mitigation measures

CM/SM/ Subcontractor Site Inspections Chemical storage and use in accordance with H&DG Management Plan requirements

8.3 Contaminated Soil

Test for soil contamination in advance of construction activities in the NACC Project Area


Consistent with the Sampling and Analysis Plan, qualified Environmental Consultants to conduct soil sampling in advance of construction activities.

Consultants to compile test results and tabulate with reference to the Soil Reuse Criteria (Section 5)

CM/ SM/ EM/ Environmental Consultant (EES)

Sampling and Analysis Plan.

Test reports

Contamination status with reference to Soil Reuse Criteria is confirmed prior to commencing construction in an area.

Test excess soil from trenches and minor excavations that has not been previously tested prior to excavation

As required Soil from trenches and minor excavations will be returned to the trench or excavation as backfill.

Excess material will be stockpiled and tested with reference to the soil reuse criteria to determine appropriate reuse or stockpiling.

SM / Sub contractor Test reports Excess material from trenches and minor excavations is tested and managed in accordance with the Soil Reuse Criteria

Minimise worker exposure to known contamination


WHS precautions appropriate to the anticipated contamination will be included in the SWMS and put in place prior to excavation commencing.

CM/SM/ Subcontractor/ Environmental Consultant (EES)

Safe Work Method Statements


Risk of exposure to contaminated materials effectively managed




A qualified environmental consultant will provide guidance on appropriate controls to manage occupational exposure.

Minimise worker exposure to known PFOS / PFOA contamination in soil

During excavation, and placement of spoil.

Test soil and groundwater in advance of NACC construction activities

In areas where the PFOS / PFOA Human Health Threshold Concentrations are exceeded (see Section 4 Risks) minimise exposure by:

Ensuring hands and face are

washed prior to eating, even if

gloves are worn

Use disposal coveralls where risk of

contaminating clothing exists.

Use of water-proof disposable nitrile

gloves (either instead of or in

conjunction with other gloves);

Use of P2 dust masks associated

with use of a water truck that is

spraying water drawn from areas

where the triggers are exceeded;

If skin contact with contaminated

water above the trigger level is

unavoidable, ensure sleeves rolled

down and change wet clothing

immediately post-work activities.

CM/SM/ Subcontractor Safe Work Method Statements Risk of exposure to PFOS / PFOA contamination effectively managed

Minimise worker exposure to known Benzo(a)pyrene contamination in soil

During excavation, and placement of spoil.

PPE requirements for pyrogenic material (including coke, ash, clinker, slag is limited to either wearing gloves or washing hands after contact

Where gas condensates (tar, benzol, naphtha oil, ammoniacal liquor, creosote, pitch) and particulates (soot)are present, PPE for BaP exposure include:

CM/SM/ Subcontractor Safe Work Method Statements Risk of exposure to Benzo(a)pyrene contamination effectively managed




gloves,

full sleeves and pants,

where volatile chemicals are also

present carbon filtered respirators

should be available for use if

required.

If soots are present P2 dust masks

should also be available (if

respirators are not already being

used).

Respirators and masks are not necessary from a chronic (long-term health) perspective, and are designed to alleviate acute (short-term) effects such as nausea, vomiting and headaches.

Minimise cross contamination of clean soil with contaminated soil

During excavation and earthworks

Excavate and separately stockpile clean strata from suspected or known contaminated soil strata.

All soil excavated from known contaminated areas (ie exceeding Industrial Soil Reuse Criteria, Special Waste or Hazardous Waste) to be managed under guidance from a qualified environmental consultant.


Work Method Statements Minimise exposure of contaminated materials

Prevent erosion of contaminated soils from construction areas


Apply water sprays or dust suppressants to control dust if required when working in contaminated areas.

Control water sprays to prevent excess water runoff.

Stop dust generating activities during dry windy conditions if dust from potentially contaminated areas cannot be otherwise controlled.

CM/SM/ Subcontractor Work Method Statements

ESCPs

Site inspections

No erosion and spread of contaminated soils from construction areas




Erosion and Sediment controls will be used to prevent contaminated material being washed into water courses or drains.

Control dust generation and monitor to confirm potentially contaminated dust is not being spread across or off the site.


Construction teams to control dust and visually monitor for dust generation and migration from the NACC project areas.

Where there is potential for contaminated dust to have left work areas, the project Environmental Consultants will advise on appropriate testing to sample for airborne dust contamination.

Based on the outcome of testing the project Environmental Consultants will advise what further action is required.


Monitoring results No exposure of workers or public to contaminated dust.

Monitor excavations for signs of contamination – Unexpected Finds


During excavation works, the soil will be

monitored for signs of contamination.

Signs of contamination would include:

Unusual odours, eg fuel odour or

sewage odours.

Unusual soil colour change, eg black

staining, yellow or other brightly

coloured material.

Foreign materials: eg asbestos,

construction waste materials, military

items, ash.

Should indication of contamination be discovered, work in that excavation must stop, the Site Supervisor be notified and the Unexpected Contamination Procedure will be followed. (Refer Appendix A)

Note: When working in areas of known

SM/ Subcontractor Site inspections

Ongoing observation

Test reports and consultants recommendations

Work in the area of suspected contamination stopped immediately upon the identification of potentially contaminated soil or water.




contamination the appropriate

environmental and WHS controls

described in this plan must also be

implemented.

Determine nature of unexpected contamination finds and manage appropriately


Samples of the suspected contaminated material will be collected by an appropriately qualified environmental consultant and tested at a NATA accredited lab to determine the type and concentration of contaminants present and advise appropriate management controls consistent with the requirements of this plan.

SM/ Environmental Consultant (EES)

Test reports Suspect contamination is tested to confirm nature of contamination and potential disposal / reuse options

Manage stockpiles to prevent pollution from potentially contaminated materials


Temporary stockpiles may be created as required within the NACC Project Area

Temporary stockpiles outside the NACC Project Area require approval by the Base Redevelopment Coordination Officer (in consultation with relevant stakeholders)

All temporary stockpiles will be removed before completion of the project.

CM/SM ESCP

Stakeholder Coordination Meeting Minutes

Site inspections

Specific stockpile approvals

Temporary stockpiles established only in appropriate locations, and removed before completion of the project.

Long-term stockpiles for material that is unsuitable for reuse by the NACC Project requires approval from the Base Redevelopment Coordination Officer (in consultation with relevant stakeholders)

CM/SM Stakeholder Coordination Meeting Minutes

Specific stockpile approvals

Long-term stockpiles only established in Defence approved locations.

Stockpile approvals will include details of the material type (including Soil Reuse Criteria) to be stockpiled and environmental controls to be installed to prevent pollution from potential contaminants.

CM/SM/EM Specific stockpile approvals

ESCPs

Stockpiles to be planned, and setup so as to not cause pollution




Stockpile locations will be identified and prepared prior to commencing excavation in an area of known contaminated material.

SM/ EM ESCP

Site inspections

Contaminated soil stockpiled appropriately as per approvals

Contaminated spoil stockpiles will be designed to minimise the risk of causing pollution of soil or water by contaminated soil or leachate

The Project Environmental Consultant will provide advice on appropriate stockpile design and management measures (eg impermeable base and/or covers, leachate collection etc.)

Where possible contaminated stockpiles should be located away from, drainage lines and waterways, Hunter Water Corp Bores and Base personnel residential and working areas. Where this cannot be achieved additional layers of controls must be employed to further reduce the risk of the stockpiled material causing pollution.

SM/EM/ Environmental Consultant (EES)

ESCP

Site inspections

Contaminated soil stockpile set up with appropriate controls to control risk of causing pollution.

Contaminated soil stockpiles do not cause pollution.

Contaminated soil stockpiled in clearly signposted, safe and protected location away from water courses/ sensitive receptors.

Excavated material that has indications of contamination, eg unusual odour, colour, or consistency, if safely possible, should be placed on impervious surface, and covered until the nature of the contamination can be determined by the Projects Environmental Consultant.

Where ever possible suspected contaminated material will not be excavated and will be left in place until the nature of the contamination and appropriate management measures can be determined.

SM/ EM/ Environmental Consultant (EES)

ESCP

Site inspections

Risk Assessment

Potentially contaminated material is identified, assessed and is handled such that it does not cause pollution.

Management of potentially contaminated material will not cause a FOD risk to aircraft.




In Airside Areas, a risk assessment for Foreign Object Damage risk will be carried out in consultation with Defence to consider most appropriate options for management of leachate (eg covering contaminated material, or other management methods such as bunds or relocation of the suspect material to a suitable location pending receipt of analysis results).

Water collected in contaminated soil bunds will be tested prior to discharge.

Water must be tested as per the controls described in Section 8.5 Water Contamination Control Measures, and must meet the Water Discharge Criteria described in Section 5 prior to discharge.

Where collected water exceeds the water discharge criteria the Project Environmental Consultants will advise on appropriate treatment or reuse / disposal options


Site inspections

Test results

Waste receipts / disposal dockets

Water collected in contaminated soil bunds to only be discharged on site if it meets the water discharge criteria.

Maximise onsite reuse of excavated spoil

At all times The Environmental Consultants will determine Soil Reuse Criteria classification (see Section 5) based on soil sampling test results.

For bulk earthworks areas this may developed into maps showing the soil classification in areas to excavated for communication to work teams

This classification will determine where soil from that area can be reused or stockpiled.

Defence have consulted with Environmental Consultants to develop a

SM / Environmental Consultant (EES) / Sub Contractors

Specialist Consultant reports

Land Use Sensitivity Map

Disposal receipts / disposal dockets

Maximise onsite reuse of excavated soil.

Appropriately stockpile or dispose of excess or unsuitable soil.




Land Use Sensitivity Map showing the appropriate land use designations within the NACC Project Area.

Material can potentially be reused or stockpiled without further environmental controls in areas of equal or lower Land Use Scenario ie

Industrial Reuse Criteria soil

can be reused or stockpiled in

areas zoned as Industrial

sensitivity

Residential Reuse Criteria soil


areas zoned as Residential or

Industrial sensitivity

Sensitive Reuse Criteria soil


areas zoned as Sensitive,

Residential or Industrial

sensitivity

Material that exceeds the Industrial Reuse Criteria will be stockpiled at Defence approved location on site for subsequent decision by Defence on treatment, disposal or reuse of the soil.

The stockpiles (locations are to be confirmed) will be constructed with appropriate pollution controls (e.g. bunding, impervious base / cover and leachate control).

Material classifying as Special or Hazardous Waste under NSW EPA waste classification guidelines will be sent to an appropriately licenced waste




facility for disposal. Special or Hazardous waste containing PFC’s will require specific classification by the NSW EPA prior to disposal.

Where there is an excess of material suitable for reuse within the available Land Use Scenario areas, it will be moved to the long-term stockpile location for subsequent decision by Defence on treatment, reuse or disposal.

Disposal of contaminated soil At all times Material classifying as Special or Hazardous Waste under NSW EPA waste classification guidelines will be sent to an appropriately licenced waste facility for disposal.

Soil unable to be reused on site and requiring disposal will be classified using the EPA Waste Classification Guidelines (2014)

Special or Hazardous waste containing PFC’s will require specific classification by the NSW EPA prior to disposal.

Currently no waste classification guidelines exist for soil contaminated with PFOS or PFOA. As such specific EPA approval will be required for any PFOS or PFOA contaminated material leaving site for disposal.

To provide waste classification determination for PFOS / PFOA contaminated material the EPA will require both the total and leachable (TCLP) PFOS /PFOA analysis results.

Waste classification sampling will be performed by an appropriately qualified


Test reports

Disposal receipts / disposal dockets

For offsite reuse – signed Section 143 notices or other EPA approved certification.

Contaminated waste disposed of to appropriately licenced waste facilities




environmental consultant and testing will be carried out by a NATA accredited laboratory

Soil disposal will be to appropriately licenced waste facilities

Waste classification and disposal records will be maintained for all soil leaving site.

Off-site transport of contaminated material to licensed waste facility for disposal.

At all times Contaminated soil must only be transported to licenced waste facilities lawfully able to accept the material

Soil loads leaving the premises should be covered. Truck covers must be suitable to effectively cover the load and should be maintained in working condition.

Tracking of contaminated soil onto public roads is to be prevented through use of rumble grids or wheel washes where required.

Should contaminated soil be tracked out onto public or base roads it must be immediately cleaned up using a road sweeper.

SM /Subcontractor Disposal receipts / disposal dockets

Site inspections

Contaminated waste lawfully transported.

No tracking or spillage of contaminated material onto public roads

No dust from contaminated material haulage.

8.4 Unexpected Contamination Procedure

All excavations will proceed with caution with respect to contamination. Contamination hotspots may be encountered at any location on the project.


If unexpected contamination is encountered, stop work and follow the Unexpected Contamination Procedure (Appendix A)

SM/Subcontractor Site inspections Unexpected contamination is identified and managed appropriately




8.5 Contaminated Groundwater

Test water prior to dewatering and discharge to prevent pollution of aquifers or waterways

Prior to dewatering

Water in the area of planned dewatering must be tested prior to approval of the Dewatering Permit to identify potential contamination.

Water that is in contact with natural ground (ie ponded on the ground, in an excavation or to be dewatered from groundwater) must be tested before dewatering.

The Minimum Analysis Suite required for dewatering discharge approval is:

TRH(C6-C40)/BTEXN/PAH

(with silica gel clean up)

Dissolved metals (As, Cd, Cr,

Cu, Ni, Pb, Zn, Hg, Fe, Al, Co)

PFOS/PFOA

pH

Where recent test results are available for the area of dewatering, these may be used to determine the contamination risk.

All testing is to be carried out by a NATA accredited laboratory (with the exception of field tests).


Dewatering Permit

Test results

Monthly reports

Site inspections

Discharged water remains within acceptable parameters

Dewatering from ‘clean’ surface areas Prior to dewatering

Rainwater ponded on imported Virgin Excavated Natural Material or sealed areas (eg concrete or tarmac) that is otherwise free of signs of contamination does not require testing prior to dewatering.

Where there is any indication or risk of contamination, testing as described


Dewatering Permit

Test results

Site inspections





above must be completed prior to discharge.

Minimise worker exposure to known contamination


WHS precautions appropriate to the anticipated contamination will be included in the SWMS and put in place prior to excavation commencing.

A qualified environmental consultant will provide guidance on appropriate controls to manage occupational exposure.

CM/SM/ Subcontractor/ Environmental Consultant (EES)

Safe Work Method Statements


Risk of exposure to contaminated materials effectively managed

Minimise worker exposure to known PFOS / PFOA contamination in water

During excavation, dewatering and groundwater contact.

In areas where the PFC Human Health Threshold Concentrations (see Section 4) are exceeded minimise exposure by:

Ensuring hands and face are

washed prior to eating, even if

gloves are worn

Use disposal coveralls where risk of

contaminating clothing exists.

Use of water-proof disposable nitrile

gloves (either instead of or in

conjunction with other gloves);

Use of P2 dust masks associated

with use of a water truck that is

spraying water drawn from areas

where the triggers are exceeded;

If skin contact with contaminated

water above the trigger level is

unavoidable, ensure sleeves are

rolled down and change wet

clothing immediately post-work

activities.

CM/SM/ Subcontractor Safe Work Method Statements Risk of exposure to PFOS / PFOA contamination effectively managed

Minimise potential for modification of groundwater flow patterns, groundwater

During excavation and

Dewatering of excavations will be at the minimum required to enable safe

Cm/SM/ EM/Environmental Work Method Statements Groundwater flow patterns or levels are not excessively




drawdown or modification of groundwater contamination migration.

earthworks construction.

Where extensive dewatering is required:

consider alternative

construction methodologies

reduce the dewatering

requirement, or

seek specialist consultants

advice on actions to minimise

groundwater dewatering

requirements

For instances of pumped reinjection obtain specialist consultants advice to minimise potential for significant modification of groundwater contamination flow.

Consultant (EES) Hydrogeologist / consultant reports

modified by construction activities

Minimise generation of potentially contaminated groundwater


Dewatering of excavations will be at the minimum required to enable safe construction.

Design erosion and sediment controls to direct runoff away from open excavations where applicable.

Limit the time excavations in areas of known contamination are open and require dewatering.

CM/SM/EM Work Method Statements

ESCP

Site Inspections

Dewatering requirements are minimised

Control dewatering activities to prevent pollution of aquifers or waterways.

Prior to dewatering

No discharge of dewatered groundwater offsite, either through overland flow or discharged to stormwater drains or sewers.

All dewatering will require a Dewatering Permit approved by the Managing Contractor.

The Dewatering Permit will detail the

SM/EM Dewatering Permit

Site Inspections

Dewatering does not cause pollution of waterways or aquifers




dewatering, required treatment or additional testing and location and manner of discharge.

All dewatering permits will be time limited and will require renewal should the details of dewatering location, treatment or discharge methods change.

Monitor water quality during dewatering to prevent pollution of aquifers or waterways

During dewatering

Ongoing visual assessment of odour, colour and sheen will continue for the duration of the dewatering.

Where changes in any of the above parameters indicate contamination, dewatering will stop and advice from the Managing Contractor sought.

Where water is found to be below the Water Discharge Criteria and is being discharged without treatment, one water sample will be collected each day of dewatering and tested for the Minimum Analysis Suite described above.

Where the test results exceed the Water Discharge Criteria (see Section 5) dewatering will stop and advice from the Project Environmental Consultant will be sought.

Where test results are seen to be trending towards exceeding the Water Discharge Criteria the Project Environmental Consultant will investigate the source of the contamination and provide advice to minimise the potential of exceedance.

SM/ EM/Environmental Consultant (EES)

Dewatering Permit

Test results

Monthly reports

Site inspections


Where pH testing indicates unusually low pH, or a falling pH, dewatering will stop and investigations for ASS commence

SM/ EM/ Sub Contactor Dewatering Permit

Test results

Dewatering activities do not cause oxidation of Potentially Acid Sulphate Soils, or




(See Acid Sulphate Soil Management Plan)

Monthly reports

Site inspections

migration of acidic water from Actual Acid Sulphate Soils

Dewatering discharge During dewatering

Where water test results are below the Water Discharge Criteria concentrations this water may be discharged in accordance with the approved Dewatering Permit without any further restrictions.

Anticipated dewatering discharge routes may include:

Dust suppression – water carts and

sprays (where suitable)

Surface discharge (setup so as to

minimise sediment scour) and

subsequent infiltration – but no offsite

surface discharge.

Detention basins and infiltration

Pumped reinjection

Note no discharge to stormwater drains, sewer or off site is permitted.

SM/ EM/ Sub Contactor Work Method Statements

Site inspections

Waste receipts/dockets

Test reports

Dewatering Permits

Discharge of collected ground water is managed to maximise reuse and prevent environmental harm.

Management of water that exceeds the Water Discharge Criteria

During dewatering

Where water contamination levels exceed the Water Discharge Criteria water must be treated to lower the level of contamination to below the discharge criteria, or be disposed of as waste to an appropriately licenced waste.

SM/ EM/ Sub Contactor Test reports

Dewatering Permits

Waste receipts/dockets

Dewatering does not discharge water that exceeds the Water Discharge Criteria

Operation of Water Treatment Plant to achieve Water Discharge Criteria Limits

As required Water treatment may be provided to reduce the concentration of contaminants to below the Water Discharge Criteria.

The Water Treatment Plant (WTP) will be designed to reduce the concentration of contaminants encountered on the Project

SM/ EM/ Water Treatment Contractor

WTP Operational and Environmental Management Plan(s)

Commissioning records

Test reports

Water treatment plant is operated efficiently to reduce water contamination to below Water Discharge Criteria levels




to below the relevant Water Discharge Criteria.

Prior to operational use, commissioning trials will demonstrate the WTP’s capability to achieve the required contaminant reduction.

Water discharge from the WTP will be sampled and tested for the Minimum Analysis Suite at a frequency set out in the WTP operational management plan

The WTP discharges will comply with all the Water Discharge Criteria not just the chemical of concern for which it was designed.

Where treated water discharge monitoring shows exceedance of the Water Discharge Criteria the WTP is to stop discharging water pending investigation of the cause of the exceedance and measures put in place to prevent reoccurrence.

An Operational and Environmental Management Plan will be provided by the WTP supplier / operator detailing:

commissioning and operation

of the plant,

monitoring to confirm efficient

operation of the plant,

waste stream management,

including waste classification

and disposal routes.

Environmental controls for

issues such as chemical

storage, spills, leaks and

Waste dockets / receipts




discharge criteria

exceedances.

Waste streams generated by the WTP will be classified as per NSW EPA waste Guidelines prior to disposal to an appropriately licenced waste facility.

No WTP waste stream is to remain on the Base at the end of the NACC Project.

Use of bore water for construction to minimise potable water use

As required Where bore water has been tested and shown to be below the Water Discharge Criteria, this water may be used for construction purposes such as dust suppression or compaction.

SM / Sub Contractor Test reports Bore water used does not exceed the Water Discharge Criteria.

CM – Construction Manager, SM – Site Manager, EM – Environmental Manager



References:

Coffey 2012 Coffey Environments (2012), Contamination Report New Air Combat Capability (NACC), Williamtown, RAAF Base, NSW;

EES 2015a Environmental Earth Sciences, Soil sample results and locations to date (18/09/2015) at the New Air Combat Capability (NACC), RAAF, Williamtown, NSW.

EES 2015b Environmental Earth Sciences Water sample results and locations to date (18/09/2015) at the New Air Combat Capability (NACC), RAAF, Williamtown, NSW

EES 2015c Environmental Earth Sciences, 115042 Unexpected Find Protocol 1 Letter Report

EES 2015d Environmental Earth Sciences, Soil reuse and groundwater discharge criteria with regard to the New Air Combat Capability (NACC) redevelopment at RAAF Williamtown NSW

EES 2015e Environmental Earth Sciences RAAF Airbase Williamtown, NACC Precinct – Occupational Exposure Health Risk Assessment for Perfluorinated Compounds (PFCs)

Hunter Water Corporation 2015, RAAF Base Williamtown Stage 2 Environmental Investigation, Community Consultation - 16 Sept 2015, Hunter Water Presentation

DCD #8 Department of Defence, Defence contamination directive #8 interim screening criteria: consistency of toxicology or ecotoxicology based environmental screening levels for PFOS, PFOA, 6:2 FtS. Directive Version 1 dated May 2015.

URS 2015, URS, Stage 2 Environmental Investigation Report AFFF PFAS, RAAF Base Williamtown, Williamtown NSW



Appendix A



Appendix B

Environmental Earth Sciences, Soil reuse and groundwater discharge criteria with regard to the New Air Combat Capability (NACC) redevelopment at RAAF Williamtown NSW

11 November 2015 Lend Lease Building Pty Ltd PO Box 41 Williamtown NSW 2314 Attention: Environmental Manager, Facilities for NACC Dear James RE: Soil reuse and groundwater discharge criteria w ith regard to the New Air Combat Capability (NACC) redevelopment at RAAF Williamtown NSW.

1.0 Introduction Environmental Earth Sciences NSW was requested by Lend Lease to prepare a letter detailing appropriate soil reuse and water discharge acceptance criteria generated by the New Air Combat Capability (NACC) redevelopment project.

2.0 Context Previous investigations have identified chemicals of concern (COCs) within soil and groundwater at the site, these include (after GHD 2012, Coffey 2012, URS 2015, Environmental Earth Sciences 2015):

• Perflourinated compounds (PFCs);

• Poly-aromatic hydrocarbons (PAH), total recoverable hydrocarbons (TRH), benzene, toluene, ethylbenzene, xylenes (BTEX);

• Heavy metals;

• Organochlorine Pesticides (OCPs);

• Organophosphate Pesticides (OPPs);

• Poly chlorinated biphenyls (PCBs); and

• Chlorinated solvents. Previous investigations (GHD 2012, Coffey 2012, URS 2015, Environmental Earth Sciences 2015) have evaluated the potential key sensitive receptors for the site.

115042 Lt12 SoilGW criteria V2 2

The identified sensitive receptors include the following:

• Department of Defence (DoD) and/ or DoD representatives or residents who work, visit or live at the site;

• visitors, contract workers and other authorised persons;

• groundwater ecosystem directly beneath the site;

• nearby major surface water courses (including Lake Cochran, Tiligerry Creek leading to Port Stephens and Fullerton Cove, all located within ~1 km of the site) that are both groundwater discharge zones and groundwater dependent ecosystems;

• groundwater users to the south of base including vegetation, animals and humans; and

• Hunter Water Corporation Pumping Stations PS7 and PS9, which are located near the base and are periodically used to access the Tomago Sandbeds Aquifer beneath the site as an supplementary water source for the Newcastle and surrounds potable water supply.

With particular reference to PFCs, Defence contamination directive #8 (DoD 2015) has established interim screening guidelines for Defence sites. As yet there are no established guidelines for PFCs within the NSW regulatory framework. DCD#8 has been used to establish the concentration levels as referred to in Tables 1 and 2 below.

3.0 Soil Reuse Criteria In accordance with current legislation, Environmental Earth Sciences refers to the National Environment Protection Council (NEPC, 2013) for site assessment criteria to establish beneficial reuse options under different land use settings. Typically for contaminant concentration to be considered acceptable for the respective land use criteria, the data set must conform to the following requirements:

• the 95% upper confidence limit (UCL) of the arithmetic mean of analytical results is below the site criteria;

• the arithmetic (or geometric in cases where the data is log normally distributed) mean is below the site criteria;

• the standard deviation is less than 50% of the site criteria; and

• no single sample analytical result is greater than 250% of the site criteria. Soil investigation levels have been based upon NEPC (2013), Schedule B(1): Guidelines on the Investigation Levels for Soil, and include:

• Health investigation level (HIL) human exposure setting A and C (residential and Public open space) and D (Commercial/ Industrial);

• Ecological investigation levels (EILs) for residential and public open space, and Commercial/ Industrial, aged soil;

• Ecological Screening Levels (ESLs) for TRH fractions and BTEXN in soil for residential and public open space, and Commercial/ Industrial, (assuming coarse textured soil such as sand);

• Management Limits (MLs) for TPH/ TRH in soil; and


• Health Screening Levels (HSLs) for Petroleum Hydrocarbons in Soil (sand, 0-<1m). A table including all investigation levels for a wide range of chemicals and potential land-uses in soil has been provided in Table 3 Attachment 1 for reference purposes. For soil reuse criteria (Table 1), in general the following has been applied:

• Residential criteria is equivalent to HIL-A, HSL-A or DCD#8;

• Industrial criteria is equivalent to HIL-D, HSL-D, Management Limits or DCD #8; and

• Sensitive areas criteria is equivalent to EILs, ESLs for residential/ public open space (assuming coarse textured soil) or DCD#8.

The soil reuse criteria provided in Table 1 below should be applied with the following methodology:

• any values less than or equal to the relevant soil reuse criteria are considered acceptable for its land use scenario; and

• any values exceeding the criteria will require either:

o risk assessment to determine site-specific values;

o placement of relevant soil in a less conservative land use scenario;

o treatment; or

o disposal as waste.

TABLE 1 SOIL REUSE CRITERIA


PFCs

PFOS mg/kg 6 90 0.91

PFOA mg/kg 16 240 3.73

6:2 Fluorotelomer sulfonate (6:2 FtS)

mg/kg 60 900 -

PAHs

Naphthalene mg/kg 3 9NL 170

Benzo(a)pyrene mg/kg - - 0.7

Sum of 16 PAHs mg/kg 300 4000

Benzo(a)pyrene TEQ 3 40 -

BTEX

Benzene mg/kg 0.5 360NL 50

Toluene mg/kg 160 560NL 85

Ethylbenzene mg/kg 55 64NL 70

Xylenes mg/kg 40 300NL 105



TRH

>C6 - C10 Fraction mg/kg - 700 -

>C6 - C10 Fraction minus BTEX (F1) mg/kg 45 950NL 180

>C10 - C16 Fraction mg/kg - 1,000

>C10 - C16 Fraction minus Naphthalene (F2) mg/kg 110 560NL 120

>C16 - C34 Fraction mg/kg - 2,500 300

>C34 - C40 Fraction mg/kg - 10,000 2,800

Heavy metals

Arsenic mg/kg 100 3,000 100

Cadmium mg/kg 20 900 -

Chromium mg/kg 100 3,600 320

Copper mg/kg 6,000 240,000 170

Lead mg/kg 300 1,500 1,100

Nickel mg/kg 400 6,000 80

Zinc mg/kg 7400 400,000 200

Mercury mg/kg 40 730 -

OCP

Hexachlorobenzene (HCB)

mg/kg 10 80 -

Heptachlor mg/kg 6 50 -

cis-Chlordane mg/kg 50 530 -

Endrin mg/kg 10 100 -

Endosulfan (sum) mg/kg 270 2000 -

4.4`-DDT mg/kg - - 180

Methoxychlor mg/kg 300 2500 -

DDD + DDE + DDT mg/kg 240 3600 -

Aldrin + Dieldrin mg/kg 6 45 -

OPP

Clorpyrifos mg/kg 160 2000 -

PCBs

PCBs mg/kg 1 7 -

Notes

1. Sensitive area criteria for Zn, Cu, Ni based on assumption of 0.1% organic carbon, 1% Fe, pH 4.5, and 5 meq CEC as calculated from Schedule B5c NEPAM 2013 based on EC50 data. EIL for CrIII based on 5% clay content

2. mg/kg - milligrams per kilogram;


4.0 Water Discharge Criteria The data in Table 2 has been derived from Tier 1 criteria for a range of relevant receptors, beneficial uses and chemicals of concern for groundwater and surface waters based upon potential receptors for the site. Note that the following criteria have been cited in the allocation of guidelines within Table 2. For reference a summary of concentrations for each beneficial use and receptor under the below guidelines has been provided in Table 4, Attachment 1. It should be noted that NEPC (2013) provides the overarching document for assignment of guidelines and water quality criteria for each receptor under consideration:

• Ecosystems (freshwater):

o ANZECC/ ARMCANZ (2000)/ NEPC (2013);

o DCD#8 Interim Screening Criteria;

• Ecosystems (marine):

o ANZECC/ ARMCANZ (2000)/ NEPC (2013);

• Drinking and Domestic use:

o NHMRC/ NRMMC (2011)/ NEPC (2013);


• Recreational and direct contact:

o NHMRC/ NRMMC (2008);

o NHMRC/ NRMMC (2011);

o ANZECC/ ARMCANZ (2000);


o ANZECC (1992);

• Agriculture: stock-watering;


o NEPC (2013);

o ANZECC (1992);

• Agriculture: irrigation:


o NEPC (2013);

o ANZECC (1992). Given the potential range of relevant receptors and beneficial uses with regard to groundwater at the site the following discharge criteria has been based on selection of the most conservative values across the two most applicable scenarios (Freshwater Ecosystems and drinking water guidelines protective of human health).


The water discharge criteria provided in Table 2 below should be applied with the following methodology:

• any values less than or equal to the criteria are considered acceptable for discharge, whilst any values exceeding the criteria will trigger the need for further assessment; and

• if a concentration level is exceeded, consideration of the most relevant receptor or beneficial use must be undertaken;

o a complete list of concentrations for all potential receptors and beneficial uses is provided in Attachment 1 Table 4 at the rear of this document.

TABLE 2 WATER DISCHARGE CRITERIA – GROUNDWATER



PFOS µg/L 0.2

PFOA µg/L 0.4

6:2 FTS µg/L 5.0

Nutrients/ Ions

Ammonia (as NH3-N) mg/L 0.9A

Nitrate (as NO3) mg/L 10.6^

Nitrite (as NO2) mg/L 3

Fluoride mg/L 1.5

Dissolved Metals/ Metalloids

Aluminium mg/L 0.055

Arsenic mg/L 0.01

Cadmium mg/L 0.0002H

Hexavalent Chromium mg/L 0.001

Copper mg/L 0.0014H

Lead mg/L 0.0034H

Manganese mg/L 0.5

Nickel mg/L 0.011H

Zinc mg/L 0.008H

Mercury mg/L 0.0006

TPH/ TRH

TRH C6-C10 µg/L 150D

TRH >C10 µg/L 600D

MAHs

Benzene µg/L 1

Toluene µg/L 800

Ethyl-benzene µg/L 300

Total Xylenes µg/L 550

HACs (aliphatic)



Vinyl chloride µg/L 0.3

cis-1.2-Dichloroethene µg/L 70U

Trichloroethene (TCE) µg/L 20W

Tetrachloroethene (PCE) µg/L 50

Note(s): 1. D Dutch; A adjust for pH as per ANZECC/ ARMCANZ (2000) Table 8.3.7

2. H Hardness Modified Trigger Values to be adjusted as per ANZECC/ ARMCANZ (2000) Table 3.4.3 3. U USEPA guidelines; W WHO guidelines; ^ adjusted after Hickey (2013)

5.0 Limitations This letter report has been prepared by Environmental Earth Sciences NSW ABN 109 404 006 in response to and subject to the following limitations:

1. The specific instructions received from Lend Lease Building Pty Ltd;

2. The specific scope of works set out in tender no: 251130-13-18 and PO115059 issued by Environmental Earth Sciences NSW;

3. May not be relied upon by any third party not named in this report for any purpose except with the prior written consent of Environmental Earth Sciences NSW (which consent may or may not be given at the discretion of Environmental Earth Sciences NSW);

4. This report comprises the formal report, documentation sections, tables, figures and appendices and must not be released to any third party or copied in part without all the material included in this report for any reason;

5. The report only relates to the site referred to in the scope of works being located at the New Air Combat Capability, RAAF, Williamtown, NSW (“the site”);

6. The report relates to the site as at the date of the report as conditions may change thereafter due to natural processes and/or site activities;

7. No warranty or guarantee is made in regard to any other use than as specified in the scope of works and only applies to the depth tested and reported in this report,

8. Fill, soil, groundwater and rock to the depth tested on the site may be fit for the use specified in this report. Unless it is expressly stated in this report, the fill, soil and/or rock may not be suitable for classification as clean fill if deposited off site; and

9. Our General Limitations set out at the back of the body of this report. Should you have any further queries, please contact us on (02) 9922 1777.


On behalf of Environmental Earth Sciences NSW Project Manager / Report Author

Senior Environmental Scientist Project Director

Senior Geologist Technical Review/ Int ernal Reviewer

Principal Soil Scientist, Hydrogeologist & Risk Assessor 115042 Lt12 SoilGWcriteria V2

6.0 References

Australian & New Zealand Environment and Conservation Council (ANZECC), 1992. Australian water quality guidelines for fresh and marine ecosystems. National Water Quality Management Strategy.

ANZECC/ Agriculture and Resource Management Council of Australia and New Zealand (ARMCANZ), 2000. Australian and New Zealand Guidelines for Fresh and Marine Water Quality. National Water Quality Management Strategy.

Canadian Council of Ministers of the Environment (CCME), 2007. Canadian Water Quality Guidelines for the Protection of Aquatic Life.

Coffey Environments (2012) Contamination report, New Air Combat Capability R8000 Williamtown Airbase; report to Abigroup Contractors Pty Ltd; report ref. GEOWARA21713AA.

Department of Defence (DoD) (2015) Defence contamination directive #8, interim screening criteria – consistency of toxicology or ecotoxicology based environmental screening levels for PFOS, PFOA, 6:2 FTS; report ref. DERP-ID/OUT/2015/AF18370121.

Environmental Earth Sciences (2015) Draft: Data Review, Conceptual Site Model and Data Gaps for redevelopment areas at the New Air Combat Capability (NACC) facility, RAAF, Williamtown, NSW.

Florida Department of Environmental Protection (FDEP) (2005) Contaminant Target Cleanup Levels.

GHD (2013) Department of Defence, RAAF Base Williamtown and Salt Ash Weapons Range, Groundwater Monitoring Program, 2012 Annual Report (ref: 22/16319, dated 8 April 2013);

Hickey, C W, 2013. Updating nitrate toxicity effects on freshwater aquatic species. National Institute of Water & Atmospheric Research Ltd (NIWA), Hamilton, NZ, January 2013.

National Environment Protection Council (NEPC), 2013. National Environment Protection (Assessment of Site Contamination) Amendment Measure 2013 (No.1) (NEPAM, 2013).


National Health and Medical Research Council (NHMRC)/ Natural Resource Management Ministerial Council (NRMMC), 2011. Australian drinking water guidelines. National Water Quality Management Strategy.

NHMRC/ NRMMC, 2008. Guidelines for managing risks in recreational water. Australian Government, February 2008.

The Netherlands Ministry of Housing, Spatial Development and Environment (MHSDE), 2011. Soil Remediation Circular 2009.

United States Environmental Protection Agency (US EPA), 2015. Regional Screening Levels for Chemical Contaminants at Superfund Sites. January 2015.

World Health Organisation (WHO), 2011. Guidelines for drinking water quality, Fourth Edition.


ATTACHMENT 1 TABLES


TABLE 3 SOIL INVESTIGATION LEVELS

Analyte Units HIL/HSL-A HIL/HSL-C HIL/HSL-D MLs EILs/ESLs

PFCs

PFOS mg/kg 6 - 90 - 0.91/4.71

PFOA mg/kg 16 - 240 - 3.73

6:2 Fluorotelomer sulfonate (6:2 FtS) mg/kg 60 - 900 - -

PAHs

Naphthalene mg/kg 3 9NL 9NL - 170/370

Benzo(a)pyrene mg/kg - - - - 0.7/1.4

Sum of 16 PAHs mg/kg 300 300 4000

Benzo(a)pyrene TEQ 3 3 40 - -

BTEX

Benzene mg/kg 0.5 360NL 360NL - 50/75

Toluene mg/kg 160 560NL 560NL - 85/135

Ethylbenzene mg/kg 55 64NL 64NL - 70/165

Xylenes mg/kg 40 300NL 300NL - 105/180

TRH

>C6 - C10 Fraction mg/kg - - - 700 -

>C6 - C10 Fraction minus BTEX (F1)

mg/kg 45 950NL 950NL - 180/215

>C10 - C16 Fraction mg/kg - - - 1,000

>C10 - C16 Fraction minus Naphthalene (F2) mg/kg 110 560NL 560NL - 120/170

>C16 - C34 Fraction mg/kg - - - 2,500 300/1,700

>C34 - C40 Fraction mg/kg - - - 10,000 2,800/3,300

Heavy metals

Arsenic mg/kg 100 300 3,000 - 100/160

Cadmium mg/kg 20 90 900 - -

Chromium mg/kg 100 300 3,600 - 320/530

Copper mg/kg 6,000 17,000 240,000 - 170/230

Lead mg/kg 300 600 1,500 - 1,100/1,800

Nickel mg/kg 400 1,200 6,000 - 80/110

Zinc mg/kg 7400 30,000 400,000 - 200/300

Mercury mg/kg 40 80 730 - -


Analyte Units HIL/HSL-A HIL/HSL-C HIL/HSL-D MLs EILs/ESLs

Organochlorine pesticides

Hexachlorobenzene (HCB) mg/kg 10 10 80 - -

Heptachlor mg/kg 6 10 50 - -

cis-Chlordane mg/kg 50 70 530 - -

Endrin mg/kg 10 20 100 - -

Endosulfan (sum) mg/kg 270 340 2000 - -

4.4`-DDT mg/kg - - - - 180/640

Methoxychlor mg/kg 300 400 2500 - -

DDD + DDE + DDT mg/kg 240 400 3600 - -

Aldrin + Dieldrin mg/kg 6 10 45 - -

Organophosphorus Pesticides (OP)

Clorpyrifos mg/kg 160 250 2000 - -

Polychlorinated Biphenyls (PCBs)

PCBs mg/kg 1 1 7 - -

Notes

1. EILs for Zn, Cu, Ni based on assumption of 0.1% organic carbon, 1% Fe, pH 4.5, and 5 meq CEC as calculated from Schedule B5c NEPAM 2013 based on EC50 data. EIL for CrIII based on 5% clay content

2. mg/kg - milligrams per kilogram; NL non limiting 3. HIL/HSL – Health Investigation Level /Health Screening Level 4. EIL/ESL – Ecological Investigation Level / Ecological screening level


TABLE 4 TIER 1 SCREENING CRITERIA – GROUNDWATER

Analyte/ Receptor Unit A1-E A2-M B-H C-R D-S E-I


PFOS µg/L 6.66 - 0.2 2 - -

PFOA µg/L 2900 - 0.4 4 - -

6:2 FTS µg/L - - 5.0 50 - -

Inorganic Analytes

pH pH units - - 6.5-8.5 6.5-8.5 - 6.0-8.5

Total Dissolved Salts mg/L - - 600* - 4000 1500

Sulfate as SO4 mg/L - - 500 5000 1000 -

Chloride mg/L - - 250* - - 175-700

Calcium mg/L - - - - 1000 -

Magnesium mg/L - - - - 600 -

Sodium mg/L - - 180* - - 115-460

Potassium mg/L - - - - - -

Fluoride mg/L - - 1.5 15 2 1

Nitrite as NO2 mg/L - - 3 30 30 -

Nitrate as NO3 mg/L 10.6^ 10.6^ 50 500 400 20

TKN as N mg/L - - - - - 5

Ammonium mg/L 0.9A 0.91A 0.5* - - 5

Phosphate as PO4 mg/L - - - - - 0.15

Free CN mg/L 0.007 0.004 0.08 0.8 - -

Dissolved Metals

Aluminium mg/L 0.055 0.0005LR 0.2* - 5 -

Antimony mg/L 0.009 0.27LR 0.003 0.03 - -

Arsenic mg/L 0.024 0.0023LR 0.01 0.1 0.5 0.1

Barium mg/L 0.15D 0.15D 2 20 - -

Cadmium mg/L 0.0002H 0.0007 0.002 0.02 0.01 0.01

Hexavalent Chromium mg/L 0.001 0.0044 0.05 0.5 1 0.1

Cobalt mg/L - 0.001 0.06 0.6 - -

Copper mg/L 0.0014H 0.0013 2 20 0.5 0.2

Lead mg/L 0.0034H 0.0044 0.01 0.1 0.1 2

Manganese mg/L 1.9 0.08LR 0.5 5 10 0.2

Molybdenum mg/L 0.023LR 0.023LR 0.05 0.5 0.15 0.01

Nickel mg/L 0.011H 0.07 0.02 0.2 1 0.2

Selenium mg/L 0.011 0.003LR 0.01 0.1 0.02 -

Vanadium mg/L - 0.1 0.036D 0.36 - -

Zinc mg/L 0.008H 0.015 3 30 20 2

Iron mg/L 0.3C 0.3C 0.3* - - 0.2



Mercury mg/L 0.0006 0.0004 0.001 0.01 0.002 0.002

TPH/ TRH

TRH C6-C10 mg/L 0.15D 0.15D 0.15D 0.15D - -

TRH >C10 mg/L 0.6D 0.6D 0.6D 0.6D - -

MAHs

Benzene mg/L 0.95 0.7 0.001 0.001 - -

Toluene mg/L 0.18LR 0.18LR 0.8 0.8 0.8 0.8

Ethyl-benzene mg/L 0.08LR 0.005LR 0.3 0.3 0.3 0.3

Total Xylenes mg/L 0.550 0.625LR 0.6 0.6 0.6 0.6

Styrene mg/L - 0.57D 0.03 0.03 0.03 0.03

Isopropylbenzene (cumene) mg/L 0.03LR 0.03LR 0.68U 0.68 0.68 0.68

n-Propylbenzene mg/L 0.66U - 0.66U 0.66U 0.66U 0.66U

1.3.5-Trimethylbenzene mg/L 0.12U - 0.12U 0.12U 0.12U 0.12U

1.2.4-Trimethylbenzene mg/L 0.015U 0.019U 0.015U 0.015U 0.015U 0.015U

Oxygenated Compounds

Methyl tert-butyl ether (MTBE) mg/L 0.02F 0.014U 0.014U 0.014U 0.014U

2-Propanone (Acetone) mg/L 14U - 14U 14U 14U 14U

Vinyl Acetate mg/L 0.41U - 0.41U 0.41U 0.41U 0.41U

2-Butanone (MEK) mg/L 5.6U - 5.6U 5.6U 5.6U 5.6U

4-Methyl-2-pentanone (MIBK) mg/L 1.2U 123U 1.2U 1.2U 1.2U 1.2U

2-Hexanone (MBK) mg/L 0.038U - 0.038U 0.038U 0.038U 0.038U

HACs (aliphatic)

Dichlorodifluoromethane mg/L - - 0.2 0.2 0.2 0.2

Chloromethane mg/L - 2.7U 0.19 0.19 0.19 0.19

Vinyl chloride mg/L 0.1LR 0.84D 0.0003 0.0003 0.0003 0.0003

Bromomethane mg/L - 0.12U 0.0087 0.0087 0.0087 0.0087

Chloroethane mg/L - - 21 21 21 21

Trichlorofluoromethane mg/L - - 1.3 1.3 1.3 1.3

1.1-Dichloroethene mg/L 0.7LR 0.7LR 0.03 0.03 0.03 0.03

Methylene chloride mg/L - 20D 0.004 0.004 0.004 0.004

trans-1.2-Dichloroethene mg/L 0.7LR 0.7LR 0.01U 0.01U 0.01U 0.01U

1.1-Dichloroethane mg/L 0.09LR 0.25LR 0.9D 0.9D 0.9D 0.9D

1.2-Dichloroethane mg/L 0.005U 0.005U 0.005U 0.005U 0.005U 0.005U

cis-1.2-Dichloroethene mg/L 0.7LR 0.7LR 0.070U 0.070U 0.070U 0.070U

1.1.1-Trichloroethane mg/L 0.27LR 0.27LR 2 2 2 2

Carbon Tetrachloride mg/L 0.24 LR 0.24 LR 0.003 0.003 0.003 0.003

1.2-Dichloroethane mg/L 1.9 LR 1.9 LR 0.003 0.003 0.003 0.003

Trichloroethene (TCE) mg/L 0.33LR 0.33LR 0.02W 0.02W 0.02W 0.02W

Dibromomethane mg/L - - 0.0082 0.0082 0.0082 0.0082



1.1.2-Trichloroethane mg/L - - 0.065 0.065 0.065 0.065

1.3-Dichloropropane mg/L 1.1 LR 1.1 LR 0.73 0.73 0.73 0.73

Tetrachloroethene (PCE) mg/L 0.07LR 0.07LR 0.05 0.05 0.05 0.05

1.1.1.2-Tetrachloroethane mg/L - - 0.00052 0.00052 0.00052 0.00052

HACs (aromatic)

Chlorobenzene mg/L 0.055LR 0.055LR 0.3 0.3 0.3 0.3

Bromobenzene mg/L - - 0.088 0.088 0.088 0.088

2-Chlorotoluene mg/L - - 0.73 0.73 0.73 0.73

4-Chlorotoluene mg/L - - 0.73 0.73 0.73 0.73

1.4-Dichlorobenzene mg/L 0.06LR 0.06LR 0.04 0.04 0.04 0.04

1.2-Dichlorobenzene mg/L 0.16LR 0.16LR 1.5 1.5 1.5 1.5

1.2.4-Trichlorobenzene mg/L - 0.08 0.0023 0.0023 0.0023 0.0023

1.2.3-Trichlorobenzene mg/L 0.003LR 0.003LR 0.029 0.029 0.029 0.029

Pentachlorobenzene mg/L 0.002LR 0.002LR 0.00025 0.00025 0.00025 0.00025

Hexachlorobenzene (HCB) mg/L 0.0001LR 0.0001LR 0.001 0.001 0.001 0.001

Trihalomethanes

Chloroform mg/L 0.37LR 0.37LR 0.003 0.003 0.003 0.003

Bromodichloromethane mg/L - - 0.06W 0.06W 0.06W 0.06W

Dibromochloromethane mg/L - - 0.1W 0.1W 0.1W 0.1W

Bromoform mg/L - 0.64U 0.0085U 0.0085 0.0085 0.0085

PAHs

Naphthalene mg/L 0.016 0.07 - - - -

Acenaphthene mg/L - 0.0066U - - - -

Phenanthrene mg/L 0.002LR 0.002LR - - - -

Benzo(a)pyrene mg/L 0.0002LR 0.0002LR 0.00001 - - -

Phenolic Compounds

Phenol mg/L 0.32 0.4 LR - - - -

2-Chlorophenol mg/L 0.34 LR 0.34 LR 0.3 0.3 0.3 0.3

2-Methylphenol mg/L - 1.02U - - - -

4-Chlorophenol mg/L 0.22 - - - - -

2-Nitrophenol mg/L 0.002 LR 0.002 LR - - - -

2.4-Dinitrophenol mg/L 0.045 - - - - -

2.4-Dimethylphenol mg/L 0.002 LR 0.002 LR - - - -

2.4-Dichlorophenol mg/L 0.12 LR 0.12 LR 0.2 0.2 0.2 0.2

2.6-Dichlorophenol mg/L 0.034 LR 0.034 LR - - - -

2.3.4.6-Trichlorophenol mg/L 0.01 - - - - -

2.4.6-Trichlorophenol mg/L 0.003 LR 0.003 LR 0.02 0.02 0.02 0.02

2.4.5-Trichlorophenol mg/L 0.004 LR 0.004 LR - - - -

Pentachlorophenol mg/L 0.0036 0.011 0.01 0.01 0.01 0.01



Pthalate Esters

Dimethyl phthalate mg/L 3.7 - - - - -

Diethyl phthalate mg/L 1.0 0.0759U - - - -

Dibutyl phthalate mg/L 0.01 - - - - -

bis(2-ethylhexyl) phthalate mg/L - - 0.01 0.01 0.01 0.01

Nitrosamines

N-Nitrosodi-n-propylamine mg/L - 0.120U - - - -

N-Nitrosodiphenylamine mg/L - 33U - - - -

Nitroaromatics and Ketones

Nitrobenzene mg/L - 0.0668U - - - -

Isophorone mg/L - 0.129U - - - -

Anilines and Benzidines

Aniline mg/L 0.008 LR 0.008 LR - - - -

Dibenzofuran mg/L - 0.065U - - - -

Explosives

1.3.5-Trinitrobenzene mg/L 0.004 LR 0.004 LR - - - -

1.3-Dinitrobenzene mg/L 0.015 LR 0.015 LR - - - -

2.4.6-TNT mg/L 0.14 LR 0.14 LR - - - -

2.4-Dinitrotoluene mg/L 0.016 LR 0.016 LR - - - -

2.6-Dinitrotoluene mg/L 3E-4 LR 3E-4 LR - - - -

Nitrobenzene mg/L 0.055 LR 0.055 LR - - - -

2-Nitrotoluene mg/L 0.11 LR 0.11 LR - - - -



Miscellaneous Compounds

1.3.5-Trichlorobenzene mg/L 0.013LR 0.013LR - - - -

1.2.4.5-Tetrachlorobenzene mg/L 0.007LR 0.007LR - - - -

Perchlorate mg/L 0.93 0.93 - - - -

Note(s): 1. A1-E ecosystem (fresh); A2-M (marine); B-H health; C-R recreation/direct contact; D-S stock-water; E-I irrigation 2. * aesthetic only; D Dutch; LR Low Reliability values;

3. A adjust for pH as per ANZECC/ ARMCANZ (2000) Table 8.3.7 4. H Hardness Modified Trigger Values to be adjusted as per ANZECC/ ARMCANZ (2000) Table 3.4.3 5. C Canadian guidelines; U USEPA guidelines; W WHO guidelines; F FDEP (2005); ^ adjusted after Hickey (2013)

General Limitations 6 April 2009 Page 1 of 1

ENVIRONMENTAL EARTH SCIENCES GENERAL LIMITATIONS Scope of services The work presented in this report is Environmental Earth Sciences response to the specific scope of works requested by, planned with and approved by the client. It cannot be relied on by any other third party for any purpose except with our prior written consent. Client may distribute this report to other parties and in doing so warrants that the report is suitable for the purpose it was intended for. However, any party wishing to rely on this report should contact us to determine the suitability of this report for their specific purpose. Data should not be separated from the report A report is provided inclusive of all documentation sections, limitations, tables, figures and appendices and should not be provided or copied in part without all supporting documentation for any reason, because misinterpretation may occur. Subsurface conditions change Understanding an environmental study will reduce exposure to the risk of the presence of contaminated soil and or groundwater. However, contaminants may be present in areas that were not investigated, or may migrate to other areas. Analysis cannot cover every type of contaminant that could possibly be present. When combined with field observations, field measurements and professional judgement, this approach increases the probability of identifying contaminated soil and or groundwater. Under no circumstances can it be considered that these findings represent the actual condition of the site at all points. Environmental studies identify actual sub-surface conditions only at those points where samples are taken, when they are taken. Actual conditions between sampling locations differ from those inferred because no professional, no matter how qualified, and no sub-surface exploration program, no matter how comprehensive, can reveal what is hidden below the ground surface. The actual interface between materials may be far more gradual or abrupt than an assessment indicates. Actual conditions in areas not sampled may differ from that predicted. Nothing can be done to prevent the unanticipated. However, steps can be taken to help minimize the impact. For this reason, site owners should retain our services. Problems with interpretation by others Advice and interpretation is provided on the basis that subsequent work will be undertaken by Environmental Earth Sciences NSW. This will identify variances, maintain consistency in how data is interpreted, conduct additional tests that may be necessary and recommend solutions to problems encountered on site. Other parties may misinterpret our work and we cannot be responsible for how the information in this report is used. If further data is collected or comes to light we reserve the right to alter their conclusions. Obtain regulatory approval The investigation and remediation of contaminated sites is a field in which legislation and interpretation of legislation is changing rapidly. Our interpretation of the investigation findings should not be taken to be that of any other party. When approval from a statutory authority is required for a project, that approval should be directly sought by the client. Limit of liability This study has been carried out to a particular scope of works at a specified site and should not be used for any other purpose. This report is provided on the condition that Environmental Earth Sciences NSW disclaims all liability to any person or entity other than the client in respect of anything done or omitted to be done and of the consequence of anything done or omitted to be done by any such person in reliance, whether in whole or in part, on the contents of this report. Furthermore, Environmental Earth Sciences NSW disclaims all liability in respect of anything done or omitted to be done and of the consequence of anything done or omitted to be done by the client, or any such person in reliance, whether in whole or any part of the contents of this report of all matters not stated in the brief outlined in Environmental Earth Sciences NSW’s proposal number and according to Environmental Earth Sciences general terms and conditions and special terms and conditions for contaminated sites. To the maximum extent permitted by law, we exclude all liability of whatever nature, whether in contract, tort or otherwise, for the acts, omissions or default, whether negligent or otherwise for any loss or damage whatsoever that may arise in any way in connection with the supply of services. Under circumstances where liability cannot be excluded, such liability is limited to the value of the purchased service.