Appendix F: Record of CLG, IPR and Auckland Council Comments

Source

_______________ _______________ _______________ _______________ _______________ _______________ _______________ _______________ _______________ _______________ Level*

VISIBLE DUST EMISSIONS

Colour/Opacity Time Weather Cond. (i.e. rain, windy, calm)

*Levels (extent) of visible dust emissions:

(1) Minor visible emissions (<5m from source); (2) Moderate visible emissions (<30m from source); (3) Major visible emissions (>30m from source).

Wind Speed / Wind Direction (e.g. “7 m/s / NE”)

INVESTIGATION AND RESPONSE

Date event was investigated:___/___/_____ Person responsible for investigation and response:________________________________

Possible cause(s):

 Dust from wind erosion of exposed ground

 Watercart not used properly

 Exceedance of speed limit in unpaved surface

 Materials not handled or stored properly

 Loading/Unloading not carried out properly

 Other_________________________________________

________________________________________________ Corrective actions:

Date: ___/___/_____ Description: ___________________________________________

Preventive actions: Date: ___/___/_____ Description: ___________________________________________

Equipment identification

VEHICLES AND MACHINERY –PRESTART CHECK

Excessive or prolonged visible emissions observed? ________________________ ________________________ ________________________ If yes, describe action taken (e.g., equipment repaired or removed from site within 24 hours): _________________________________________________________ _________________________________________________________ _________________________________________________________

F.1 CLG Comments

A Mt Eden CLG meeting was held on 8 October to discuss the Mt Eden Enabling Works and for the CLG to provide comments / feedback on the CEMP and sub-plans, including this AQ DWP.

Comments from the CLG are recorded in Table F-1 below.

Table F-1: Response to CLG feedback.

Comment ID Feedback received from Feedback comment Response

CLG 01 Megan Ottley, 10 Ruru St Apartments (three blocks) at 10 Ruru Street are scheduled to be re-painted in 2020 during the works Further visual dust inspection requirements have been added to section 6.2 in the event the repainting of the apartment blocks occur

CLG-02 Richard Coombes, 3 Akiraho St

CLG-02 Richard Coombes, 3 Akiraho St Movements of trucks will cause dust issues Truck movements (over unsealed surfaces in particular) have the potential to generate dust. These emissions are to be managed in accordance Table 5 1 of the DWP.

Cars in the apartment block car park have already covered in a layer of dust. Will targeted monitoring be done off site? Dust deposition reported at 3 Akiraho St could potentially have resulted from preceding demolition works (e.g. at the South Pacific Timber site) or from background sources (e.g. pollen). A dust monitor (measuring suspended dust concentrations) is recommended to be located on the south or southwest side of the Site (upwind of the works activities in prevailing southwest winds and downwind in northeast winds that are more common in summer months). A further monitor is recommended on the opposite side of the Site at Nikau Street.

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F.2 Independent Peer Review Comments

Comments received from the independent peer review (IPR) are recorded in Table F-2 below.

Table F-2: Response to Independent Peer Review feedback.

Comment ID Content Feedback comment

IPR 01 Section 6.3.1 It is noted that the method for particulate monitoring has not yet been determined. (Section 6.3.1) Three options are given. If particle counters are used, a dust trigger levels will need to be added to reflect the output of that instrument. That trigger value needs to be in Table 6.2 if there is any likelihood that this method is to be used. If particle counters are used, a dust trigger levels will need to be added to reflect the output of that instrument.

IPR-02 Section 6.6 Section 6.6 relates to odour monitoring. The suggestion is that odour may be produced from the site if potentially contaminated material is excavated. The identification of nuisance odour described is considered appropriate. However, as the excavation of contaminated material is likely to be an unplanned event, it would be useful to see some process for the identification of the cause of the odour and some public health risk assessment of that odour. This may be detailed elsewhere, such as in a contamination plan for the project, and could be cross referenced in this document. However, this reviewer has not seen any contamination plan. Response

Particle counters have now been confirmed as the dust monitoring method to be employed. Units are subject to factory TSP calibration and the trigger levels in Table 6-2 remain unchanged on this basis. Requirements for review of dust monitoring results have been added to Section 6.3.2 including a potential for update of trigger levels.

Reference to section 7.1 of Contamination DWP for unexpected discovery of contamination added to section 6.6.

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F.3 Auckland Council Comments

Comments received from the Auckland Council (AC) technical review are recorded in Table F-3 below.

Table F-3: Response to Auckland Council technical review feedback.

Comment ID Content Feedback comment

AC 01 Section 2.2 [Concrete crushing] May require mention of crystalline silica as a risk –see Mt Eden Demo AQ DWP.

AC-02 Section 2.3 [Asbestos removal] Was referenced in the Mt Eden Demo AQ DWP; okay to leave it there as most demolitions completed under that works package.

AC-03 Section 5.2, Table 5-1 (Stockpiles) I agree with need for further discussion. On an effects basis, I have no issue with stockpiles as dust can be controlled by other measures than the 24 m³ maximum size threshold. However, on a consent compliance basis, it’s hard to get around this specific figure. I don’t believe that merely shifting the stockpiles to the CSA from the ACZ is a positive dust control measure.

AC-04 Section 5.2, Table 5-1 (Vehicle movements over sealed and unsealed surfaces) No mention of sweeping any sealed vehicle accessways. The exit needs to be sealed and cleaned regularly. Some further mention of avoiding tracking material onto the public road by cleaning (not just wheel washes).

AC-05 Section 6.2, Table 6-1 Contingency measure for tracking on public roads required elsewhere in the DWP.

AC-06 Section 6.3.1 I’m not opposed to this reduction from 3 monitors, but it is hard to sign off as compliant with the A2N resource consent condition. I suggest either ‘general compliance’ is sought or a s127 of the RC sought (which could also resolve the 24 m³ stockpile limit).

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Response

Description of the potential effects of each emitted contaminant added to section 6.2, including reference to potential health effects of respirable crystalline silica.

References in section 2.3 updated to Mt Eden Demo AQ DWP for demolition asbestos and to the Contamination DWP for excavation asbestos.

Interpretation/application of outdoor stockpiling condition requirements are currently subject to discussions between the Link Alliance and Auckland Council. This DWP will be updated on the basis of the outcome of those discussions.

Vacuum sweeping requirements for sealed accessways and public roads added to Table 5-1.

Section 5.2, Table 5-1 updated to include responses to identification of material tracked onto public roads

The requirements relating to number of monitors are subject to similar discussions referred to in relation to comment AC-03 above. This DWP will be updated on the basis of the outcome of those discussions.

Comment ID Content Feedback comment

AC-07 Section 6.3.1 The prevailing wind directions appear incorrect here? SW with 2° NE (particularly in summer) –as stated in the controls table about wind fences. AC-08 Section 6.3.1 It’s a little surprising there isn’t yet more certainty on the instrumental monitoring –it would be easier to sign off on the AQ DWP if info of the monitor type and a map of indicative locations were included. Isn’t one already installed from the demo works?

AC-09 Section 6.3.2, Table 6-2 I agree with these 1-hr average trigger levels –high sensitivity environment under the GPG:Dust. Thoughts invited on also including 5-min and/or 24-hr average trigger values for TSP. Other CRL AQ DWPs have included the 24-hr trigger (60 µg/m³ as alert; 80 µg/m³ not to be exceeded). Whether formally included as a trigger or not, a 24-hr avg TSP value of >60 µg/m³ could indicate further dust controls are required, so some consideration of longer-term dust concentrations recorded should be made as part of the on-going Dust Risk Assessments.

AC-10 Section 6.3.3 That [preference for a 10 m weather mast] would be ideal, but less robust met monitoring (i.e. monitor mounted to the dust instrument) would also be acceptable and still give useful info to supplement Met Service data. AC-11 Section 6.3.4 A 1-hr average [for the wind speed trigger] is quite coarse. GPG:Dust suggests trigger value of 10 m/s as a 1 min average –if exceeding twice in a 20 min period, then undertake mitigation measures. Response

Text deleted in response to following comment (AC-08).

Section 6.3.1 has been updated to describe the initial monitoring locations and methods.

Trigger levels based on 5 minute average particulate concentrations have not been included as they may be subject to short-term fluctuations that may not be reflective of a potential for dust nuisance. Use of rolling averages over longer averaging periods (e.g. 1 hour) would provide similarly rapid feedback on sustained dust levels that are more likely to cause dust nuisance. Table 6-2 has been updated to clarify that triggers apply to rolling 1-hour average concentrations.

24-hour average dust triggers would not provide for rapid

response to increasing dust levels (even as a rolling average) and as a result have not been specified in Table 6-2. However, a 24-hour average review criterion may have use in illustrating trends in dust levels. Requirements for regular review of

monitoring results are now specified in Section 6.3.2 including

comparison with the suggested criterion for TSP concentrations of 60 µg/m 3 as a 24-hour average.

Preference for 10 m weather mast deleted.

Additional short term wind trigger added to Table 6-3 to provide additional notification of strong gust speeds. Visual inspection trigger remain based on 1-hour averages to avoid repeated inspections on 20 minutes bases.

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Comment ID Content Feedback comment Response

Not a big issue though; 5 m/s as a 1-hr average would be a reasonably windy day and visual assessments would likely have already concluded a high Dust Risk Index. AC-12 Section 6.3.4 Note this inspection is additional to the routine daily monitoring in Table 6-1 AC-13 Section 6.3.5 I’d prefer if this [use of the alternative dust management approach] was discussed with Council Monitoring Officer first (once false dust alerts identified as an issue). Suggest insert ‘identified to be required by the ESM in consultation with Council Monitoring Officer’ Corresponding inspection requirement exists in Table 6-1.

Suggested modification adopted.

AC-14 Section 9.1 Only 1-hr average trigger values in the above. Reference to average concentrations removed.

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