Auckland City Rail Link In association with:
ENABLING WORKS CONTRACT 1 CONTAMINATION DELIVERY WORK PLAN
Document ref: CRL-BTM-ENV-DOW-PLN-000295
Revision: 7 FINAL June 2016
COMMERCIAL IN CONFIDENCE Contamination Delivery Work Plan
June 2016
Version history Rev.
Date
Version details
Prepared by
Reviewed by
1
November 2015
Draft for Auckland Transport review
L Phuah
P Roan, D Burtenshaw
2
November 2015
Draft for CLG review
L Phuah
R Jenkins
3
January 2016
Draft for peer review
L Phuah
R Purdy, R Jenkins
4
April 2016
Draft to incorporate comments from independent peer review
L Phuah
R Purdy
5
May 2016
Draft to incorporate CLG comments
L Phuah
J Urquhart, P Roan
6
May 2016
Draft for Auckland Transport review
L Phuah
J Urquhart, P Roan
7
June 2016
Final
L Phuah
J Urquhart, P Roan, R Jenkins
Distribution Date
Version
Issued to
Quantity & type
Approved for the DSBJV by
5 November 2015
Draft
Auckland Transport
1x Electronic
D Burtenshaw
13 November 2015
Draft
Community Liaison Group
1x Electronic
D Burtenshaw
29 January 2016
Draft
Independent Peer Review
1x Electronic
D Burtenshaw
12 May 2016
Draft
Community Liaison Group
1 x Electronic
D Burtenshaw
27 May 2016
Draft
Auckland Transport
1x Electronic
D Burtenshaw
2 June
Final
Auckland Transport
1x Electronic 1 x Hard copy
D Burtenshaw
This document remains the property of DSBJV. Its contents are confidential and shall not be reproduced, destroyed or given away without express, written permission of DSBJV. The electronic version of this document in FULCRUM on designated serves(s) is the Master Copy and is a controlled document. Unless specifically noted, thereon, other copies of this document are uncontrolled. p:\30850\30850.0500 planning\30850.0507 (contamination)\workingmaterial\dwp\crl-btm-env-dow-pln-000295 contamination final 30 05 16.docx
Contamination Delivery Work Plan
January 2016
Table of contents 1
2
3
4
5
6
7
Introduction 1.1 Purpose of the Contamination DWP 1.2 Relevant Conditions 1.3 Sustainability 1.4 DWP Review and updates 1.5 Contamination DWP Author Project Description 2.1 Overview 2.2 Construction Zones Summary of contaminated land assessment 3.1 Overview 3.2 Geology and Hydrogeology 3.3 Soil Quality 3.4 Groundwater Quality 3.5 Ground Gas Mitigation and management of effects 4.1 General Mitigation Measures 4.2 Soil Contamination Effects 4.3 Groundwater Contamination Effects 4.4 Soil Disposal 4.4.1 Soil Classification 4.5 Soil sampling and testing 4.6 Imported material requirements 4.7 Sealing Excavation Service Trenches Contaminated Fill Management 5.1 Overview 5.2 Excavation of Contaminated Fill 5.3 Water Management 5.4 Dust Management 5.5 Odour Management 5.6 Decontamination 5.7 Monitoring Programme Health and Safety Procedures 6.1 Overview 6.2 General Safety Requirements and Training 6.3 Control Measures 6.4 Identification of Hazards 6.5 Identification of New Hazards 6.6 Hazard Mitigation Procedures 6.6.1 Dust inhalation 6.6.2 Vapour inhalation 6.6.3 Dermal contact and ingestion 6.7 Personal Protective Equipment Contingency actions 7.1 Unexpected discovery of contamination 7.2 Complaints procedure 7.3 Water discharges
Contamination Delivery Work Plan
1 1 2 7 7 7 8 8 8 10 10 10 10 10 11 12 12 13 13 13 13 14 15 16 17 17 17 17 18 18 19 19 20 20 20 21 21 21 22 22 22 23 23 24 24 25 26
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Works Summary/Validation Report Review and Updating of the DWP 9.1 DWP Review 9.2 DWP Updates
Appendix A :
ISCA Requirements
Appendix B :
Plans of Works
Appendix C :
Soil Remediation Appraisal
Appendix D :
CLG and Independent Peer Review Comments
Contamination Delivery Work Plan
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Glossary of terms Acronym
Definition
ACZ
Active construction zones
ALW Plan
Auckland Council Regional Plan: Air, Land and Water
bgl
Below ground level
BTC
Britomart Transport Centre
CEMP
Construction Environmental Management Plan
CLG
Community Liaison Group
CLP
Contaminated Land professional
CPO
Former Chief Post Office building
CRL
City Rail Link
CSMP
Contaminated Soils Management Plan
DWP
Delivery Work Plan
HSO
Health and safety Officer
IS
Infrastructure Sustainability
ISCA
Infrastructure Sustainability Council of Australia
m
Metre
MfE
Ministry for the Environment
mg/L
Milligrams per litre
NES Soil
Regulation 11 of the Resource Management (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health) Regulations 2011
PAH
Polycyclic aromatic hydrocarbons
PAUP
Proposed Auckland Unitary Plan
PID
Photo-ionisation detector
PPE
Personal protective equipment
SQEP
Suitably qualified and experienced practitioner
VOC
Volatile organic compound
Contamination Delivery Work Plan
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1
1
Introduction
The City Rail Link (CRL) project comprises the construction, operation and maintenance of a 3.4 km underground passenger railway, running between Britomart Station and the North Auckland Rail Line in the vicinity of Mt Eden station. The works relating to this Contamination Delivery Work Plan (DWP) constitute part of the enabling works for the CRL. The works (the Project) involve the construction of an extension to the existing passenger rail network from the current termination point within the Britomart Transport Centre (BTC), westwards underneath the former Chief Post Office building (CPO) and Lower Queen Street. The Project footprint is shown by the blue shaded area in Figure 1.1 below.
LEGEND CRL alignment BTC designation CRL designation C1 worksite
Figure 1.1: Project Footprint
1.1
Purpose of the Contamination DWP
This Contamination DWP has been prepared to manage the adverse effects relating to contaminated land during the construction of the Project. Specifically, the purpose of the plan is:
To avoid, remedy or mitigate the adverse effects of the construction on human health, which may result from the disturbance of contaminated fill (as defined in Section 4.4.1 of this DWP) during construction; and
To minimise discharges to land or water from contaminated fill within the Project footprint.
This DWP incorporates the requirements of the CRL designation (Conditions 57 and 58) and discharge permit R/REG/2014/5435 (Conditions 77 to 94). The CRL designation requires the preparation of a DWP while the discharge permit require a Contaminated Soils Management Plan (CSMP). These two separate document requirements have been combined and are addressed in this single Contamination DWP. The Contamination DWP addresses the following:
A summary of soil and groundwater quality within the Project footprint based on previous Project contamination assessments;
Management of contaminated fill and groundwater within the Project footprint, including soil classification, sampling and testing;
Contamination Delivery Work Plan
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Procedures to manage the disturbance of contaminated fill during earthworks activities, including measures for reducing human exposure to contaminated fill and minimising contaminated discharges to air, land or water;

Contamination Health and Safety Plan; and

Contingency measures to manage any unexpected discovery of contamination.
This Contamination DWP has been prepared by Tonkin & Taylor Ltd (T+T) for the Downer Soletanche Bachy Joint Venture (the Contractor - DSBJV). The DWP has been prepared in general accordance with Ministry for the Environment (MfE 2011) Contaminated Land Management Guideline No. 1: Reporting on Contaminated Sites in New Zealand, and forms part of the Construction Environmental Management Plan (CEMP) for the Project.
1.2
Relevant Conditions
Table 1.1 identifies the CRL designation and discharge permit conditions relevant to this Contamination DWP and where they are addressed in the document. Table 1.1: Contamination DWP Conditions and section where addressed in the DWP Condition No.
Condition
Relevant section of the DWP CRL Designation Conditions
Contamination DWP 57.1A
57.2
57.3
This document A Contamination DWP shall be prepared to manage the adverse effects relating to contaminated land during the construction of the City Rail Link or any part of it. The objective of the Contamination DWP is to avoid, remedy or mitigate This document the adverse effects of construction on human health which may result from the disturbance of contaminated materials during construction. To achieve the above objective the following shall be included in the Contamination DWP and implemented as required: a)
Health and safety plan that addresses: worker safety worker training with regard to handling and identifying potentially contaminated soil and notification procedures for discovery of contamination b) Procedures for how erosion and sediment control, storm water, dust, and odour control measures will manage the removal of contaminated soil/material c) Procedures for contaminated soil classification, management and disposal of contaminated soil/material d) Where any trenches/excavations during civil works are to be sealed as a result of contamination and how this is to be recorded e) How and which work areas are to be restricted to authorised personnel only and procedures to limit the presence of ignition sources in these areas (e.g. no smoking within or adjacent to construction area, no welding or open flames near areas with high concentrations of hydrocarbon contamination) f) Procedures for the monitoring and management of the removal of contaminated soil/material by a suitably qualified environmental specialist;
Contamination Delivery Work Plan
Section 6 Section 6.2
Section 5
Sections 4 and 5 Section 4.7 Section 7.1
Section 5
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Condition
Relevant section of the DWP
g)
Sections 4.4.1, 7.1 and 8 Section 5.2
How the placement of re-used contaminated soil/material will be recorded and tracked h) Where areas for stockpiling and storing soil/material will be established on the construction site and the procedures for managing the containment of the contaminated soil / material in these areas i) Cross references to the specific sections in the Communication and Consultation Plan which detail how the general public are to be communicated with on the management of the adverse effects relating to the removal of contaminated soil/material. 58.1
At the completion of construction works a validation report will be prepared in accordance with any Ministry for the Environment guidelines and submitted to the Auckland Council Consent Monitoring officer documenting the management of soil and evidence of appropriate disposal. The validation report shall include a record of all analytical results, volumes, tip dockets, and any incidents or complaints and how these were addressed. The validation report shall also identify any areas which need on-going monitoring and management by the Requiring Authority.
Sections 4.1 and 7.2
Section 8
Discharge Permit (R/REG/2014/5435) 78
At least 20 working days prior to the commencement of construction, a final CSMP shall be submitted to the Council (Team Leader Earthworks and Contaminated Land, Natural Resources and Specialist Input and Team Leader Central Monitoring) for certification. The CSMP shall be prepared by a suitably qualified and experienced Contaminated Land Professional in accordance with Schedule 13 (A4) of the Auckland Council Regional Plan: Air, Land and Water (ACRP:ALW). The Consent Holder shall request the Council’s (Team Leader Central Monitoring) determination as to whether the CSMP can be certified, in writing, within 10 working days of receipt of the CSMP.
This document, Section 1.4
79
No construction shall commence until certification is provided from the Council (Team Leader Earthworks and Contaminated Land, Natural Resources and Specialist Input and Team Leader Central Monitoring) that the CSMP meets the requirements of Schedule 13 (A4) of the ACRP:ALW.
This document
80
All measures identified in that CSMP must be established prior to the commencement of bulk earthworks.
Section 5.1
81
The CSMP shall address the following matters: a)
Identification of mitigation measures to ensure that discharges from the construction support areas to land or water are minimised, and to ensure that potential effects on the health of workers on the site and nearby sites can be appropriately managed
Sections 4 and 5
b) The areas within the project site designated for the excavation works, including depths and extent of the proposed works, and an updated map showing the land disturbance activity areas;
Section 2 and Appendix B
c)
Section 5
Contamination Delivery Work Plan
Excavation, management, and disposal procedures for soil, sediment, dust, surface run-off water, perched groundwater, and groundwater, if encountered;
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Condition
Relevant section of the DWP
d) Temporary containment, treatment, and testing procedures for any water getting in contact with the contaminated material if disposal option to the stormwater system or marine environment is considered;
Section 5.3
e)
Contingency measures for unexpected discovery of contamination;
Section 7.1
f)
Proposed gas monitoring in the Lower Queen Street area, and any other proposed sampling and analysis, if applicable; and
Sections 6.6.2 and 4.5
g)
Proposed Works Summary Reporting.
Section 8
Advice Note: The Council acknowledges that the CSMP is intended to provide flexibility of the management of the works and contaminant discharge. Accordingly, the plan may need to be further updated. Any updates must be limited to the scope of this consent and be consistent with the conditions of this consent. If you would like to confirm that any proposed updates are within scope, please contact the Council (Team Leader Earthworks and Contaminated Land, Natural Resources and Specialist Input) on (09) 301 0101.
Section 1.3
82
All disturbance of contaminated and potentially contaminated soil as part of the bulk earthworks activity shall be carried out in accordance with the certified CSMP required by Condition 78 and any changes to the plan shall be submitted to the Council (Team Leader Earthworks and Contaminated Land, Natural Resources and Specialist Input and Team Leader Central Monitoring) for certification prior to the change being implemented. No activity reliant upon a change to the CSMP can be undertaken until the change has been certified. The Consent Holder shall request the Council’s (Team Leader Central Monitoring) determination as to whether the proposed change can be certified, in writing, within 10 working days of submission of the change.
Section 1.1 and 1.4
83
The Consent Holder shall notify the Council (Team Leader Earthworks and Contaminated Land, Natural Resources and Specialist Input and Team Leader Central Monitoring) at least two working days prior to the commencement of bulk earthworks on the subject site. Advice Note: Condition 83 requires the consent holder to notify the Council of their intention to begin works in contaminated areas a minimum of two working days prior to commencement of construction. Please contact the Team Leader, Earthworks and Contaminated Land, Natural Resources and Specialist Input at david.hampson@aucklandcouncil.govt.nz to advise of the start of works. The following details should also be provided: Name and telephone number of the project manager and the site owner; Site address to which the consents relate; Activity to which the consents relate; and Expected duration of the works.
Section 4.1
84
All disturbance of contaminated soil shall be supervised by a suitably qualified and experienced Contaminated Land Professional who shall ensure that soil management and disposal procedures, contingency measures outlined in the certified CSMP required by Condition 78, and all relevant consent conditions are adhered to. Regular inspections of the works area shall be carried out by the Contaminated Land Professional.
Sections 4.1, 5.7 and 8
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Condition
Relevant section of the DWP
These inspections shall be documented and the relevant records shall be retained and provided to Council (Team Leader Earthworks and Contaminated Land, Natural Resources and Specialist Input) as part of the Works Summary Report required by Condition 93. 85
All land disturbance works shall be managed to avoid the potential for cross-contamination of materials to occur. In particular, movement of contaminated soil around the site and/or deposition of contaminated soil on other parts of the site shall be avoided. Soils that are identified for offsite disposal must be loaded directly for removal where possible, and all material shall be covered during transportation off-site.
Section 5.2
86
To minimise the spread of contaminated material, any temporary stockpiles of excavated contaminated material shall be located within the catchment of erosion and sediment controls for the site. All stockpiles shall be covered with either polythene or an equivalent impermeable material when the site is not being worked and during periods of heavy rain.
Section 5.2
87
Excess soil or waste materials removed from the Project worksite shall be deposited at a disposal site that holds a resource consent to accept the relevant level and type of contamination.
Section 4.4
88
Where it can be demonstrated that the soil has been fully characterised and meets the definition of ‘cleanfill’ in accordance with the Ministry for the Environment’s publication ‘A Guide to the Management of Cleanfills’ (2002), the removal of such material to a consented disposal facility is not required. In such circumstances, a record of the location, depth, and volume of the material removed as ‘cleanfill’ shall be kept for the purpose of being included in the Works Summary Report required by Condition 93.
Sections 4.4 and 8
89
Any perched groundwater or surface run-off water encountered within the excavation area requiring removal shall be considered as potentially contaminated, and shall either: a) be disposed of by a licensed liquid waste contractor; or b) pumped to sewer, providing relevant permits are obtained; or c) discharged to the stormwater system, provided testing demonstrates compliance with 50 times the Australian and New Zealand Environment Conservation Council (ANZECC) Guidelines for Fresh and Marine Water Quality (2000) for the protection of 95 percent of marine water species.
Section 5.3
90
Where contaminants are identified that have not been anticipated by the application, works in the area containing the unexpected contamination shall cease until the contingency measures outlined in the certified CSMP required by Condition 78 have been implemented, and have been notified to the Council (Team Leader, Earthworks and Contaminated Land, Natural Resources and Specialist Input). Any unexpected contamination encountered during the works and contingency measures implemented shall be documented in the Works Summary Report required by Condition 93. Advice Note: In accordance with Condition 90 any unexpected contamination may include separate phase hydrocarbons, contaminated soil, perched water or groundwater. The consent holder is advised that where unexpected contamination is significantly different in extent and concentration from that anticipated, handling the contamination may be outside the scope of this consent. Advice should be sought from the Council
Section 7
Contamination Delivery Work Plan
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Condition
Relevant section of the DWP
(Team Leader Earthworks and Contaminated Land, Natural Resources and Specialist Input) prior to carrying out any further work in the area of the unexpected contamination to ensure this is within the scope of this consent. 91
All imported fill shall: a) comply with the definition of 'cleanfill' in the Ministry for the Environment publication 'A Guide to the Management of Cleanfills’ (2002); b) be solid material of an inert nature; and c) not contain hazardous substances or contaminants above recorded natural background levels of the receiving site. Advice Note: Background contamination levels for the site receiving cleanfill can be found in the Technical Publication No. 153, Background concentrations of inorganic elements in soils from the Auckland Region, Auckland Regional Council (2001).
Section 4.6
92
All sampling and testing of contamination on the site shall be overseen by the Contaminated Land Professional and shall be undertaken in accordance with Contaminated Land Management Guidelines, No.5 – Site Investigation and Analysis of Soils, Ministry for the Environment (revised 2011). Advice Note: All testing and analysis should be undertaken in a laboratory with suitable experience and ability to carry out the analysis. For more details on how to confirm the suitability of the laboratory please refer to Part 4: Laboratory Analysis, of Contaminated Land Management Guidelines No.5.
Section 4.5
93
Within three months of the completion of bulk earthworks on the site, a Works Summary Report shall be provided to the Council (Team Leader Earthworks and Contaminated Land, Natural Resources and Specialist Input and Team Leader Central Monitoring). The Works Summary Report shall be prepared by a suitably qualified and experienced Contaminated Land Professional in accordance with Schedule 13 (A5) of the Auckland Council Regional Plan: Air, Land and Water and Contaminated Land Management Guidelines, No.1 - Reporting on Contaminated Sites in New Zealand, Ministry for the Environment (revised 2011).
Section 8
94
The Works Summary Report shall address the following matters:
Section 8
a)
a summary of the works undertaken, including a statement confirming whether the excavation of the site has been completed in accordance with the certified CSMP required by Condition 78;
b) the location and dimensions of the excavations carried out, including a site plan; c)
a summary of soil, perched water and groundwater testing undertaken (if applicable) including tabulated analytical results, and interpretation of the results in the context of the Contaminated Land Rules of the Auckland Council Regional Plan: Air, Land and Water and the Proposed Auckland Unitary Plan;
d) copies of the disposal dockets for the contaminated soil and ‘cleanfill’ material removed from the site; e)
Contamination Delivery Work Plan
records of any unexpected contamination encountered during the works and contingency measures undertaken (if applicable);
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Condition
f)
details regarding any complaints and/or breaches of the procedures set out in the certified CSMP required by Condition 78 and the conditions of this consent;
g)
results of testing, if required, of any spoil disposed offsite; and
Relevant section of the DWP
h) results of testing of any imported fill material to ensure compliance with the definition of 'cleanfill', as per 'A Guide to the Management of Cleanfills’, Ministry for the Environment (2002).
1.3
Sustainability
AT is seeking an Infrastructure Sustainability Council of Australia (ISCA) Infrastructure Sustainability (IS) Rating. Further details can be found in the Project CEMP and Sustainability Rating Management Plan. Project sustainability requirements that relate directly to this Contamination DWP are included in Appendix A. These requirements are imbedded within tis Contamination DWP to ensure that sustainability is a key focus and ‘the way we do things’. In some cases the IS requirements and sustainability goals enhance the designation and consent requirements.
1.4
DWP Review and updates
This DWP is a live document that will be reviewed and updated if needed during the course of the Project to reflect changes in the understanding of ground contamination in the Project area, accepted best operational practice or regulations. Any material changes to this DWP must be certified by Auckland Council prior to any on-site activity reliant upon the change commencing. A formal review process is described in Section 9 of this DWP.
1.5
Contamination DWP Author
This Contamination DWP has been prepared by Lean Phuah who is a Contaminated Land Professional at T+T. Lean has Bachelor of Civil Engineering degree from the University of Canterbury and is a chartered professional engineer working in the environmental practice area. She has more than 20 years’ experience in investigations, assessment, management and reporting of contaminated sites. She is a suitably qualified and experienced practitioner under the Resource Management (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health) Regulations 2011 (NES Soil).
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2
Project Description
2.1
Overview
The Project involves the construction of an extension to the existing passenger rail network from the current termination point within the BTC, westwards underneath the CPO and Lower Queen Street Separate works are being undertaken to continue the CRL tunnels from this point under the Downtown Shopping Centre site (which is to be redeveloped by Precinct Properties), and up Albert Street. Significant works beneath the CPO will be undertaken, with the construction of two new rail tunnels extending westwards beneath the basement floor level. In Lower Queen Street, sheet piling will be extended across the road corridor, excavation undertaken to form the tunnels followed by reinstatement of the road corridor following the completion of works. During construction, existing ticketing and retail functions and pedestrian access to the station will be accommodated in Station Plaza, at the rear of the CPO building. Surface works will also be required in QEII Square associated with the Downtown Shopping Centre redevelopment, including construction of the CRL rail tunnels beneath this site (Precinct Properties scope of work). A detailed description of the construction works is provided in the CEMP.
2.2
Construction Zones
The Project will be divided into four discrete active construction zones (ACZ) as shown in Figure 2.1.
Figure 2.1: Active Construction Zones1
1
The referencing of Project ACZs adopted in this DWP reflects that of the BTC designation in order to ensure consistency across all Project Delivery Work Plans and Environmental Management Plans. It is noted that under the resource consents, the Project area is separated into two larger ACZ’s – ACZ A (CPO) and ACZ B (Lower Queen Street).
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Works required in the four ACZs are outlined in Table 2.1. Table 2.1: Summary of key construction activities within each ACZ2 Active Construction Zone
Key work components
A
Britomart Station modifications Modification of existing platforms and track lines Installation of temporary access stairs, station entry and egress
B
Accommodation within Station Plaza Construction of temporary accommodation buildings and facilities and relocation of ticketing, staff facilities, public amenities, retail/kiosk areas from the CPO building Installation of services
C
CPO building works Removal of the CPO fixtures and fittings, including the timber floor Saw cutting and demolition of the concrete ground floor in the main ticket hall and processing concrete for use as backfill later Installation of guide walls, diaphragm wall and underpinning structures to provide support for the CPO Soil excavation Construction of the base slab, walls and roofs for new rail tunnels Backfill excavation Reinstatement and fit out of CPO building
D
Lower Queen Street Carry out piling and underpinning works Soil excavation Construct base slab, walls and roofs for new rail tunnels Backfill excavation Reinstatement of Lower Queen Street
Excavation of both Lower Queen Street and beneath the CPO will be conducted concurrently. The proposed excavations will extend approximately 16 m below ground level (bgl) beneath the CPO and Lower Queen Street with the excavations in Lower Queen Street extending approximately 28 m from the western edge of the CPO building. The works will result in an anticipated cut soil volume of 20,000 m3. The extent of excavation is shown on plans provided in Appendix B. Spoil will be loaded directly onto truck and trailers and transported from the site. A detailed description of the construction works is provided in the Project CEMP.
2
Note these activities are not in order of programme
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3
Summary of contaminated land assessment
3.1
Overview
Contamination investigations conducted for the CRL Project to support obtaining the necessary planning approvals are documented in the following reports:
City Rail Link Contaminated Land Assessment July 2012, prepared by AECOM;
Auckland City Rail Link Britomart to Wyndham Contaminated Land Assessment December 2014, prepared by Golder Associates; and
Auckland City Rail Link Britomart to Wyndham Water Quality Assessment December 2014, prepared by Golder Associates.
The contaminated land assessments undertaken for the Project comprised an assessment of soil, groundwater and ground gas. Limited soil testing has been carried out to date within the Project area with a single borehole (EB301). A summary of the key findings of the assessment relevant to the Project is outlined in this section of the Contamination DWP.
3.2
Geology and Hydrogeology
Geology in the proposed excavation area comprise:
Reclamation Fill below surface seal (asphalt and/or concrete). The fill is likely to comprise reworked natural soils and rocks (silts, sands, gravels and basalt), and waste materials (such as timber, metal, brick, concrete, ash, clinker, household refuse, and possibly gas works waste).
Tauranga Group – alluvial sediments comprising silty clay with occasional wood fragments.
East Coast Bays Formation – silty clay, clayey silt and sandy silt overlying alternating sandstone and siltstone beds.
Groundwater is expected to occur between 2 and 3 m bgl, with a likely tidal fluctuation ranging in the order of 1 m.
3.3
Soil Quality
Two samples of the fill were collected from EB301. The samples, collected from 4.3 and 4.8 m bgl, show contaminant concentrations that comply with applicable NES Soil contaminant standards and the Auckland Council Regional Plan: Air, Land and Water (ALW Plan) and the Proposed Auckland Unitary Plan (PAUP) permitted activity criteria. However, the assessment undertaken to date in the Project area is limited in scope. In their investigation, Golder Associates considered that soils with contamination above human health and environmental discharge assessment criteria may be present within fill. In particular, the reclaimed foreshore beneath Britomart and QE II Square (including beneath the Downtown Shopping Centre) may contain hydrocarbons, metals/metalloids, asbestos, and gas works waste.
3.4
Groundwater Quality
One groundwater sample collected from EB301 screened within the fill returned results below the relevant ANZECC (2000) trigger levels, indicating compliance with Rule 5.5.43 of the ALW plan and Rule 2.2.1 of the PAUP.
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3.5
Ground Gas
Ground gas monitoring recorded carbon dioxide at 0.2 % v/v in EB301 during a single monitoring event on 6 November 2014. The measured concentrations were elevated above atmospheric carbon dioxide concentrations but below levels which represent a risk to human health. Oxygen levels were recorded within normal atmospheric range at sea level.
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4
Mitigation and management of effects
4.1
General Mitigation Measures
The proposed mitigation and management of adverse environmental effects associated with contaminated and potentially contaminated fill within the Project footprint are detailed in this section of the DWP. The key mitigation and management measures that apply to the Project are summarised below: Pre-works:
Appoint a Contaminated Land Professional (CLP) prior to commencing work. The CLP shall be considered a ‘suitably qualified and experienced practitioner’ (SQEP) as required under the NES Soil. The CLP will be available to be present on site during all excavation works, and has responsibility for:
Co-ordinating contaminated land assessments and testing;
Advising on classification of excavated materials for reuse and disposal;
Co-ordinating groundwater management and disposal;
Training staff in contaminated fill identification and control procedures;
Liaising with the Health and Safety Officer during the excavation of contaminated fill; and
Supervision during any disturbance of contaminated fill.
Notify Auckland Council at least two working days prior to commencing any bulk earthworks on the site. The following information will be provided to the Council’s Team Leader Earthworks and Contaminated Land, Natural Resources and Specialist Input:
Name and telephone number of the project manager and site owner;
Address of the site;
Description of works and expected duration. During works
Adherence to the Health and Safety procedures in Section 6 of this Contamination DWP to mitigate risks to construction workers and the general public in relation to the excavation of contaminated fill as defined in Section 4.4.1 of this DWP.
Adherence to the management procedures for the excavation of contaminated fill set out in Section 5 for:
Handling and storage requirements;
Measures to prevent the discharge of contamination; and
Disposal of contaminated fill to appropriately licensed landfill and appropriate treatment of potentially contaminated water.
Management of cleanfill and managed fill according to standard earthworks controls (dust and erosion and sediment control) and disposal to a landfill approved to take the fill.
Following procedures for identifying and managing unexpected discovery of contaminated soils or hazardous materials.
Restricting work areas if significant contamination (above the NES Soil commercial/industrial land use soil contaminant standard) is encountered as per Section 7.1 of this DWP.
Undertaking review and update of this DWP.
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Preparation of a Works Summary Report / Validation Report to establish measures complied with during the works. The Project Communication and Consultation Plan, along with Section 5.3 of the CEMP, addresses methods for communicating with, and informing the public on works and activities occurring in the Project area.
4.2
Soil Contamination Effects
Previous testing of soil in the Project area has not detected contamination within the fill material above relevant assessment criteria. However, as discussed in Section 3.3 of this DWP, the investigations have been limited in extent and there is potential for contamination to be encountered in the reclamation fill within the project excavation footprint. Hence, this Contamination DWP adopts a conservative approach to soil management during excavation within reclamation fill materials. The conservative approach considers reclamation fill materials to be contaminated unless proven otherwise by soil testing.
4.3
Groundwater Contamination Effects
Previous investigations have not identified any significant contamination of groundwater within the Project footprint and there are no anticipated adverse environmental effects associated with groundwater. However, groundwater that is encountered during excavations (that requires removal for construction purposes) will be pumped into the Project’s water treatment and storage tanks before discharging to the stormwater system, thus mitigating any potential adverse environmental effects.
4.4
Soil Disposal
The conservative approach to soil management when excavating within reclamation fill means that, unless proven otherwise by soil testing, excavated soils will be treated as contaminated fill and disposed of to an appropriately licensed solid waste landfill. It is possible that, with the additional testing being undertaken, as described in Section 4.5 below, some of the reclamation fill material could be removed to Managed Landfill and the natural underlying soils (Tauranga Group and ECBF) could be removed to Managed or Clean Fill (refer to Section 4.4.1 of this DWP). The necessary approvals/permits shall be obtained from the disposal destination prior to transportation of any materials from the site. All weighbridge dockets and a summary sheet shall be retained for inclusion in the site closure Works Summary/Validation Report (refer to Section 8 of this DWP).
4.4.1
Soil Classification
Soils within the Project area will be classified into the following three categories to define management and disposal requirements: Contaminated fill Contaminated fill in the context of this Contamination DWP constitutes: 
Hazardous materials in the form of household and industrial waste, organic waste or asbestos containing material.
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Soil containing contaminants that exceed the lower value of the ALW Plan permitted activity rule 5.5.41 soil acceptance criteria or the NES Soil human health soil contaminant standard for commercial/industrial land use.
Reuse of contaminated fill on the Project will not be permitted without discussion with AC prior to placement. The location of any contaminated fill that is re-used within the project footprint will be surveyed (grid coordinates to be recorded) and the information will be provided in the Works Summary/Site Validation Report (refer Section 8 of this DWP). (Note: An additional resource consent may be required to reuse contaminated material on site). Managed fill Managed fill comprises:
Soil containing metal contaminants above the published background concentrations in the Auckland region for non-volcanic soils.
Soil containing low level hydrocarbon compounds.
Soil that does not contain hazardous substances or materials in the form of household and industrial waste, organic waste or asbestos containing material.
Cleanfill Cleanfill is defined in Condition 88 of discharge permit R/REG/2014/5435 by reference to the Ministry for the Environment (MfE) Document ‘A Guide to the Management of Cleanfills’ (2002), which states that: “..material that when buried will have no adverse effect on people or the environment; and includes virgin materials such as clay, soil and rock, and other inert materials such as concrete or brick that are free of:
Combustible, putrescible, degradable or leachable components
Hazardous substances
Products or materials derived from hazardous waste treatment, hazardous waste stabilization or hazardous waste disposal practices
Materials that may present a risk to human health
Liquid waste.”
In simple terms, cleanfill includes materials such as uncontaminated soils, cured asphalt, bricks, unreinforced concrete, fibre cement building products (excluding asbestos) and glass. Non-cleanfill materials would include soils with analytical results showing detectable hydrocarbon compounds and/or exceedance of Auckland Region background concentrations of metals, asbestoscontaining materials and new asphalt.
4.5
Soil sampling and testing
As outlined above, only limited soil testing has been undertaken in the Project area. Further sampling and testing of soils within the project footprint is proposed to be undertaken prior to commencing bulk earthworks in order to classify soils for management and removal. Specifically, soil testing is anticipated to be undertaken between June and December 2017 preferably in conjunction with further geotechnical investigations. At this stage, the geotechnical investigations have not yet been defined. Samples shall be taken at a minimum of 15 m spacings across the excavation area proposed for the project.
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15 The soil sampling will be undertaken under the supervision of the CLP according to the requirements of the NES Soil Regulations and the MfE Contaminated Land Management Guidelines No.53. Soil samples shall be collected according to the following procedure:
Representative samples of the reclamation fill and natural soils;
The materials encountered shall be described in accordance with the NZ Geotechnical Society Guidelines for the classification and field description of soils and rocks for engineering purposes;
Freshly gloved hands shall be used to collect soil and the samples shall be placed immediately into the appropriate laboratory supplied sample containers;
Any equipment used to collect the samples shall be decontaminated between sample locations using clean water and Decon 90 (a phosphate-free detergent) rinses; and
Samples shall be shipped in chilled container to an IANZ certified laboratory under chain of custody documentation.
As a minimum, testing shall be for metals and PAH. Any evidence of the presence of asbestos shall trigger testing for asbestos content in soil. The CLP will evaluate any analytical results with respect to the soil classification categories identified in Section 4.4.1 of this DWP. The following basic principles will be adopted to define which materials are cleanfill, managed fill or contaminated fill:
Assume to mid-point where cleanfill and managed fill locations are adjacent to each other;
Assume to mid-point where managed fill and contaminated fill locations are adjacent to each other; and
Assume contaminated fill extends to the cleanfill location.
However, the CLP will review the geological information and the contaminant concentrations of the samples. Depending on the results of the review and the final disposal or placement location of the excavated soil, the CLS may instruct the on-site workers to adopt a variation of the basic principles outlined above.
4.6
Imported material requirements
In the event that any fill or soil is required to be imported to the site, the materials shall comprise either:
Granular materials, which are sourced directly from a licensed quarry. Such material will not require testing, provided documentation confirming the source of the material is kept; or
If soil needs to be imported, then any imported soil shall:
3
Comply with the definition of 'cleanfill' in the MfE publication 'A Guide to the Management of Cleanfills’ (2002) (refer Section 4.4.1 of this DWP);
Be of a solid material of an inert nature; and/or
Be sampled by a suitably qualified CLP at a rate of 1 sample for every 500 m3 and tested to confirm that contaminants are not above published natural background levels of the site. It is preferable if the soil is tested at its source prior to its placement at the site. If not, the materials shall be stockpiled on site until test results are available.
MfE, revised 2011: Contaminated Land Management Guideline No. 5 – Site Investigation and Sampling.
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4.7
Sealing Excavation Service Trenches
If contaminated fill is encountered, and sealing of service trenches is consequently required to prevent them from acting as a conduit for migration of contaminated groundwater away from the site, then a pipe dam will be installed at the boundary of the Project footprint. The pipe dam will be either concrete or some other impervious material to be specified by the drainage design engineer. The dam will encase the pipe and extend up the trench to just below the paved surface as shown in Figure 4.1 below. The locations of pipe dams will be recorded on as-built drainage drawings for the Project area.
Figure 4.1: Pipe Dam
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5
Contaminated Fill Management
5.1
Overview
This section details the procedures for the management of contaminated fill during earthworks. It includes control measures for reducing human exposure to contaminated fill and minimising contaminated discharges to air, land or water. These measures will be established prior to commencement of bulk earthworks in areas of known contamination.
5.2
Excavation of Contaminated Fill
As previously discussed, contamination is only likely to be present within reclamation fill. Areas of contamination will be further defined as indicated in Section 4.5 above. The following protocols shall apply to the excavation of contaminated fill:
Erosion and sediment controls shall be implemented in accordance with the Project Erosion and Sediment Control Plan (ESCP) (refer to Appendix M of the CEMP) before earthworks commence.
Excavated soil shall be placed directly into a truck for immediate off-site disposal to prevent the potential for cross contamination of soils.
Any soils retained on site as part of contingency storage (e.g. during night works) shall be placed in a designated area, contained within the catchment area of the erosion and sediment controls for the site or appropriately bunded and covered with polyethylene or an equivalent impermeable material so as to minimise emission of particulates and stormwater runoff.
Any spillages of contaminated fill during placement in trucks shall be cleaned up as soon as practicable following the spillage. Spillages shall not be left unattended as contaminated fill could be trafficked by trucks and transported onto the public road network.
The earthworks shall be observed by the CLP.
5.3
Water Management
Separation and diversion of clean stormwater away from areas of ground disturbance is standard practice for any earthworks activity but becomes more important where contaminants are present. Any contact between clean stormwater or perched groundwater and potentially contaminated fill/spoil means the water will likely require treatment prior to discharge to the stormwater network. To minimise the potential for clean stormwater to encounter potentially contaminated fill, the stormwater and sediment controls outlined in the Project ESCP shall be implemented during the earthworks. In the event that clean stormwater or perched groundwater comes in contact with potentially contaminated fill, the water shall either be disposed of by a licensed liquid waste contractor or pumped to sewer (subject to approval by Watercare Services Limited). Discharge to stormwater shall only be allowed to occur if the average concentration of samples of effluent collected by the CLP from the outlet of the stormwater treatment system on a daily basis for three consecutive days complies with 50 times the ANZECC ‘Guidelines for Fresh and Marine Water Quality’ (2000) for the protection of marine water species. Table 5.1 provides the stormwater disposal acceptance criteria for common contaminants. Discharge to stormwater shall not be allowed to occur prior to the testing or if the average concentrations do not comply with the acceptance criteria.
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18 Table 5.1: Stormwater disposal acceptance criteria Parameter
ANZECC 95% (marine) (mg/L)
Acceptance concentration (mg/L)
Arsenic
0.0023
0.115
Cadmium
0.0055
0.275
Chromium
0.0274
1.37
Copper
0.0013
0.065
Nickel
0.070
3.5
Lead
0.0044
0.22
Zinc
0.015
0.75
-
No sheen
Hydrocarbons
5.4
Dust Management
Works in the CPO will be undertaken inside the building so that dust controls will only be required to protect workers. Measures to mitigate dust issues are likely to comprise wetting the contaminated fill and the use of dust masks by workers inside the building. The following controls shall be implemented during extraction of contaminated fill in the Lower Queen Street ACZ (ACZ-D as shown in Figure 2.1 of this DWP):
Weather forecasts shall be obtained each day during work to check for predicted high wind conditions and any such predictions shall be notified to relevant construction staff so that dust management procedures are adequately prepared and implemented.
In windy conditions, if soils are dry and friable during excavation then they shall be dampened.
Limit drop heights of soil from the excavator bucket into trucks.
Immediately clean up spilled soil from truck loading areas prior to loading additional trucks.
Ensure vehicles do not leave site with excess soils between the tyre tread as this will be distributed on public roads and will generate dust.
If dust cannot be controlled during excessively windy conditions then earthworks shall cease until conditions are favourable.
Further dust management and monitoring requirements are set out in the project Air Quality DWP (Appendix L of the CEMP).
5.5
Odour Management
The contaminants in soil and groundwater, particularly during excavation in the reclamation fill, may generate odours and vapours. If odorous contaminated fill is encountered, then the actions outlined in Section 7.1 of this DWP shall be implemented. Further odour management and monitoring requirements are set out in the project Air Quality DWP (Appendix L of the CEMP). To prevent odours from causing an effect beyond the boundary of the Project work site, management procedures will include, but not be limited to, the following:
Limiting the time that the excavation of odorous materials is exposed;
Removing excavated odorous material from the site as quickly as possible; and
The use of odour masking agents, chemical counteractants and digestive odour deodorant sprays.
If significant odour is detected and the odorous material cannot be removed quickly, and odour masking agents, chemical counteractants or digestive deodorant sprays are not immediately
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19 available, the odorous material will be covered, and work in that area suspended until suitable mitigation measures can be put in place.
5.6
Decontamination
The following measures shall be implemented to prevent contaminated fill from being dispersed onto roads or transported to another site (excluding transport to a disposal facility) as well as to minimise generation of dust:
Any excess soil on vehicle tyres shall be removed before vehicles leave the works area.
Excess soil shall be removed from vehicles and plant before they leave the works area.
All trucks transporting excavated soil to the selected disposal facility shall be covered to prevent the spillage of soil and dust emissions.
The contractor shall be responsible for both monitoring and cleaning up any soil that is deposited onto public roads or walkways from the Project.
5.7
Monitoring Programme
Regular visual inspections of the earthwork areas will be carried out by the Site Manager or appointed person as follows:
Sediment control and compliance with this Contamination DWP (at least daily);
Dust and odour generation (at least daily)
Water accumulation (at least daily);
Perimeter fencing (at least weekly);
Evidence of olfactory and/or visual contamination of fill material (all loads); and
Access road surface deterioration (at least weekly).
The CLP will also observe the Project works on a regular basis during all ground disturbance activities in order to check compliance with this Contamination DWP. Observation will be increased to weekly periods during bulk earthworks of the reclamation fill materials. All stormwater facilities will be inspected after heavy rain events. Inspections are to identify any blockage which reduces the capacity of the drain; and any erosion or scouring which creates silt and damages the drain. Maintenance to ensure the effectiveness of the control measures will be carried out if the inspections show that this is required. Methods that shall be used to address any breaches of the stormwater system, or any discharges onto soil, are provided in Sections 7.1 and 7.3 of this DWP.
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6
Health and Safety Procedures
6.1
Overview
This Contamination DWP provides procedures for site personnel working in and around contaminated and/or potentially contaminated fill during the excavation works. The procedures are not intended to relieve Auckland Transport, or the DSBJV, of either their responsibility for the health and safety of their workers, contractors and the public, or their responsibility for the protection of the environment. Daily health and safety toolbox meetings will be undertaken and documented. All parties working on the project shall comply with:
Applicable parts of their Company Health and Safety Policy.
Site-specific Health and Safety Plan.
Any requirements of Worksafe New Zealand.
Health and Safety at Work Act 2015.
Any other applicable legislation, regulations, codes and guidelines, including any new relevant regulations that come into force during the Project.
Sub-contractors engaged on the Project are required to provide their own Job Safety Assessment (JSA) for their equipment and workers to the DSBJV for approval prior to the commencement of their works on-site. Sub-contractors are also required to supervise the health and safety of their staff on the Project.
6.2
General Safety Requirements and Training
All Project staff (including sub-contractors) shall be required to participate in a site environmental and sustainability induction, which includes a review of procedures with respect to site contamination. The induction shall be provided such that all relevant personnel understand, prior to commencing work, what procedures are to be implemented in relation to site contamination and why. The purpose of the induction is to educate the workers with respect to the hazards associated with contaminated fill, safe working procedures, safety equipment and requirements, and the response plan in the event of an emergency. An appropriately qualified Health and Safety Officer (HSO), or similar, shall be appointed for the duration of the works. This will ensure that where contamination is being managed, there is a designated person responsible for the implementation of, and adherence to, contamination related health and safety procedures, in addition to the other site specific health and safety requirements. The designated HSO shall ensure that all relevant personnel are familiar with the application and use of required personal protective equipment (PPE) and procedures specified in this DWP and other site specific documentation prior to the commencement of work. The following general safety procedures shall be followed by all personnel entering and/or working in the project construction zone:
Hazards encountered and not identified during the site induction/toolbox shall be reported to the designated HSO.
Any incidents shall be reported to the HSO.
Site personnel shall avoid unnecessary contact with documented and potentially contaminated fill and groundwater.
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6.3
Site personnel who may come into contact with contaminated fill shall be provided with the minimum level of PPE as defined in Section 6.7 of this DWP.
Control Measures
When considering hazard controls, the hierarchy listed below will be followed, in preference from one to five. Example questions are provided to illustrate each step. 1 2 3 4
5
6.4
ELIMINATION – does the task that creates the hazard need to be performed? SUBSTITUTION – can a different tool be used? ENGINEERING – can the hazard be guarded to protect people? ADMINISTRATION – are there warning signs and a procedure to address the hazard? Administrative controls include procedures to reduce the risks associated with identified hazards. These controls include: a Job Safety Analysis (JSA) or Task Analysis. b Work plans. c Training. d Warning signs. e Communication with the Site Manager/HSO. PERSONAL PROTECTIVE EQUIPMENT – is the appropriate PPE being used? The following is noted: a PPE is considered the lowest level of protection against a hazard. b No single combination of protective equipment and clothing can provide protection against all hazards; PPE should be used in conjunction with other protective methods. c The types of PPE will depend on the specific task undertaken. However, certain PPE is required in all work areas.
Identification of Hazards
This DWP identifies potential hazards associated with the presence of soil contamination and recommends procedures to mitigate these risks. Contaminants in reclamation fill materials could include metals/metalloids and hydrocarbons. Other hazards that may be identified during pretesting of the material or during the works are outlined in Section 7 of this DWP. Potential exposure routes for contaminants include:
Inhalation of dust (potentially contaminated and uncontaminated).
Ingestion of potentially contaminated fill or dust.
Dermal absorption of potentially contaminated fill or dust.
Skin and eye contact with potentially contaminated fill or dust.
6.5
Identification of New Hazards
There is the potential for additional hazards to be identified and encountered during the project. The HSO is responsible for reviewing any new work element and assessing whether there are any new associated hazards and associated elimination, isolation and minimisation measures. The HSO shall seek review by the CLP if necessary. The HSO shall then instruct all personnel on the health and safety procedures associated with the new hazard.
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6.6
Hazard Mitigation Procedures
6.6.1
Dust inhalation
Inhalation of dust (whether it is contaminated or not) can pose a health risk and therefore the dust control measures shall be implemented for the duration of the earthworks as outlined in Section 5.4 of this DWP. The following additional measures shall be considered to minimise inhalation of dust:
Monitor wind speed and direction during earthworks;
Workers involved in excavation activities will stand up wind of excavation and vehicle loading areas during windy conditions, where practicable; and
If exposure to dust cannot be prevented dust masks shall be worn.
6.6.2
Vapour inhalation
It is conservatively considered that volatile contaminants could be present in reclamation fill. Mitigation of vapour risk will be achieved as follows:
If there are olfactory indications for vapours or vapours are suspected, the following monitoring shall occur:
Volatile organic compound (VOC) content of the area shall be checked with a calibrated photo-ionisation detector (PID) with a 10.6 electron volt (eV) lamp. If readings are above 50 ppm (refer Table 6.1), work shall stop, the area vacated and the CLP and/or HSO shall be informed. A respirator shall be worn when re-entering the area to re-test the atmosphere. The appropriateness of the trigger level of 50 ppm shall be reviewed by the CLP, depending on the type of contaminants found within the project area.
Lower explosive limit (LEL), oxygen levels shall be checked with a gas meter prior to entering and working within confined spaces. Work shall not commence/continue if levels exceed the triggers set out in Table 6.1 below. The area shall be vacated and the CLP and/or HSO shall be informed to provide advice.
Table 6.1: Gas trigger levels Compound
Trigger level
VOC
Greater than 50 ppm
LEL
Greater than 0% if hot work is proposed Greater than 10% if cold work is being undertaken
Oxygen
Below 19.5% and above 23.5%
Hydrogen sulphide (H2S)
Greater than 10 ppm
Carbon dioxide (CO2)
Greater than 5,000 ppm
Carbon monoxide (CO)
Greater than 25 ppm
Note: Refer Appendix D, response to IPR comments s6.6.2, for rationale for VOC trigger LEL trigger is based on Department of Labour, Safe working in a Confined Space (http://www.business.govt.nz/worksafe/information-guidance/all-guidance-items/confined-space-safe-working-ina/confined%20space.pdf) Oxygen, H2S, CO2 and CO triggers are based on Ministry of Business, Innovation & Employment, Feb 2013, Workplace Exposure Standards and Biological Exposure Indices
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6.6.3
Work shall not resume unless approved by the Site Manager in consultation with the CLP/HSO.
Dermal contact and ingestion
The following precautionary measures shall be implemented to ensure skin contact with and ingestion of contaminants is minimised:
Disposable gloves shall be worn by personnel who need to have contact with contaminated fill during the excavation works. Consideration shall be given to the requirement for tear resistant gloves.
Overalls shall be worn if there is the potential for contaminated fill to contact other parts of the body (legs, arms etc.).
There shall be no eating, drinking or smoking in the works area to prevent contaminated fill contacting food or being ingested directly via soiled hands.
A key factor in controlling dermal contact and ingestion of contaminated fill is through maintaining good personal hygiene. The following shall be observed for works involving contaminated soils:
Hand to mouth and hand to face contact shall be avoided during work.
Hands and face shall be washed before eating, drinking and smoking.
Eating, drinking and smoking shall only be permitted in designated areas.
Overalls worn within the works area shall be removed before leaving the works area.
Disposable coveralls may be worn and disposed of at the end of each working day.
6.7
Personal Protective Equipment
All workers handling or coming into contact with contaminated or potentially contaminated fill shall wear the following PPE to protect against the above risks:
Overalls or disposable coveralls.
Impermeable gloves (tear resistant if appropriate).
Disposable dust masks will be available to workers for use if dust is being generated.
Changes to site specific PPE requirements shall be reflected in all health and safety documentation and all parties notified. The PPE specified above is in addition to that required by the Principal Contractor for non-contamination related health and safety.
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7
Contingency actions
7.1
Unexpected discovery of contamination
If evidence of contaminated fill or hazardous material is encountered during earthworks, work in the area of concern shall cease until the CLP has assessed and identified the material. Evidence of additional contamination likely to trigger a stop work procedure may include:
Visual (buried refuse, metal objects, building material, soil or water staining/bleaching or discolouration).
Chemical odours (fuel, sulphurous, rotting vegetation or sewage).
Separate phase liquids or ‘rainbow effect’ films on groundwater.
Auditory (gas leaks, flowing or dripping liquid).
Fibrous cement based board materials that may contain asbestos.
If any such indicator is observed during earthworks, the following steps will be taken:
Cease all work within a 20 m radius and make the work area safe and restrict access to all workers until instructed by the Site Manager.
Shut off all ignition sources and, if possible, contain any contaminant discharge and close/divert any water flow.
Advise the Site Manager.
Work shall not resume until the ‘all clear’ is given by the Site Manager.
The Site Manager (in consultation with the CLP) shall assess the site. If the assessment concludes that confirmation of contamination is required, the following actions shall be implemented:
Control the site: install temporary fencing, temporary cover, silt traps and bunding as required around the area of potential contamination.
Small volumes of excavated contaminated fill shall be contained in covered skips to minimise contaminated discharges from rainfall runoff and dust.
If this is not possible, larger volumes shall be covered and bunded to manage dust and storm water runoff.
Potentially contaminated water shall be collected and disposed of to an appropriately licensed treatment facility. It must not be discharged to the construction storm water system.
Samples of the suspect contaminated fill shall be collected (by appropriately trained and qualified personnel) for laboratory analysis using appropriate procedures.
Notify Auckland Council as soon as practicable.
The results of the laboratory analysis shall be assessed against the relevant human health and environmental discharge regulatory standards/acceptance criteria as appropriate.
If asbestos fragments are encountered in the reclamation fill, earthworks shall follow:
Guidelines for the Management and Removal of Asbestos, revised 1999, Department of Labour;
New Zealand Guidelines for the Management and Removal of Asbestos, March 2011, New Zealand Demolition and Asbestos Association;
Worksafe NZ Position Statement Remediating Asbestos – Contaminated Sites, October 2014; and
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25 Health & Safety at Work (Asbestos) Regulations 2016. Asbestos is a human health related contaminant and no environmental effects are known to be associated with asbestos. Thus, the works will be undertaken in a manner that will protect human health of the workers undertaking the work and the general public in the vicinity of the area. The main aim will be to prevent the generation, and hence inhalation, of airborne asbestos fibres. To mitigate against dust generation, any exposed asbestos or soil containing asbestos shall be kept damp at all times until it is covered, for example placed into bags or a covered metal skip bin or covered by polyethylene. The work involving friable asbestos shall be supervised by a competent person as defined by the Health & Safety at Work (Asbestos) Regulations 2016. All asbestos and any soil containing asbestos shall be appropriately encapsulated or disposed to a landfill approved to take the material.
Remediation options will be selected using the following sustainability hierarchy, refer to Appendix C for the appraisal tool: 1 If practical, on site treatment of the contamination so that it is destroyed or the associated risk is reduced to an acceptable level 2 Offsite treatment of excavated contaminated fill so that the contamination is destroyed or the associated risk is reduced to an acceptable level, after which the treated soil is returned to the site 3 Consolidation and isolation of the contaminated fill is on site by containment with a properly designed barrier It should be noted that if the contaminated fill is proposed to be encapsulated in another area of the project (i.e. not in the area where the contaminated fill was discovered), then further resource consent and approval from Auckland Council is required. 4 Removal of contaminated fill to an approved site or facility, followed, where necessary, by replacement with appropriate material 5 Where the assessment indicates remediation would have no net environmental benefit or would have a net adverse environmental effect, implementation of an appropriate management strategy.
The CLP will be consulted on the handling and management of contaminated fill and/or water, and any specific health and safety precautions that may need to be taken to minimise risk to construction workers/and or the general public.
Any contaminated fill requiring off-site disposal must be disposed of at facilities consented to accept the material.
Maintain a register of any contaminated fill discovered, including location, type, quantity and disposal record (landfill receipts and waste manifest).
7.2
Complaints procedure
Procedures for handling a complaint are set out in Section 12 of the Project Communication and Consultation Plan and Section 5.3.1 of the CEMP. The following actions shall be undertaken for ground contamination-related complaints.
A written record of all ground contamination related complaints received shall be maintained.
The Site Manager shall initiate an investigation as soon as practicable on receipt of a complaint, but as a minimum shall notify Auckland Council as soon as practicable of the complaint being received, including providing details of any corrective actions taken.
Appropriate feedback will be provided to the complainant, such as the response made and any corrective actions taken, in response to the complaint.
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7.3
Water discharges
Should an incident occur on-site which may result in any unauthorised discharges (e.g. contaminated water to stormwater and/or to soil), the Site Manager and/or Environmental and Sustainability Manager will take control of the situation and coordinate the efforts of site personnel to minimise any adverse impacts. A number of options could be employed if the quality of water being discharged from the site cannot meet the standards required for discharge to stormwater, including, but not limited to: 1. 2. 3.
Using tanker trucks to pump out contaminated water; Improving effluent quality through additional treatment; and/or Discharge to sewer, subject to removal of sediment and issue of any necessary temporary trade waste permits. However, diversion to tradewaste cannot be assumed to be available.
The CLP shall be consulted to assist with defining appropriate control measures in the event that the standards required for discharge to stormwater cannot be met. If contaminated water discharges onto soil, further testing of the impacted soil may need to be carried out. Soil samples shall be collected by the CLP according to the requirements of the NES Soil, the MfE Contaminated Land Management Guidelines No.5. The materials encountered shall be described in accordance with the NZ Geotechnical Society “Guidelines for the classification and field description of soils and rocks for engineering purposes�. The CLP shall identify potential contaminants on the basis of visual and olfactory observations.
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8
Works Summary/Validation Report
On completion of the soil disturbance works, a Works Summary Report (also referred to as a validation report) will be prepared and provided to Auckland Council. The purpose of the Works Summary / Validation Report is to confirm that the objectives of the works have been achieved, and that the works were undertaken according to agreed procedures and reporting on any incidents. The report is required to be prepared by the CLP. The report shall include, as a minimum:
A summary of the works undertaken, including a site plan and a statement confirming whether the excavation of the site has been completed in accordance with the certified Contamination DWP;
The location and dimensions of the excavations carried out, including the location, depth and volumes of contaminated fill, managed fill and cleanfill that required disposal and location of any contaminated fill re-used within the Project footprint;
Copies of the disposal dockets for the contaminated fill, managed fill and ‘cleanfill’ material removed from the site;
Records of all inspections undertaken by the CLP during disturbance works of contaminated fill;
Records of any unexpected contamination encountered during the works and contingency measures undertaken (if applicable);
A summary of soil, perched water and groundwater testing undertaken (if applicable) including tabulated analytical results, and interpretation of the results in the context of the Contaminated Land Rules of the ALW Plan and the PAUP;
Details regarding any complaints and/or breaches of the procedures;
Results of testing, if required, of any spoil disposed offsite;
Results of testing of any imported fill material; and
Any long term monitoring/management requirements.
This report shall be provided to Auckland Council within three months of completion of the soil disturbance works. The Works Summary / Validation Report shall comply with the MfE Contaminated Land Guideline No. 1 - Guidelines for Reporting on Contaminated Sites in New Zealand.
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9
Review and Updating of the DWP
This Contamination DWP has undergone a review process with the Community Liaison Group (CLG) established for the Project and a suitably qualified independent peer reviewer. An explanation of how any comments from the CLG and independent peer reviewer are addressed in the Contamination DWP is provided in Appendix D.
9.1
DWP Review
This Contamination DWP will be reviewed throughout the course of the Project: a b
To reflect material changes associated with changes to construction techniques, the natural environment or due to unresolved complaints. As part of the annual management review of the DWP.
The management review of the DWP will be undertaken at least annually by the Project Management team and the AT representatives. The management review will be organised by the Environmental and Sustainability Manager and the Project team will be informed of any changes to this DWP through the regular Project communications processes. The review will take into consideration:
Compliance with the designation or consent conditions, the CEMP, DWPs and EMPs (including site specific plans) and material changes to these plans.
Any significant changes to construction activities or methods.
Key changes to roles and responsibilities within the Project team.
Changes in industry best practice standards.
Changes in legal or other requirements (social and environmental legal requirements, consent conditions, AT objectives and relevant policies, plans, standards, specifications and guidelines).
Results of inspections, monitoring and reporting procedures associated with the management of adverse effects during construction.
Comments or recommendations from Auckland Council regarding the CEMP, DWPs and EMPs.
Unresolved complaints and any response to complaints and remedial action taken to address the complaint.
9.2
DWP Updates
The process for updating this DWP as a result of a material change to the Project or the annual review, is as follows (refer to CRL designation Condition 23 for further information):
Any material change to this DWP must be consistent with the purpose and objective of the relevant conditions listed in Table 1.1 of this document.
Affected parties and the CLG must be notified of the review and any material change proposed to this DWP.
This DWP must clearly document the comments and inputs received from affected parties in relation to any material changes, along with a clear explanation of where any comments have not been incorporated, and the reasons why not.
Any material change proposed to this DWP shall be subject to an independent peer review as required by CRL Condition 11.
Any material change proposed to this DWP relating to an adverse effect shall be submitted for approval to Auckland Council Compliance and Monitoring Officer, at least 10 working days prior to
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29 the proposed changes taking effect. If any changes are not agreed, the relevant provisions of the RMA relating to approval of outline plans shall apply. A copy of the original Contamination DWP document and subsequent versions will be kept for the Project records, and marked as obsolete. Each new / updated version of the Contamination DWP documentation will be issued with a version number and date to eliminate obsolete Contamination DWP documentation being used. A summary of the review process will be provided annually to Auckland Council and otherwise be made available on request.
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Applicability This report has been prepared by Tonkin & Taylor Ltd for the benefit of the Downer Soletanche Bachy Joint Venture with respect to Contract 1 of the CRL Enabling Works. This report has been prepared with respect to the particular brief given to us and it may not be relied upon in other contexts or for any other purpose without our prior review and agreement. Recommendations and opinions contained in this report are based on previous investigations and monitoring data. The nature and continuity of the subsoil away from the test and sample locations is inferred but it must be appreciated that actual conditions may vary from the assumed conditions.
Report certified by a suitably qualified and experienced practitioner as defined by the NES Soil Users Guide (April 2012):
.......................................................... Lean Phuah Senior Contaminated Land Specialist
Authorised for Tonkin & Taylor Ltd by:
pp .......................................................... Peter Millar Project Director
Contamination Delivery Work Plan
June 2016
Appendix A:
ISCA Requirements
Table A identifies the ISCA Credit Requirements relevant to this Contamination DWP and where they are addressed in the document. Table A: ISCA Requirements ISCA Credit
ISCA Requirement *
Relevant section
Other relevant information
LAN-3 Level 1
Site assessment follows recommended approach
This document
A site investigation has been completed for the Project - refer Section 3 of this DWP and the following reports: - City Rail Link Contaminated Land Assessment July 2012, prepared by AECOM; - Auckland City Rail Link Britomart to Wyndham Contaminated Land Assessment December 2014, prepared by Golder Associates; and - Auckland City Rail Link Britomart to Wyndham Water Quality Assessment December 2014, prepared by Golder Associates. As outlined in Section 3 of this DWP, the limited sampling of the Project area undertaken to date has identified that ground material complies with applicable NES Soil contaminant standards and the ALW Plan and PAUP permitted activity criteria. Therefore, at this stage a Remediation Action Plan is not required. Further site investigations will be undertaken prior to the commencement of excavation as outlined in Section 4.5 of this DWP. Ongoing monitoring and further sampling will continue during excavation as outlined in Sections 4.4, 4.5 and 5.7 of this DWP. Supervision by a Contaminated Land Professional will occur when excavating in areas suspected of being contaminated (refer to Section 4.1 of this DWP).
LAN-3 Level 2
Remediation options are identified and selected using sustainability indicator as detailed and using a multicriteria analysis or other scored or quantified means.
7.1, Appendix C
Sampling of limited scope identified material that complies with applicable NES Soil contaminant standards and the ALW Plan and PAUP permitted activity criteria. Therefore, at this stage a Remediation Action Plan is not required. Should contaminated material be identified, the Contamination Remediation Options Appraisal (Appendix C) will be completed.
LAN-3 Level 2
Site assessment work audited by qualified independent specialist
N/A
This will be completed as part of resource consenting process for this Project.
* Refer to ISCA Rating Tool for full details of the requirement
Appendix B:
Plans of Works
N
QUAY ST
STAGE 1 CONSTRUCTION ACTIVITIES JULY 2016 TO JANUARY 2017
100
CONSTRUCT TEMPORARY FACILITIES (INCLUDING NEW STAIRS) REMOVE EXISTING STAIRS AND ESCALATORS REMOVE/RELOCATE PUBLIC ARTWORK ROAD AND FOOTPATH ALIGNMENTS MODIFIED
80
90
EMERGENCY EGRESS MAINTAINED WHILE UPPER CPO IS TENANTED
70
TRAFFIC DIRECTION REVERSED ON TYLER ST
SITE ACCESS
SITE EGRESS REMOVE CANOPIES
50
60
QUEEN ELIZABETH II SQUARE
40
LAYDOWN AREA
PRECINCT
SITE EGRESS
10
20
30
(NOT PART OF WORKS)
ORIGINAL SCALE OF MM.
0
CONSTRUCTION ZONE WORK PHASED TO ALLOW EMERGENCY ONLY PUBLIC ACCESS DURING OPERATING HOURS SITE ACCESS
CPO TO REMAIN OPEN. UPPER FLOORS REMAIN TENANTED LAYDOWN AREA
SITE EGRESS
SITE ACCESS COMMERCE ST
QUEEN ST
GALWAY ST
REMOVE CANOPIES
REV
AMENDMENT
BY NAME
DATE
CITY RAIL LINK ENABLING WORKS CONTRACT 1 STAGE 1 OVERVIEW TEMPORARY STATION ENABLING WORKS
CONTRACT No.
880201-250
DWG. SCALE (A3 Original)
1:500 @ A3 DRAWING No.
REVISION
STAGE 1 CONSTRUCTION
09.05.2016
N
QUAY ST
STAGE 2 CONSTRUCTION ACTIVITIES JANUARY 2017 TO MAY 2017
100
CONSTRUCT DUST/NOISE BARRIERS STRIP OUT CPO CPO GROUND FLOOR DEMOLITION CPO DIAPHRAGM WALL CONSTRUCTION (BEGIN) B2 TEMPORARY ACCOMMODATION WORKS
80
90
MAIN CONSTRUCTION ACCESS INTO CPO. BUS SHELTERS REMOVED. SITE FENCED AND GLASSHOUSE PROTECTED. SITE PARKING PROVIDED ALONG TYLER ST
70
TRAFFIC DIRECTION REVERSED ON TYLER ST
TYLER ST
PRECINCT
CONSTRUCTION ZONE ALL PUBLIC ACCESS TO CPO CLOSED. UPPER FLOORS VACATED BY TENANTS AND USED AS SITE OFFICES AND STORAGE UNDERTAKE CPO WORKS AND COMMENCE DIAPHRAGM WALL INSTALLATION
WORK AREA SECURELY FENCED
ORIGINAL SCALE OF MM.
0
10
20
30
(NOT PART OF WORKS)
DRYWALL BENTONITE TREATMENT AREA
PUBLIC ACCES NEW STATION LAYOUT IN OPERATION
NOISE/DUST BARRIER BETWEEN CONSTRUCTION AND PUBLIC AREAS
PUBLIC ACCESS
GALWAY ST COMMERCE ST
40
50
60
QUEEN ELIZABETH II SQUARE
QUEEN ST
GALWAY AND COMMERCE STREETS UNAFFECTED
REV
AMENDMENT
BY NAME
DATE
CITY RAIL LINK ENABLING WORKS CONTRACT 1 STAGE 2 OVERVIEW CPO DEMOLITION AND PILING WORKS
CONTRACT No.
880201-250
DWG. SCALE (A3 Original)
1:500 @ A3 DRAWING No.
REVISION
STAGE 2 CONSTRUCTION
09.05.2016
N
QUAY ST
STAGE 3 CONSTRUCTION ACTIVITIES MAY 2017 TO MAR 2020 B2 ACCOMMODATION WORKS & B1-B2 ESCALATOR COMPLETE QUEEN ST PILING CPO AND QUEEN ST EXCAVATION UNDERPINNING CPO BREAK-THROUGH INTO PRECINCT WORKS TUNNEL CONSTRUCTION BACKFILL QUEEN ST REINSTATEMENT STATION BOH B2 WORKS CPO REBUILD
100
SITE BOUNDARY EXTENDED TO QUAY ST
80
90
AUXILIARY SITE ACCESS
70
TRAFFIC DIRECTION REVERSED ON TYLER ST
TYLER ST
40
50
60
QUEEN ELIZABETH II SQUARE
PRECINCT
CONSTRUCTION ZONE PUBLIC ACCESS TO CPO REMAINS CLOSED. UPPER FLOORS USED AS SITE OFFICES AND STORAGE COMPLETE UNDERPINNING, EXCAVATION AND CONCRETE WORKS READY TO CPO OPEN
ORIGINAL SCALE OF MM.
0
10
20
30
(NOT PART OF WORKS)
PEDESTRIAN ACCESS MAINTAINED VIA TEMPORARY FOOTBRIDGE OVER EXCAVATION
QUEEN ST CLOSED TO VEHICLES BETWEEN TYLER AND GALWAY. PEDESTRIAN ACCESS MAINTAINED
PUBLIC ACCES
CONSTRUCTION ZONE (BACK OF HOUSE AREA)
NEW STATION LAYOUT IN OPERATION
PUBLIC ACCES
DEMOLISH OFFICES AND CUT THROUGH SECANT PILE WALL
GALWAY ST
REV
AMENDMENT
GALWAY AND COMMERCE STREETS UNAFFECTED
QUEEN ST
SITE BOUNDARY AT QUEEN ST / CUSTOM ST INTERSECTION (EXTENDED TO CUSTOM ST)
COMMERCE ST
SITE ACCESS
BY NAME
DATE
CITY RAIL LINK ENABLING WORKS CONTRACT 1 STAGE 3 OVERVIEW PILING, EXCAVATION, CONCRETE WORK AND BACKFILL
CONTRACT No.
880201-250
DWG. SCALE (A3 Original)
1:500 @ A3 DRAWING No.
REVISION
STAGE 3 CONSTRUCTION
09.05.2016
N
QUAY ST
STAGE 4 CONSTRUCTION ACTIVITIES APR 2020 TO JUN 2020
70
80
90
100
CPO OPEN REINSTATEMENT OF QUEEN, TYLER & GALWAY & STATION PLAZA TIE IN RAIL TUNNELS TO EXISTING RAIL AT STATION LINE REMOVE TEMPORARY ACCOMMODATION
NEW PUBLIC REALM REINSTATEMENT
60
QUEEN ELIZABETH II SQUARE
TRAFFIC DIRECTION REVERSED ON TYLER ST
TYLER ST
40
50
REMOVE TEMPORARY ACCOMMODATION BUILDING
PRECINCT
10
20
30
(NOT PART OF WORKS)
0
CPO OPEN ORIGINAL SCALE OF MM.
PUBLIC ACCESS CONSTRUCTION ZONE TIE INTO EXISTING RAIL ALIGNMENT AT STATION LEVEL
QUEEN ST REOPENED
GALWAY AND COMMERCE STREETS UNAFFECTED
QUEEN ST
REV
AMENDMENT
COMMERCE ST
GALWAY ST
BY NAME
DATE
CITY RAIL LINK ENABLING WORKS CONTRACT 1 STAGE 4 OVERVIEW UNDERPINNING REMOVAL AND CPO FIT-OUT
CONTRACT No.
880201-250
DWG. SCALE (A3 Original)
1:500 @ A3 DRAWING No.
STAGE 4 CONSTRUCTION
REVISION
09.05.2016
Appendix C:
Soil Remediation Appraisal
If any unexpected discovery of contaminated soil is encountered during the Project, it will be managed using the ISCA sustainability hierarchy approach. Soil remediation and management options will be assessed in accordance with a rating tool and the following multiple category assessment table will be used to complete this:
DSBJV Contamination Remediation Sustainability Appraisal Location of Contamination 3 2 1 0
Date
Author
Rev 1.0
Remediation Efficiency Rating Major Improvement 3Major Reduction Moderate Improvement 2Moderate Reduction Minor Improvement 1Minor Reduction N/A 0 N/A Criteria
1
Cost of managing remediation
2
Cost of undertaking remediation
3
Effect on programme
4
Health and Safety including to workers and public now and in future
5
Consents/Legal Issues
6
Co-ordination with other activities
7
Environmental Impacts consider air, soil, water, ecology and use of natural resources
8
Waste Minimisation Impacts
9
Community Stakeholder Impacts
10
Cultural Impacts
11
Risk
Remediation Option 4
Remediation Option 5
On-site treatment of the Off-site treatment of excavated Consolidation and isolation of the contamination so that it is soil so that the contamination is soil is on-site by containment with destroyed or the associated risk is destroyed or the associated risk is a properly designed barrier reduced to an acceptable level reduced to an acceptable level, after which soil is returned to the site
Removal of contaminated material to an approved site or facility, followed, where necessary, by replacement with appropriate material
Where the assessment indicates remediation would have no net environmental benefit or would have a net adverse environmental effect, implementation of an appropriate management strategy
Ranking
Ranking
Ranking
Remediation Option 1
Comments
Remediation Option 2
Ranking
Comments
Remediation Option 3
Ranking
Comments
Total Average
Recommendation and Justification NOTE: If an option less favourable than Option 1 is selected, then justification for not selecting options higher on the hierarchy must be provided
Outcome
Comments
Comments
Appendix D:
CLG and Independent Peer Review Comments
Community Liaison Group Comments
Comments received from the CLG are as follows: Date
CLG Member
Comment
Response
24th November 2015
Kathy Ross
Will soil monitoring release contaminants into the atmosphere?
Monitoring will be undertaken to inform the appropriate disposal method for contaminated material – no change to DWP required.
24th November 2015
Kathy Ross
Will dust from contaminated material be toxic?
Based on contaminant levels identified to date and historical information, any dust will be from natural or inert (non-toxic) material – no change to DWP required.
24th November 2015
Peter Bowden
Will contaminated material be disposed of at the Three Kings Quarry?
Based on existing information yes but further soil testing is required to confirm the disposal location – no change to DWP required.
4 May 2016
Cooper and Company
Section 4.1, General Mitigation Measures, states that AC will be notified at least “2 days” prior to commencing any contaminated works or bulk earthworks on site. Condition 83 (RC) refers to 2 “working days” the plan should be amended to reflect this. In the post works section it refers to the production of a “Works Completion Report”. However, elsewhere the terms “Works Summary” or “Validation Report” are used. The conditions used the term “Works Completion Report” suggest amending reference in this section to that term for consistency/clarity.
Section 4.1 General Mitigation Measure’s text updated to 2 working days. Condition 93 and 94 of the regional discharge permit refers to a Works Summary Report. Condition 58.1 of the CRL Designation refers to Validation Report. We could not find a condition that used the term “Works Completion report”. We have amended text thought the DWP to refer to Works Summary / Validation report for consistency and clarity.
4 May 2016
Cooper and Company
Section 4.6, Imported Material Requirements refers to any imported fill complying with the definition of clean-fill and not containing contaminants above the natural background levels. However, condition 91 (RC) also requires that any fill be solid material of an inert nature. Might be helpful to specify that in this section too.
Section 4.6 text updated to refer to condition 91 (RC) requirement that any fill be solid material of an inert nature.
4 May 2016
Cooper and Company
Section 6.1, Overview, refers to new Health and Safety at Work Act “which will come into force on 5 April 2016”. Update to
Section 6.1 text updated to refer to the current status of the Health and Safety at Work Act.
reflect it came into force on that date. 4 May 2016
Cooper and Company
Section 9, Review and Updating of the DWP, sets out the formal review process. This section mentions providing outcome of the annual review process to council but does not mention consultation with CLG. Condition 19 states that the consent holder is required to consult with the CLG upon the review of this plan. Reference should be included here of this obligation.
Section 9 text has been updated to reference Condition 19 requirement to consult with the CLG upon the review of this plan.
18 May 2016
Cooper and Company
Section 5.4 Dust Management, there is a typo “exaction” should be “extraction”.
Section 5.4 text updated to correct typo.
Independent Peer Review Comments
An Independent Peer Review of the draft Contamination DWP was undertaken by Terre Maize from 4Sight Consulting, with peer review comments received on 5th February 2016. The comments received are as follows: Section of DWP
Comment
Response
4.1
Section number reference is missing with regard to Communication and Consultation Plan and CEMP. The designation condition requires crossreferences to specific sections of the Communication and Consultation Plan, and the text says “along with Section xx of the CEMP…”
The Communication and Consultation Plan section reference will be included once that plan is finalised, and prior to finalisation of this Contamination DWP
4.4
There is reference to “an appropriately licensed municipal solid waste landfill” with regard to disposal of contaminated soil. Typically, “municipal solid waste landfill” is the term used for the municipal landfill which accepts general rubbish; e.g., household rubbish. It would probably be more clear if the word “municipal” was removed from the sentence.
The word municipal has been removed.
4.6
While it is not required that the Contract 1 and Contract 2 plans match, the Contract 2 plan specifies testing of imported material at a rate of 1 sample per 100 cubic metres and the Contract 1 plan specifies testing at a rate of 1 sample per 500 cubic metres. The frequency of sampling is dependent on the source, type and homogeneity of the material imported. It would be
Only cleanfill is proposed to be imported and this would be reflected in the selection of the source site and material. Material that requires a high level of testing (e.g. 1 in 100 cubic metres) should not be considered cleanfill and would not be considered in the first place.
Section of DWP
Comment
Response
beneficial to note the rationale for the selection of the sampling frequency for imported material. 5.7
It would be helpful to describe what (if any) methods will be used to address breaches of the stormwater system and any validation sampling requirements in the event of a breach that discharges onto soil.
Additional information is provided in Sections 5.7 and 7.3.
6.6.2
While it is not required that the Contract 1 and Contract 2 plans match, there are areas where they should be consistent. The Contract 1 plan sets a limit of 5 ppm for VOCs (measured with the PID). The Contract 2 plan establishes a limit of 50 ppm VOC as measured by the PID. Typically, at concentrations between 5 and 50 ppm VOC, respiratory protection is required. It would be useful to also note this in the Contract 1 plan as this would make them more consistent and better reflect requirements. The Contract 2 plan also sets out limits for LEL, oxygen, hydrogen sulphide, carbon dioxide and carbon monoxide. The likely contaminants may be different enough that this is not warranted for Contract 1 plan, but it is recommended that it be considered.
PIDs are not contaminant specific and will therefore detect all ionisable compounds that are present in the air space of the work area. The proposed trigger set in the DWP, of 50 ppm, is based primarily on cumulative experience with using the PID working across sites with mixed hydrocarbon contamination. The derivation of this action level was based on balancing the highly variable effects thresholds and response factors of a wide range of potential contaminants e.g. benzene at 1 ppm to petrol at 300 ppm, and higher for some of the other hydrocarbons. Since benzene is rarely present at elevated concentrations, 50 ppm provides a workable yet conservative compromise. Using a much lower level of 5 ppm, is likely to result in false exceedances of the action level as a result of detection of compounds, which are present at higher, although still safe concentrations, or the detection of compounds introduced by other activities which are being undertaken within or adjacent to the work area (for example vehicle exhaust emissions, use of glues, solvents, or paints etc.). This action level should be reviewed by the CLP to ensure it remains appropriate. This recommendation has been added to Section 6.6.2. Trigger levels for the contaminants have been included in Section 6.6.2.
6.6.3
It would be good to state that “hands and face” (not just “hands”) should be washed to reflect industry good practice.
The word “face” has been added.
7.2
Please include the section number for the Communication and Consultation Plan.
The Communication and Consultation Plan section reference will be included once that plan is finalised, and prior to finalisation of this Contamination DWP