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Form current as at December 2015 1

SITE CONTAMINATION AUDIT SYSTEMSITE CONTAMINATION AUDIT STATEMENT

INSTRUCTIONSRequirements relating to site contamination audit statements are prescribed in the Environment ProtectionRegulations 2009 (the Regulations) and include the following:

Regulation 67—Site contamination audit report summary and statement

(1) A site contamination audit report required under section 103Z(4)(a) and (b)(i) of the Act1 must include asummary of the findings of the site contamination audit to which it relates that—

(a) is in the form set out in Schedule 3 clause 8 for site contamination audit statements; and

(b) is certified by the responsible auditor in accordance with the directions contained in the form set outin Schedule 3 clause 8.

(2) A site contamination audit statement required under section 103Z(4)(b)(ii) of the Act in relation to a sitecontamination audit must comprise—

(a) a copy of the summary in the site contamination audit report relating to the audit and itself becertified by the responsible auditor in accordance with the directions contained in the form set outin Schedule 3 clause 8; or

(b) a photocopy, faxed copy or electronic copy of the summary as certified by the responsible auditorin accordance with the directions contained in the form set out in Schedule 3 clause 8.

Audit reports and audit statements are required to be provided to the EPA under section 103Z(4) of the Act,which requires that:

103Z—Requirements relating to site contamination audits(4) A site contamination auditor must, on the completion of each site contamination audit for which the

auditor is the responsible auditor—

(a) provide a site contamination audit report to the person who commissioned the audit; and

(b) at the same time, provide—

(i) a site contamination audit report to the Authority; and

(ii) a site contamination audit statement to the council for the area in which the land to whichthe audit relates is situated and any prescribed body2.

Penalty: Division 5 fine.

Where the audit subject to this form has been completed subject to a restricted scope, the audit reportmust be identified in the title as a ‘Site contamination audit report (restricted scope)’.An audit subject to a restricted scope is not suitable to be relied upon by a planning authority for thepurpose of making decisions as to whether land is suitable for a sensitive use or another use or rangeof uses.Please ensure that all sections of the form are completed, requested information and attachments (wherenecessary) are provided and labelled as indicated.

Please do not modify the form by moving or deleting sections or text, including these instructions.

Please ensure you are using the current version of the form (check the EPA website).

Refer to the current version of the EPA publication Guidelines for the site contamination audit system, for furtherinformation. For any enquiries or questions relating to the site contamination audit system, including requests foreditable versions of this form, contact the EPA Site Contamination Branch.

1 Environment Protection Act 1993.2 Refer to Regulation 68 of the Environment Protection Regulations 2009 regarding prescribed bodies.

http://www.epa.sa.gov.au/

http://www.epa.sa.gov.au/files/4771800_guidelines_sc_audit.pdf

SITE CONTAMINATION AUDIT STATEMENT


Site contamination audit statements must be included in the relevant site contamination audit reports,and be sent to:By mail

Manager, Site Contamination BranchEnvironment Protection AuthorityGPO Box 2607Adelaide SA 5001

Forms can also be emailed in pdf format to the Manager and an auditor’s allocated EPA coordinator.

For any enquiries or questions relating to the site contamination audit system, contact the EPA SiteContamination Branch on:

Telephone: (08) 8204 2004

Email: <[email protected]>

mailto:<[email protected]>



EPA GENI Reference

(EPA use only)

SITE CONTAMINATION AUDIT STATEMENT(under section 103Z of the Environment Protection Act 1993)

This statement contains the summary of the findings of the site contamination audit set out in the sitecontamination audit report titled: [insert title of site contamination audit report]

Site Contamination Audit Report (Restricted Scope). EPA Identified Source Areas 3 and 4, 1284 SouthRoad, Tonsley, South Australia.(referred to in this form as ‘the report’)dated [insert report date]: 17/04/2020

SECTION A: AUDITOR DETAILSName of auditor*: Anthony Lane

Auditor’s accreditation number: 2009010

Name of auditor’s company or business: SLR Consulting Australia

SECTION B: AUDIT SITE DETAILSAuditor’s project reference: 640.11900

EPA reference: 61504

Name of audit site [if applicable]: EPA Identified Source Areas 3 & 4

Address of audit site: 1284 South Road, Tonsley South Australia, 5042

Name of council for area in which audit site issituated [if within council area]:

City of Marion

Provide the following particulars** relating tothe relevant land and the audit:

** If insufficient space, details may beannexed to this form.

- certificates of title of all the relevant landand an indication of whether the audit sitecomprises all or part only of the landshown on or described in the certificates oftitle

CT6235/197 (D122629QP594)

Parts Only- EPA Identified Source Areas 3 and EPAIdentified Source Areas 4

Attachment 1- Certificate of Title

- details sufficient to identify the location ofthe land, including section or allotmentnumbers, area and hundred and AMG co-ordinates (GDA 94, UTM 53 and 54)

Part Allotments 590, 591, 592, 593, 594, 595, 596, 597, 598Deposited Plan 122629 Refer Figure 1 and Figure 2- EPAIdentified Source Areas 3 and 4 (GDA 94)

Hundred Named Adelaide, Area named Clovelly Park


- if the audit site comprises part only of theland described in the certificates of title,or if there is no certificate of title for theland comprising the audit site— surveyplans prepared by a licensed surveyor

Figures 1 and 2- EPA Identified Source Areas 3 and 4 (GDA94)

- audit plans indicating the location and extent of the audit site (which must comply with the guidelinesissued by the EPA from time to time)

SECTION C: AUDIT DETAILS

Name of owner of audit site: Urban Renewal SA Authority trading as Renewal SA

Name of occupier of audit site: EPA Identified Source Areas Area 3: VacantEPA Identified Source Areas Area 4: Minister of Transport

Name, postal address and position ofperson who commissioned audit:

Helen King, Director Environmental ServicesUrban Renewal AuthorityLevel 9 (west), Riverside Centre, North Terrace, Adelaide,South Australia, 5000GPO Box 698, Adelaide SA 5001

Indicate authority of person whocommissioned audit:

EPA Yes NoOwner Yes NoOccupier Yes NoDeveloper Yes NoOther [please specify]

Indicate reasons for audit [indicate allreasons]:

Required under the Development Act 1993Yes No

Required under the Environment Protection Act 1993 Yes No

Other [please specify]

If audit was required under the EnvironmentProtection Act 1993, provide EPA referencenumber:

61504

Indicate audit purposes [indicate allpurposes]:

Determining the nature and extent of any site contaminationpresent or remaining on or below the surface of the site

Yes NoDetermining the suitability of the site for a sensitive use oranother use or range of uses

Yes NoDetermining what remediation is or remains necessary for aspecified use or range of uses

Yes No[NB: an audit may be required for all of the above purposes.]



If audit was required for development plan consent under the Development Act 1993, provide:

Name of relevant planning authority: Not applicable

Development application number [if known]: Not applicable

Site zoning: Not applicable

Proposed site use: Not applicable

Date of commencement of audit: 23 June 2015

Date of notification of commencement of audit toEPA:

7 July 2015 (Original Audit Notification submitted toEPA)

4 April 2016 (Date of notification and submission ofrestricted scope objectives to EPA)

Date of completion of audit: 17/04/2020

SUMMARY OF FINDINGS

A restricted scope has been applied to this site contamination audit. The audit has not considered the suitabilityof land for a sensitive use or another use or range of uses. This site contamination audit report should not berelied upon for the granting of planning and development approvals where site contamination is known or issuspected to exist and a change to a sensitive use is proposed.

CONCEPTUAL SITE MODEL

The following sections provide summary discussions on key topics relating to the Conceptual Site Model (CSM).The CSM presented herein is based on the documented restricted scope in Section 4.1 of the SCAR. It has beendeveloped to determine the presence of plausible complete exposure pathways from potential contaminationsources to susceptible receptors such as humans and/or environmental values. It is based on the ConceptualHydrogeological Model (CHM) and description of sources of groundwater contamination presented in Section 7of the SCAR.

This section has been written with the assistance of the Site Contamination Auditor’s EPA approved specialistteam member Giorgio De Nola (Chemist and toxicologist).

Sources of Contamination

There is no compelling evidence to prove EPA Identified Source Areas 3 and 4 are sources of Volatile ChlorinatedHydrocarbons (VCH) contamination to groundwater. Seven (7) separate VCH source zones or release areas havebeen identified associated with motor vehicle manufacture over the long history of manufacture at the site:

Sources up-gradient (to the east) of EPA Identified Source Areas 3 and 4.

· The Monroe site (two potential sources, Source 1 and 23).

· The former Reckitt & Coleman (R&C) site in the Relocation Area (Source 3, the sewer line and concretesump and tank).

3 The “source” designations here were ascribed by Blue Sphere Environment and are separate from the EPA Identified Source Areas 3 & 4.



· On the MMAL site (between the R&C and Monroe sites) from an unidentified Source4 (Source 4).

· In the Relocation Area (Source 5, the sewer line).

· At or near the location of a former Electroplating Shop (Source 6) east of EPA Identified Source Area 4.

Sources down-gradient (to the west) of EPA Identified Source Areas 3 and Source 4.

· Mitchell Park release Area (Source 7) at a sewer in the vicinity of the intersection of Lanark Avenueand Cumbria Court.

Stormwater drainage lines present above the former sewer line near the boundary between the Relocation Areaand EPA Identified Source Area 3 may have acted as preferential pathway of contaminant migration (mainly VCHand per and poly fluorinated alkyl substances [PFAS]).

PFAS and chromium were also released to groundwater from Source 6 whereas PFAS was released togroundwater from Source 5 and potentially from other sources up-gradient of EPA Identified Source Areas 3 andSource 4. Petroleum hydrocarbons have been released from an area in the vicinity of Source 2 on the Monroesite as well as other zones to the north and northeast of EPA Identified Source Area 4.

PFAS identified in fill on EPA Identified Source Area 3 is understood to be remnants of a concrete slab from theelectroplating facility. This slab was broken up and stockpiled in the centre of this site and has subsequentlybeen removed.

The sources described in this section are considered historical, and as levels of soil impact are low, they do notform significant ongoing secondary sources to groundwater.

Environmental Receptors

The following receptors were identified on EPA Identified Source Areas 3 and 4 and surrounds5:

People potentially exposed:

· Residents (off-site, to the west of EPA Identified Source Areas 3 and 4 and south of EPA IdentifiedSource Area 3).

· Commercial workers (on-site and off-site) including tertiary students (off-site only).

· Intrusive workers including maintenance and construction workers (on-site and off-site).

· Users of extracted groundwater (off-site).

Ecological receptors

· Terrestrial ecosystems (on-site and off-site).

· Aquatic ecosystems in Viaduct Creek (buried concrete pipe beneath Mitsubishi Motors AustraliaLimited MMAL site), Sturt River (a concrete lined channel in the study area), shallow stormwaterdetention ponds in Mitchell Park (not in connection with groundwater) and the Oaklands wetland.

4 There is no evidence for the historical use of VCH in this area. The elevated concentrations may be due to infiltration of VCH impacted water fromunlined open drainage lines in this area, a historic release area and infiltration of washdown water in eastern portion of AOI 14-7 (Source Zone andRelease Area 4).

5 Receptors do not consider those potentially present on the Monroe site or the Residential Audit Area to the north of EPA Identified Source Areas 4which are being addressed in a separate Audit being prepared for each of those sites.



Note that other people may also be present at the site, such as visitors. This CSM has not considered transientexposure to occasional visitors at the site, as on-going daily exposures are generally considered to representmore significant exposure.

Potential Migration Mechanisms and Pathways

The primary release and migration mechanism from primary sources in the manufacturing area or connectedsewers impacting groundwater are considered to be direct discharge to ground or leakage of in-ground sumpsand pipes.

The most feasible migration pathways from secondary sources that have been identified include the following:

· Lateral migration of contaminants in groundwater (plumes of contaminated groundwater).

· Seepage of contaminants from soil to groundwater (historical migration pathway).

· Vertical upward migration of volatile contaminants from groundwater through the vadose zone andinto air, i.e. volatilisation and accumulation in air.

· Extraction of contaminated groundwater from bores.

For the identified migration pathways, the following potential exposure routes of receptors have beenidentified.

· Direct contact (incidental ingestion, dermal contact etc.) with soil.

· Direct contact (incidental ingestion, dermal contact etc.) with extracted non-potable groundwater.

· Inhalation of vapours (e.g. from vapour intrusion).

· Consumption of home grown produce and other products by people irrigating gardens with extractedgroundwater.

Assessment of Source-Pathway-Receptor Linkages (from Secondary Sources)

For a complete exposure pathway to be present in the environment there must a contaminant source, amigration pathway and exposure route to a particular receptor, i.e. a Source-Pathway-Receptor linkage must bepresent. Potentially complete exposure pathways in relation to the site’s contamination status at the time ofthis report are presented below. An illustrative CSM in the form of a cross-section has been prepared by theauditor and their specialist support team for the site reflecting all chemical substances and media based on therestricted scope (Attachment 2 SCAR Appendix B- Figure 1).



On-site 3

IntrusiveWorkers

CommericalWorkers

IntrusiveWorkers

CommericalWorkers Residents Terrestrial Terrestrial Aquatic

Dermal Contact ü ü ûû ûû ûû ûû ûû ûû

Incidental Ingestion of soil ü ü ûû ûû ûû ûû ûû ûû

Inhalation of Dusts and Vapours ü ü ûû ûû ûû ûû ûû ûû

Uptake via Plants ûû ûû ûû ûû ûû ü ûû ûû

Inhalation of Vapours ü ü ü ü ü ûû ûû ûû

Dermal Contact û 1 û 2 û 1 ü ü ûû ûû ûû 4

Inhalation of Vapours û 1 û 2 û 1 ü ü ûû ûû ûû 4

Incidental Ingestion of water û 1 û 2 û 1 ü ü ûû ûû ûû 4

Consumptionof home-grown produce ûû ûû ûû ûû ü ûû ûû ûû 4

Dermal Contact ûû ûû ûû ûû ûû ûû ûû ûû

Inhalation of Vapours ûû ûû ûû ûû ûû ûû ûû ûû

Incidental Ingestion of water ûû ûû ûû ûû ûû ûû ûû ûû

Consumptionof home-grown produce ûû ûû ûû ûû ûû ûû ûû ûû

1. Due to depth to groundwater it is unlikely that construction workers will come in to contact with groundwater2. Groundwater extraction is unlikely to occur on-site and not considered a relevant migration pathway3. On-site refers to EPA Identified Source 3 and 44. Groundwater contaminants are delineated to the west of EPA Idenitified Source 3 and 4 and do not reach aquatic ecosystems off-site

5. To consider deeper acquifer impacts is outside restricted scope audit but discussion is provided in Section 7.5 of the SCAR

Pathway Potentially Complete – a migration pathway and exposure route exist from the source to the potential receptorPathway Insignificant – a migration pathway potentially exists however the exposure is considered unlikely to present an unacceptable risk to the potential receptorPathway Incomplete – no transport mechanism or exposure route exists to the potential receptor

Primary Source Secondary SourceTransport Pathways &Mechanisms

þ Volatilisation andaccumulation in air

þ Impacted sub-surface soils(NB: PFAS in EPAIdentified Source 3)

Stockpile of concreteslab previously storedon EPA Identified Area

3.

þ Dissolvedgroundwater plume

x Non-aqeuous phaseliquid (light or dense)groundwater plume o Dissolution of NAPL,

lateral migration ingroundwater and subsequentextraction

þ Lateral migration ofcontaminants in groundwaterand subsequent extraction

Seven source areas ingroundwater off-sitesurrounding the EPAIdentified Source 3

and 4 with historicalstorage, use and

storage of solventsincluding direct

discharge to sewer.

þ Direct Contact with soils

ReceptorsHuman Ecological Ecosystems

o Vertical migration todeeper aquifers andextraction

Off-siteExposure Route On-site 3 Off-site

Conceptual Site Model Matrix



A potentially complete exposure pathway does not indicate that an unacceptable level of risk of harmis present; rather it provides guidance on the data to be collected in order to confirm whether thepathway is complete and to identify people and/or ecological receptors for which potential health riskmay need to be further assessed.

Endorsement of CSM

The CSM has been progressively developed and refined as information came to hand in each phase ofthe investigation, in accordance with National Environment Protection Measure (NEPM). The revisionsof the CSM were provided to the Auditor for comment and discussion. Discussions were held betweenthe Audit team and BlueSphere for CSM Revision 4 (BlueSphere, 2018e) to confirm aspects of the CSMinterpretation.

The most recent version of the CSM prepared by the site assessor titled ‘Conceptual Site Model (CSM):Tonsley VSCAP Investigation - Revision 04’ dated 26 September 2018 (BlueSphere, 2018e) is endorsedby the Auditor as providing a sufficient basis for assessing and managing risks from VCHs andpetroleum hydrocarbons with regard to soil, groundwater and vapour. This has been supplementedwith additional information following PFAS investigations at the site (BlueSphere 2000).

The Auditor considers the data gaps identified in the 2017 Interim Auditor Advice (IAA) have beensufficiently addressed by the further investigations completed in 2018 (BlueSphere, 2018a, 2018b)and summarised in the CSM. The Auditor also considers that Voluntary Site ContaminationAssessment Proposal (VSCAP) Objectives 1 to 4 have been sufficiently addressed to the point wherean assessment of the need for remediation of EPA Identified Source Areas 3 and Source 4 can becompleted. This is discussed in Section 1 of the Site Contamination Audit Report (SCAR) report.

AUDIT DETERMINATIONS AND AUDIT OUTCOMES

Restricted Scope

The audit site known as EPA Identified Source Areas 3 and 4 and located at 1284 South Road Tonsley,SA 5042 has had a Site Contamination Audit Report completed. As required this Site ContaminationAudit Statement providing the prescribed summary of audit findings has been prepared and isincluded as the Executive Summary to the SCAR.

Given the audit is being undertaken under a Restricted Scope, the audit has not considered thesuitability of land for a sensitive use or other uses. This SCAR should not be relied upon for the grantingof planning and development approvals where site contamination is known or is suspected to existand a change to a sensitive use is proposed.

Other exclusions from the restricted scope are:

· Deep aquifers, below the water table aquifer e.g. deeper Quaternary and Tertiary aquifers.(This audit is restricted to the assessment of the water table Quaternary aquifer from whichvolatile contaminants can be emitted into the vadose zone.)

· Chemical substances that are not associated with the motor vehicle manufacture activitiesthat may have been previously used at the MMAL Site.

· Nature, extent and potential risk associated with soil-adsorbed impacts.

· Community engagement and associated communication activities.



Key aspects included in the restricted scope are:

· The activities undertaken to be applied are motor vehicle manufacture activities at theMMAL site.

· The specific elements of the environment to be considered are groundwater and soil vapour.

· The specific chemical substances to be considered are chemical substances associated withmotor vehicle manufacture including, volatile chlorinated hydrocarbons (VCH), daughterproducts and petroleum hydrocarbons.

· PFAS was subsequently included for consideration in the final restricted scope audit reportat the request of EPA in 2019.

EPA Identified Source Area 3

Groundwater – Area 3

EPA Identified Source Area 3 has VCH contamination which is not derived from on-site activities, andwhich can be attributed to off-site sources, for the following reasons:

· There may be continuity of the Trichloroethylene (TCE) plume emanating from the Monroesite extending onto the EPA Identified Source Area 3 (Figure 3),

· Identified likely release areas (where a drain/sewer conduit from a source area has leaked)and source zones (where a Potentially Contaminating Activity has been undertaken) (Figure3). For the contaminated groundwater plumes migrating through EPA Identified Source Area3 (Groundwater Plumes 1, 3 and 5) these are associated with identified sources on theMonroe (Source Zone 1 and 2), R&C (source zone 3) and MMAL sites including Section 14(source/release area 4) as well as off-site to the south on the Relocation Area (release area5) and associated with the former private sewer originating from the R&C site.

· There is no compelling evidence of EPA Identified Source Area 3 being a source zone orrelease area for groundwater contamination related to VCH.

· Residual soil impacts identified for PFAS on EPA Identified Source Area 3 are well belowadopted criteria and not a plausible source of PFAS concentrations observed in groundwater.

· Petroleum hydrocarbons (benzene and TPH C10 – C40) were not found to be present ingroundwater at EPA Source Area 3 (Figure 4).

The auditor is of the opinion that remediation in the form of institutional controls should beimplemented to mitigate the risk to users of groundwater on-site at EPA Identified Source Area 3 dueto the presence of groundwater contamination originating from sources other than the audit sites andthat the extraction of groundwater should be prevented.

Soil Vapour – Area 3

While the soil vapour risk assessment by Blue Sphere primarily addressed existing site users andresidential and commercial building occupants off-site (there are no buildings on-site), the assessmentwas extended to encompass such potential uses on site. This restricted scope excludes the need tomake conclusive findings about potential future land use suitability. However, some observations aremade in relation to those matters as context and considering risk to workers on-site undertakingexcavations.

The auditor is of the opinion that risk from on-site vapour intrusion is low and acceptable in the areasoff-site to the west, primarily occupied by low density residential housing.



However, potentially unacceptable vapour risks could occur for an occupied commercial building on-site based on levels of TCE and cis-1,2-DCE measured in soil vapour for EPA Source Area 3. These riskfindings are based on the available soil vapour and groundwater data and assumes a future buildingbeing constructed with components at ground surface level. They are a result of a screeningassessment and therefore considered to be conservative in nature. Further risk assessment andpotentially a further site assessment (including soil) and audit would be conducted to address thispotential risk when a specific development proposal (and building design) is in prospect.

Given the current site use, the risk to workers potentially engaged in excavation works particularly inEPA Identified Source Area 3 was assessed. A potentially unacceptable risk was identified forconstruction or maintenance workers entering trenches or excavations along the southern portion ofEPA Identified Source Area 3 and health and safety precautions would be required for these workersto mitigate against potential risk. To ensure all workers who undertake works involving entering andor undertaking excavations or trenching along the southern portion of EPA Identified Source Area 3are aware of potential vapour risks and necessary mitigation measures to avoid and/or reduce theserisks to acceptable levels this information is required to be incorporated into a Site EnvironmentalManagement Plan (SEMP) provided to all workers prior to commencement of works. In the centraland northern portion of EPA Identified Source Area 3 the auditor considers this risk as acceptable.

EPA Identified Source Area 4

Groundwater – Area 4

The auditor is of the opinion that EPA Identified Source Area 4 has VCH and PFAS contamination ingroundwater which is not derived from on-site sources and can be attributed to off-site sources, forthe following reasons:

Based on the information collected and reported to date there is no compelling evidence of EPAIdentified Source Area 4 accommodating a potentially contaminating activity or being a source zoneor release area for groundwater contamination related to VCH, petroleum hydrocarbons orhexavalent chromium. A hexavalent chromium plume was identified close to the northern boundaryof EPA Identified Source Area 4 but outside the audit area. Similarly, petroleum hydrocarbons(benzene and TPH C10 – C40) were not found to be present on EPA Identified Source Area 4 (Figure 4).

In considering the nature and extent of PFAS contamination the Auditor has concluded that there areno known sources of PFAS in soil on EPA Identified Source Area 4, however PFAS identified in soil onthe adjacent property (former Electroplating Shop), was found away from its boundary within EPAIdentified Source Area 4. A PFAS contaminated groundwater plume sourced from the ElectroplatingShop extends beneath the Residential Audit Area (separate audit undertaken by Mr Adrian Webber,Mud Environmental, 2017) to the north, EPA Identified Source Area 4 and off-site to the west.Groundwater is currently delineated to water quality criteria for primary contact recreational wateruse for PFOS+PFHxS on-site at EPA Identified Source Area 4

The distribution of VCH in groundwater beneath EPA Identified Source Area 4 suggests groundwatercontamination is migrating to EPA Identified Source Area 4 from up-gradient sources which include:

· One or more sources adjacent to the south-eastern corner of the area (Groundwater Plume8). These sources may be on the MMAL site under the TAFE Building (in the former MainAssembly Building), or further upgradient on the Monroe Site (Source Zone 1- Monroe Southand Source Zone 2- Monroe North) (Figure 3).



· One source at or near the former Electroplating Shop (Source Zone 6) to the north-west ofEPA Identified Source Area 4 (Groundwater Plume 6) (Figure 3). The VCH in this source zoneis co-mingled with a hexavalent chromium (Figure 3 and 4) and PFAS plume (noting thatchromium has not migrated onto EPA Identified Source Area 4) from the formerElectroplating Shop.

The auditor is of the opinion that remediation in the form of institutional controls should beimplemented to mitigate the risk to users of groundwater on-site at EPA Identified Source Area 4 dueto the presence of groundwater contamination originating from sources other than the audit sites andthat the extraction of groundwater should be prevented.

Soil Vapour – Area 4

The auditor is of the opinion that risk from on site vapour intrusion is low and acceptable for anoccupied building in a commercial setting for EPA Identified Source Area 4. These risk findings arebased on the available soil vapour and groundwater data and assumes a future building beingconstructed with components at surface level. They are a result of a screening assessment andtherefore considered to be conservative in nature. Further assessment may be conducted to addressthis conservativeness, when a specific development proposal (and building design) is in prospect.Further assessment of soil, which was beyond the scope of this VSCAP and audit (refer Section 4.1), isrequired before the site could be assessed for its suitability for commercial uses.

Risk for construction or maintenance workers entering shallow trenches within EPA Identified SourceArea 4 is considered acceptable.

Risk characterisation for the vapour intrusion pathway at off-site locations in the residential setting tothe west of the site was performed. There were no exceedances identified for TCE or 1,1-DCE forbuildings with slab on grade construction or crawl spaces and trenches.

Key audit outcomes

The key outcomes for the restricted scope are summarised as follows:

· the Auditor considers the nature and extent of site contamination which affects or threatenswaters at the audit site to be of a nature that is not trivial.

· The Auditor considers that information is sufficient to define the nature and extent of andrisks from groundwater and soil vapour contamination within the audit site from EPAIdentified Source Areas 3 and Source 4 and migrating off the western boundary of the Sitefrom these or other sources as discussed in the above sections for both EPA Source Zones 3and 4.

· The Auditor’s opinion with regard to whether remediation is or remains necessary within theaudit site can be summarised as follows:

· Active Remediation including treating, containing, or removing chemical substances isnot and does not remain necessary for any contaminants considered including PFAS onEPA Identified Source Area 3 and EPA Identified Source Area 4

· There is a need for remediation through management requiring the implementation ofinstitutional controls to mitigate the risk to site workers from vapour intrusion intoexcavations in EPA Identified Source Area 3 and;



· There is a need for remediation through management requiring the implementation ofinstitutional controls to mitigate the risk to users of groundwater on-site and off-site dueto the presence of groundwater contamination originating from sources other than theaudit sites.

AUDIT CONDITIONS AND RECOMMENDATIONS

Conditions of Environmental Audit

This audit is being undertaken as a Restricted Scope and as such determination on the suitability ofthe site for sensitive or other land uses is an exclusion from the current audit and has not beenconsidered.

Conditions of the audit and condition categories are as follows:Condition Category: Water restrictionsCondition 1 Groundwater at and from this audit site (EPA Identified Source Areas 3 & 4) is

contaminated and must not be used for existing or potential extractive beneficialuses of: Potable Water Supply, Irrigation, Stock Watering, Primary ContactRecreation and Industrial Water Use. Consequently, no groundwater shall beextracted at this site for such uses. Recommendation 1 below identifies the area ofaffected groundwater. Groundwater may be extracted for the purpose ofmonitoring.

Condition Category: Remediation and managementCondition 2 A Site Environmental Management Plan (SEMP) (Attachment 3) to mitigate risk from

vapour intrusion to site workers in excavations in EPA Identified Source Area 3 mustbe implemented. This plan is entitled “Addendum to Environmental ManagementPlan, Tonsley Innovation District, EPA designated Source Area” BlueSphereEnvironment, April 2020 reference 50130.17 RPT_Final.

Recommendations of Environmental Audit

In considering the audit conditions with regard to the restricted scope the auditor provides thefollowing supporting recommendations:Recommendation 1

The EPA should consider declaration of a Groundwater Prohibition Area (GPA) toprevent extraction of the contaminated groundwater identified in this audit. Theaffected area includes both EPA Identified Source Areas 3 & 4 as well as theaggregated plumes of contaminated groundwater off-site to the west of the auditsites. A “buffer zone” should be added to the mapped plumes beyond the existingouter ring of monitoring bores. The suggested buffer distances should be elongated,extending no less than 500m in the direction of groundwater flow to the north westfrom the furthest bore; the buffer to the northeast and south west (perpendicularto the dominant flow direction) should be no less than 250m from the outer ring ofthe monitoring bore network. It is understood that the actual boundary of the GPAwould be determined by EPA and follow cadastral, title or municipal boundaries.

Recommendation 2The Site Environmental Management Plan required to be implemented in Condition2 above, and required to manage exposure to workers potentially undertaking



excavations on EPA Identified Source Areas 3, should be in the form of a succinct addendum to the existing site-wide management plan applied by Renewal SA to all site activities at Tonsley and titled ““Tonsley Innovation District, Environmental Management Plan” August 2016, reference J115317-05 EMP” and is updated from to time and provided to all workers undertaking excavation or trenching on site.

CERTIFICATION OF COPY OF SUMMARY FINDINGS

I certify that the summary of findings contained within or annexed to this statement represents a true and accurate summary of the findings of the site contamination audit set out in the report.

Signed*:

Dated:17/04/2020

* This form must be completed and signed by the ‘responsible auditor’, being, under the Environment Protection Act 1993 and the Environment Protection Regulations 2009, the auditor who personally carried out or directly supervised the work involved in the audit.

This site contamination audit statement must be lodged, on completion of the audit, with the council for the area in which the audit site is situated and any prescribed body (see regulation 68 of the Environment Protection Regulations 2009).

The report (including the summary of findings) will be recorded in the public register kept by the EPA under section 109 of the Environment Protection Act 1993.



Figure 1: Deposited Plan of EPA Identified Source Areas 3 and Source 4 (Adopted fromAlexander Symonds)



Figure 2- Deposited Survey Plan of EPA Identified Source Area 3 (Adopted from AlexanderSymonds)



Figure 3- Known and Inferred VCH Source Zones and Release Areas (after Figure F49BlueSphere, 2018)

Figure 4- Known and Inferred Petroleum Hydrocarbon and Hexavalent Chromium SourceZones (after Figure F51 BlueSphere, 2018)



Attachment 1- Certificate of TitleAttachment 2- Illustrative Conceptual Site ModelAttachment 3- BlueSphere (2020). Addendum to Environmental Management Plan TonsleyInnovation District EPA Designated Source Area 3. BlueSphere Environment, April 2020.Reference 50130.17_RPT_Final

The Registrar-General certifies that this Title Register Search displays the recordsmaintained in the Register Book and other notations at the time of searching.

Certificate of Title - Volume 6235 Folio 197Parent Title(s) CT 6230/763

Creating Dealing(s) RTC 13257449

Title Issued 05/03/2020 Edition 1 Edition Issued 05/03/2020

Estate TypeFEE SIMPLE

Registered ProprietorURBAN RENEWAL AUTHORITY

OF LEVEL 9 (WEST) RIVERSIDE CENTRE NORTH TERRACE ADELAIDE SA 5000

Description of LandALLOTMENT COMPRISING PIECES 590, 591, 592, 593, 594, 595, 596, 597 AND 598 DEPOSITED PLAN 122629IN THE AREA NAMED TONSLEYHUNDRED OF ADELAIDE

PORTIONS OF THE WITHIN LAND MARKED H3, H8 AND H17 ON D122629 ARE LIMITED TO THE REDUCEDLEVELS A.H.D. AS DESCRIBED ON D122629

EasementsSUBJECT TO EASEMENT(S) OVER THE LAND MARKED A ON D122629 TO DISTRIBUTION LESSORCORPORATION (SUBJECT TO LEASE 8890000) (T 2487015)

SUBJECT TO EASEMENT(S) OVER THE LAND MARKED ET ON D122629 (RTC 12828624)

SUBJECT TO EASEMENT(S) OVER THE LAND MARKED FF ON D122629 FOR THE TRANSMISSION OFELECTRICITY BY UNDERGROUND CABLE (RTC 12928317)

SUBJECT TO EASEMENT(S) OVER THE LAND MARKED G ON D122629 (TG 11479066)

SUBJECT TO EASEMENT(S) OVER THE LAND MARKED H ON D122629 TO THE COUNCIL FOR THE AREA (T2663918)

SUBJECT TO EASEMENT(S) OVER THE LAND MARKED J ON D122629 TO DISTRIBUTION LESSORCORPORATION (SUBJECT TO LEASE 8890000) (TG 8927423)

SUBJECT TO EASEMENT(S) OVER THE LAND MARKED K ON D122629 (TG 11479065)

SUBJECT TO EASEMENT(S) OVER THE LAND MARKED P ON D122629 TO DISTRIBUTION LESSORCORPORATION (SUBJECT TO LEASE 8890000) (TG 12527198)

SUBJECT TO EASEMENT(S) OVER THE LAND MARKED TT ON D122629 TO THE MINISTER FORINFRASTRUCTURE (TG 7455289)

SUBJECT TO EASEMENT(S) WITH LIMITATIONS OVER THE LAND MARKED EA ON D122629 (RTC 12356771)

SUBJECT TO EASEMENT(S) WITH LIMITATIONS OVER THE LAND MARKED GA ON D122629 (RTC 12356771)

SUBJECT TO EASEMENT(S) WITH LIMITATIONS OVER THE LAND MARKED SWA ON D122629 (RTC 12356771)

SUBJECT TO EASEMENT(S) WITH LIMITATIONS OVER THE LAND MARKED SWB ON D122629 (RTC 12356771)

SUBJECT TO FREE AND UNRESTRICTED RIGHT(S) OF WAY OVER THE LAND MARKED NC ON D122629 (RTC

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12326047)

SUBJECT TO RIGHT(S) OF WAY OVER THE LAND MARKED L ON D122629 (RTC 12356771)

SUBJECT TO RIGHT(S) OF WAY OVER THE LAND MARKED LA ON D122629 (RTC 12356771)

SUBJECT TO RIGHT(S) OF WAY OVER THE LAND MARKED N ON D122629 (RTC 12356771)

SUBJECT TO RIGHT(S) OF WAY OVER THE LAND MARKED NA ON D122629 (RTC 12356771)

SUBJECT TO RIGHT(S) OF WAY OVER THE LAND MARKED ND ON D122629 (RTC 12326047)

SUBJECT TO RIGHT(S) OF WAY OVER THE LAND MARKED RD ON D122629 (RTC 12218621)

SUBJECT TO RIGHT(S) OF WAY OVER THE LAND MARKED RE ON D122629 (RTC 12828624)

SUBJECT TO RIGHT(S) OF WAY AND EASEMENT(S) OVER THE LAND MARKED B ON D122629 (RTC 12356771)

SUBJECT TO RIGHT(S) OF WAY AND EASEMENT(S) OVER THE LAND MARKED SS ON D122629 (RTC 12356771)

SUBJECT TO PARTY WALL RIGHT(S) OVER THE LAND MARKED ER ON D122629 (RTC 12828624)

SUBJECT TO SERVICE EASEMENT(S) OVER THE LAND MARKED C ON D122629 FOR ELECTRICITY SUPPLYPURPOSES TO DISTRIBUTION LESSOR CORPORATION (SUBJECT TO LEASE 8890000) (223LG RPA)

SUBJECT TO SERVICE EASEMENT(S) OVER THE LAND MARKED D(T/F) ON D122629 FOR ELECTRICITY SUPPLYPURPOSES TO DISTRIBUTION LESSOR CORPORATION (SUBJECT TO LEASE 8890000) (223LG RPA)

SUBJECT TO SERVICE EASEMENT(S) OVER THE LAND MARKED E ON D122629 FOR DRAINAGE PURPOSES TOTHE COUNCIL FOR THE AREA (223LG RPA)

SUBJECT TO SERVICE EASEMENT(S) OVER THE LAND MARKED Q(T/F) ON D122629 FOR ELECTRICITY SUPPLYPURPOSES TO DISTRIBUTION LESSOR CORPORATION (SUBJECT TO LEASE 8890000) (223LG RPA)

SUBJECT TO SERVICE EASEMENT(S) OVER THE LAND MARKED SEW ON D122629 FOR SEWERAGE PURPOSESTO SOUTH AUSTRALIAN WATER CORPORATION (223LG RPA)

SUBJECT TO SERVICE EASEMENT(S) OVER THE LAND MARKED VV ON D122629 FOR DRAINAGE PURPOSESTO THE COUNCIL FOR THE AREA (223LG RPA)

TOGETHER WITH EASEMENT(S) OVER THE LAND MARKED BB ON D122629 APPURTENANT ONLY TO PIECE 592(RTC 12356771)

TOGETHER WITH FREE AND UNRESTRICTED RIGHT(S) OF WAY OVER THE LAND MARKED U ON D122629APPURTENANT ONLY TO PORTION OF PIECE 597 MARKED Y ON D122629 (RTC 12928317)

TOGETHER WITH PARTY WALL RIGHT(S) OVER THE LAND MARKED ES ON D122629 (RTC 12828624)

Schedule of DealingsDealing Number Description

11336789 LEASE TO MITSUBISHI MOTORS AUSTRALIA LTD. COMMENCING ON 1/2/2010 ANDEXPIRING ON 31/1/2020 OF PORTION (AREA B IN F53777)

11336790 LEASE TO MITSUBISHI MOTORS AUSTRALIA LTD. COMMENCING ON 1/2/2010 ANDEXPIRING ON 31/1/2020 OF PORTION (OFFICE A, OFFICE B, OFFICE C, OFFICE D, OFFICEE, OFFICE G, OFFICE H AND CARPARK K IN F53777)

13008134 APPLICATION PURSUANT TO SECTION 103P(2) OF THE ENVIRONMENT PROTECTIONACT 1993 NOTING THAT A SITE CONTAMINATION AUDIT REPORT HAS BEEN PREPAREDIN RESPECT OF THE WITHIN LAND

NotationsDealings Affecting Title NIL

Priority Notices NIL


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Notations on Plan NIL

Registrar-General's Notes

UNAPPROVED FILED PLAN FOR LEASE PURPOSES FX252155APPROVED FILED PLAN FOR LEASE PURPOSES FX252195APPROVED FILED PLAN FOR LEASE PURPOSES FX53777APPROVED D123306

Administrative Interests NIL


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Conseptual Site Model

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DISCLAIMER: All information within this document mayt be based on external sources. SLR Consulting Pty Ltd makes no warranty regarding the data’s accuracy or reliablity for any purpose.

Addendum to Environmental Management Plan Tonsley Innovation District

Works Involving Excavation in EPA Designated Source Area 3

Prepared for:

Renewal SA

Level 9 (West), Riverside Centre North Terrace

Adelaide SA 5000

16 April 2020

Addendum to Environmental Management Plan Tonsley Innovation District Works Involving Excavation in EPA Designated Source Area 3 50130.17_RPT_Final_16Apr20

Addendum to Environmental Management Plan Tonsley Innovation District

Works Involving Excavation in EPA Designated Source Area 3

Distribution

Copies Recipient Copies Recipient

1 Meredith Rasch, Renewal SA 1 BlueSphere Project File 1 Anthony Lane, SLR Consulting

Authored and Reviewed by:

Role BlueSphere Personnel Signature

Author: Sally Egan Senior Associate Environmental Engineer

Author: Dr Rory Lane Principal Environmental Chemist

Peer Review: Larissa Willoughby Principal Environmental Engineer

Revision History

Revision Date Issued Document Status

00 16 April 2020 Final

Prepared by: BlueSphere Environmental Pty Ltd 438 Goodwood Road

Cumberland Park SA 5041

ABN: 33 095 162 893 ACN: 146 980 761


i

Table of Contents

1 Introduction 1 1.1 Site Contamination Audit 1 1.2 Site Definition 1 1.3 Definition of Excavation 1 1.4 Objective 1 1.5 Site History 2 1.6 Summary of Soil Vapour Impacts at Source Area 3 2 1.7 Nature of the Primary Contaminants of Concern 2

2 Implementation and Management 4 2.1 Roles and Responsibilities 4 2.2 Induction and Awareness 5

3 Relevant Legislation and Guidelines 7 3.1 WH&S Legislation, Regulations and Guidelines 7 3.2 Environmental Legislation, Regulations and Guidelines 7 3.3 Licences and Permits 7

4 Potential Environmental Impacts – Excavation Works 8

5 Managing Vapour Risks to Construction and Maintenance Workers 10 5.1 Vapour Emissions 10 5.1.1 Issues 10 5.1.2 Objectives 10 5.1.3 Performance Standards 10 5.1.4 Vapour Management Protocol 10

6 Limitations 13

References 14


ii

List of Tables (Body of Report)

Table 1 Roles and Responsibilities 4

Table 2 Schedule of Inductions and Meetings 5

Table 3 Summary of Potential Environmental Impacts 8

Table 4 Vapour Management Protocols 11

List of Figures

Figure F1 Site Location Plan


1

1 Introduction

BlueSphere Environmental (BlueSphere) was engaged by Renewal SA to provide an addendum to the existing site-wide Environmental Management Plan (EMP) for civil and construction works for the Tonsley Innovation District (TID).

The existing EMP (which may be periodically updated) is referenced as follows:

• Environmental Management Plan, Renewal SA, Tonsley Redevelopment Project, Greencap, 12 August 2016.

This addendum has been prepared to specifically address health & safety and environmental risks relating to residual site contamination in a portion of the TID known as EPA Designated Source Area 3 and should be read in conjunction with the existing site-wide EMP.

It should be noted that this addendum or the TID site-wide EMP do not replace the need for each person/organisation engaged in ground-breaking activities at the site from assessing risks and applying risk management measures in accordance with WHS and environmental regulations applying in SA.

1.1 Site Contamination Audit

Renewal SA has engaged Mr Anthony Lane (the Auditor) of SLR Consulting Australia (SLR) to conduct a restricted scope Site Contamination Audit (SCA) of two non-contiguous areas known as EPA Designated Source Areas 3 and 4. The EPA reference number for the SCA is 61504. Renewal SA has advised that the preparation of a Site Environmental Management Plan in relation to residual site contamination at EPA Identified Source Area 3 was a recommendation in the Site Contamination Audit Report (SCAR).

1.2 Site Definition

This Addendum to the EMP relates to the southern portion of the site contamination audit area (known as EPA Designated Source Area 3, hereafter referred to as Source Area 3), which is located in the south western corner of the Tonsley Innovation District (TID). The location of EPA Designated Source Area 3 (which is hereafter referred to as “Source Area 3”) is shown on the attached Figure F1.

The TID occupies the site of the former Mitsubishi Motors Australia Ltd (MMAL) Tonsley Park motor vehicle manufacturing facility.

1.3 Definition of Excavation

For the purpose of this document, the term excavation is defined as any soil excavation work that breaks the existing ground surface and includes excavations deeper than 0.5 m below existing ground surface (but shallower than 9 m below existing ground surface) comprising trenches, test pits and or bored piles, created mechanically or manually.

Given that the water table lies at a depth of > 9 m bgl across Source Area 3, it is considered very unlikely that any excavation works would directly intercept groundwater. Thus, this possibility has not been considered further in this Addendum. In the event that an unusually deep excavation was to extend to this depth, a separate EMP Addendum should be prepared to address the environmental issues associated with this work.

1.4 Objective

This Addendum addresses the requirements of Condition 2 of the SCAR which requires a site EMP to manage risk of vapour intrusion to workers in Source Area 3, as advised to BlueSphere by Renewal SA.


2

The objective of this document is to provide information about the site contamination hazards present in the affected areas and advise on potential management measures and Work Health and Safety (WHS) monitoring requirements relating to risks associated with TCE vapours for civil and construction workers (including maintenance and utility workers) entering excavations within Source Area 3. The Addendum also addresses management of risks for environmental consultants supervising excavation works and visitors to the work site during such activities. Management of all other environmental issues is to be conducted in accordance with the existing EMP (Greencap, 2016).

1.5 Site History

Source Area 3 lies within the portion of the former MMAL site that was labelled as Section 14 in the post-closure environmental investigations conducted by Parsons Brinckerhoff (PB) between 2008 and 2010. No buildings have been constructed on Source Area 3 and it has remained as open space since the MMAL site was developed in the mid-1960s. Between the mid-1960s and the cessation of vehicle manufacturing in 2008, Source Area 3 has been primarily used for outdoor storage of equipment and materials, and as a “graveyard” for storage of obsolete equipment and material. A former timber burning area was also located in the western portion of the area. Two rail spur lines from the adjacent Tonsley line running into the MMAL site also traversed Source Area 3 until their removal following the closure of the car manufacturing facility in 2008.

Since closure of the MMAL facility, Source Area 3 has remained as unused open space, primarily covered in weeds with some remaining asphalt hard-stand in poor condition.

1.6 Summary of Soil Vapour Impacts at Source Area 3

There have been extensive groundwater and soil vapour investigations conducted across Source Area 3 over a period of 12 years. These investigations have established that groundwater beneath Source Area 3, which lies at a depth of greater than 9 m below ground level, is known to be widely impacted by TCE and its breakdown products dichloroethene (DCE) and vinyl chloride (VC) (BlueSphere, 2018a).

Soil vapour investigations have found that TCE is generally present in soil vapour across the majority of Source Area 3, with the highest concentrations reported along the southern boundary fence line (BlueSphere, 2018b) . In this area TCE concentrations in shallow soil vapour (up to 2 m below ground level) approaching 30,000 µg/m3 have been reported. The TCE soil vapour concentrations increase with depth with concentrations of up to 165,000 µg/m3 reported at a 4 m below ground level (BlueSphere, 2018b)

While a number of other chlorinated volatile contaminants such as tetrachloroethene (PCE) and cis-1,2-dichloroethene have been detected in soil vapour within Source Area 3 (BlueSphere, 2018b), TCE is the dominant chlorinated species present in soil vapour and is the overwhelming risk driver with respect to potential human exposure to these vapours. This Addendum to the EMP therefore specifically addresses TCE as the main risk driver for potential human exposures, noting that effective management of the risks associated with TCE exposure will also be effective in managing exposure to other volatile chlorinated species that may be present in soil vapour.

It is noted that no evidence has been found of the presence of petroleum hydrocarbon vapours (such as benzene) in soil vapour within Source Area 3 (BlueSphere, 2018b).

1.7 Nature of the Primary Contaminants of Concern

The primary contaminant of concern on Source Area 3 is TCE and this Addendum to the EMP specifically addresses health risks relating to TCE.

TCE has historically been extensively used as a solvent and degreasing agent. It is moderately soluble in water, persistent and volatile. When present in water at concentrations exceeding the solubility limit of approximately 1,200 mg/L it may be present as a Dense Non-Aqueous Phase Liquid (DNAPL) that will tend to sink to the bottom of the water column.


3

In view of its volatility the most common TCE exposure route for humans is via volatilisation and inhalation. TCE concentrations in the breathing space of site personnel may be particularly prone to spiking when TCE impacted soil or water is freshly exposed during excavation works.

TCE is a potentially explosive gas with a Lower Explosive Limit (LEL) of 12% v/v. As this concentration is more than three orders of magnitude greater than the highest reported soil vapour concentration, it is considered that concentrations of this magnitude are very unlikely to be encountered when conducting excavations in the open air.


4

2 Implementation and Management

2.1 Roles and Responsibilities

The following section describes the role of key parties and nominated personal in relation to future excavations at Source Area 3:

• Principal / landowner (currently Renewal SA): overall responsibility for the implementation of this Addendum to the EMP. Principal role to be taken on by any subsequent purchaser or lessee.

• Environmental Consultant: undertake environmental supervision.

• Primary Contractor: Contractor managing and / or undertaking excavations.

Table 1 Roles and Responsibilities

Role Nominated Personnel Responsibility

Principal – Renewal SA

To be confirmed Overall responsibility for the implementation of this Addendum and the overarching site-wide EMP.

Investigate non-compliances reported in accordance with the requirements of the site-wide EMP.

Direct point of contact to Environmental Consultant for any changes to scope/ stop work authority.

Suitably qualified Environmental Consultant

To be confirmed Undertake environmental supervision and monitoring.

Provide appropriate Health, Safety and Environmental inductions in accordance with this Addendum and the Health, Safety and Environment Plan (HSEP) prepared for the site works.

Manage Addendum compliance and implement corrective actions where required.

Report non compliances of the Addendum to the Principal.

Assist the Principal in investigating reported Addendum non compliances.

Advise Primary Contractor of any scope changes or stop work requirements.

Primary Contractor

To be confirmed on a case by case basis

Supervise the sub-contractor(s) engaged in the removal and appropriate disposal of excavated material in accordance with necessary environmental controls as stipulated in the site wide EMP and under the direction of the Environmental Consultant.


5

Role Nominated Personnel Responsibility

Initiate and implement corrective actions (if required).

Report Addendum non compliances to the Principal and Environmental Consultant in accordance with the requirements of the site-wide EMP.

Assist the Environmental Consultant in investigating reported non compliances.

Visitors Visitors to the site only as approved by the Principal.

All visitors are to be inducted by the Environmental Consultant or the Principal’s

representative to the Addendum and HSEP.

Remain within the designated visitor area unless otherwise accompanied by the Environmental Consultant or Principal Contractor.

2.2 Induction and Awareness

Inductions, inspections and meetings should occur as summarised in Table 2.

Table 2 Schedule of Inductions and Meetings

Item Timing Details

Induction. Prior to works commencing on Day 1.

Administered by Environmental Consultant or Principal to all personnel on site with input from Primary Contractor as required.

Health, Safety and Environment (HSE) Meeting.

Daily before the commencement of each daily works.

If site risks or hazards change.

If site operations warrant further information or training e.g. conditions onsite change.

Administered by Environmental Consultant or Principal to all personnel onsite.

Minutes of the meeting will be taken and signed off by all participants. Agenda to include:

• Review of planned activities;

• Hazards suspected;

• Management measures required;

• Communications; and

• Site personnel responsibilities.


6

Table 2 Schedule of Inductions and Meetings

Item Timing Details

Pre-Start Works Meeting Daily following HSE meeting. Administered by Primary Contractor to all engaged sub-contractors.

Environmental Checks Throughout the scope of works as required

Conducted by Environmental Consultant and Principal on a daily basis or when appropriate.


7

3 Relevant Legislation and Guidelines

3.1 WH&S Legislation, Regulations and Guidelines

The work will be conducted in compliance with applicable WH&S legislation, regulations and standards1, including but not limited to:

• Adopted National Exposure Standards for Atmospheric Contaminants in the Occupational Environment (National Occupational Health and Safety Commission (NOHSC: 1003), (1995);

• Safe Work Australia. Workplace Exposure Standards for Airborne Contaminants (December 2019).

• Work, Health and Safety Act 2012; and

• Work, Health and Safety (Regulations) 2012.

In addition, the works will comply with relevant industry codes of practice, guidelines and other publications that have been developed by WorkSafe South Australia and Safe Work Australia.

3.2 Environmental Legislation, Regulations and Guidelines

The work will be conducted in compliance with applicable environmental legislation, regulations and standards, including but not limited to:

• Environment Protection Act, 1993; • Environment Protection (Air Quality) Policy, 2016; • enHealth (2002). Environmental Health Risk Assessment - Guidelines for assessing human

health risks from environmental hazards (updated 2012); • National Environment Protection (Ambient Air Quality) Measure (1998, as varied 2015); • National Environment Protection (Assessment of Site Contamination) Measure (NEPM) 1999

(as amended 2013); • SA EPA. Guidelines for the Assessment and Remediation of Site Contamination, (Issued July

2018, Updated November 2019); and

3.3 Licences and Permits

All contractors and subcontractors must hold relevant licences or permits to operate relevant machinery and plant.

1 This information is not legal advice and any party using this plan must make their own enquiries and satisfy themselves of the adequacy and regulatory compliance aspects of their proposed works.


8

4 Potential Environmental Impacts – Excavation Works

The potential environmental impacts associated with future excavation works at Source Area 3 are detailed in Table 3 below, noting that this Addendum to the EMP specifically relates to vapour emissions and all other potential environmental impacts are covered in the existing site-wide EMP (Greencap, 2016).

Table 3 Summary of Potential Environmental Impacts

Activity Potential Environmental Impact

Excavation of spoil

Noise emissions.

Vapour emissions.

Dust emissions.

Soil contamination from stockpiled excavated cuttings and stockpiled soils.

Surface water run-off from soil stockpiles.

Handling of contaminated excavation spoil.

Dust emissions.

Vapour emissions.

Soil contamination from stockpiled soils.

Surface water contamination (via runoff into surface water bodies and drains).

Stockpiling and disposal of solid waste.

Dust emissions.

Soil contamination from stockpiled soils.

Vapour emissions.

Groundwater contamination from leaching and infiltration of rainwater accumulating in the base of the excavation.

Surface water contamination (via runoff into surface water bodies and drains).

Sediment runoff into surface water bodies, roads and drains.

On and Off-Site transport of machinery and plant.

Dust emissions.

Noise emissions.

Incidental releases (spillage) of contaminated soil from trucks and other machinery.

Maintenance and refuelling of machinery and plant.

Only minor maintenance works are to be conducted on site.

No refuelling of machinery or plant to occur on site.

Unexpected contamination.

Soil contamination.

Groundwater contamination.

Surface water contamination.


9

Table 3 Summary of Potential Environmental Impacts

Activity Potential Environmental Impact

Excavation works compromising integrity of excavation.

Soil contamination from leaching of infiltrating rainwater if excavation base/ sides uncontained.

Groundwater contamination from leaching of liquid if excavation base/ sides uncontained.


10

5 Managing Vapour Risks to Construction and

Maintenance Workers

Environmental management requires procedures to ensure that all personnel involved in the project are aware of potential risks to the environment and human health from the proposed works, and implementation of measures to control these risks.

This Addendum to the EMP specifically relates to the management of TCE vapour emissions within excavations in Source Area 3. For management of all other environmental impacts (such as dust emissions, noise emissions, soil contamination etc), reference should be made to the existing site wide EMP (Greencap, 2016) or any future updates.

5.1 Vapour Emissions

5.1.1 Issues

The following issues associated with vapour emissions from excavations have been identified:

• Unacceptable risks to human health (primarily site workers) from inhalation of hazardous vapours when entering excavations at Source Area 3;

• Possible asphyxiant conditions within excavations;

• Possible explosive atmosphere conditions within excavations; and

• Unpleasant odours,

5.1.2 Objectives

The objective of managing vapour emissions is to:

• Minimise risks to construction and maintenance workers from inhalation of hazardous vapours within excavations;

• Minimise risk of explosive or asphyxiant conditions within excavations during works; and

• Minimise impacts to nearby residents/ site users.

5.1.3 Performance Standards

The following performance standards are associated with managing vapour emissions:

• No adverse health effects to site workers entering excavations or visitors to Source Area 3;

• Works undertaken safely with no incidents associated with vapours; and

• Minimal impact on nearby residents/ site users.

5.1.4 Vapour Management Protocol

Workers entering and operating within excavations within Source Area 3 may potentially be exposed to unacceptable risks via inhalation of vapours (primarily TCE) that may enter and accumulate within the excavation. It is assumed that workers may be operating in a manner that their breathing space lies predominantly within the excavation, and that individual workers may potentially be operating within an excavation for the majority of an 8-hour working day.

Table 4 sets out TCE concentration trigger levels for the use of respirators by personnel entering excavations at Source Area 3, and criteria for the suspension of work due to TCE concentrations within the breathing space. These criteria are based upon the eight-hour time weighted average (TWA) for TCE of 10 ppm and the 15 minute short term exposure limit (STEL) for TCE of 40 ppm published by Safe Work Australia in Workplace exposure standards for Airborne Contaminants (December 2019). .

The details of the vapour management protocols are set out in Table 4.


11

Table 4 Vapour Management Protocols

Actions Responsibility Timing

All site staff will be inducted prior to excavation works commencing and made aware of, health and safety issues, environmentally sensitive areas and environmental responsibilities. Staff will be provided with a copy of the site-wide EMP and this Addendum.

Environmental Consultant or Principal

Prior to excavation works commencing

Appropriate safety programs will be implemented including identification of the route to the nearest hospital accident and emergency facility, evacuation procedures and first aid provision.

Contractors Prior to excavation works commencing

Site workers will adopt appropriate health and safety procedures in accordance with relevant guidance, Australian Standards and legislation to minimise exposure to vapours including.

• Preparation of a site specific safe work method statement.

• Wearing appropriate PPE (including chemical resistant safety glasses, hard hats, solvent resistant steel toe capped boots, overalls (Tyvex if required), high visibility safety vests and nitrile gloves). Appropriate respirators should also be available in case they are required.

• Creation of an exclusion zone around the excavation and the restriction of entry to the exclusion area to authorised personnel wearing PPE only.

• No smoking allowed on Site.

• PPE should be removed and hands washed prior to eating, drinking or smoking.

Environmental Consultant

Contractors

Prior to excavation works commencing

The following procedure should be followed as a minimum prior to and during the removal of material from an excavation:

• A background reading for volatile compounds should be established prior to commencing excavation. This should be done using a calibrated sensitive photo-ionisation detector (PID) such as a ProCheck 5000 or equivalent that can obtain readings down to 1 ppb.

• Once a background reading has been established, excavation can commence.

• Personnel breathing zones within the excavation will be monitored whilst excavation is conducted.

• If PID readings in the excavation are sustained at more than 2 ppm above the background (20% of the 8 hour TWA), workers should be


Contractors

Pre and during excavation and stockpiling, loading truck


12

Table 4 Vapour Management Protocols

Actions Responsibility Timing

immediately notified and workers should wear a half face respirator fitted with an organic vapour cartridge complying with AS 1716:2003/Amdt1:2005. Workers should be appropriately trained in the use of the respirator.

• If PID readings in the breathing zone reach the 15 minutes STEL level of 40 ppm, work should be suspended immediately until PID readings reduce to <20 ppm when work can be recommenced with workers wearing an appropriate respirator

• If PID readings do not sustain 2ppm above the background readings, work can continue with ongoing monitoring.

• Following the excavation process, a final walkover should be conducted with vapours measured using the PID to confirm respirators are not required in the work area, particularly in the vicinity of the stockpiled material and excavation. The vapours at the boundary of the site will also be monitored.

• In the event that measured vapour concentrations at the site boundary are greater than 2 times the background concentration, and a noticeable odour is reported, the excavation and any stockpiles should be covered to reduce fugitive vapour emissions.

• All measurements and resulting management measures taken should be recorded so that they can be incorporated into a summary report.

Monitoring and Reporting

A summary report detailing the works conducted and PID measurements will be prepared after the completion of the field work and subsequent offsite disposal of any contaminated material. The report will include:

• A plan providing the location of the excavation.

• Details of the background PID measurements along with the measurements taken in conjunction with the excavation work.

• Details of any exceedances of the criteria recorded and any additional management/ mitigation measures implemented in response to these exceedances.


Post waste disposal


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6 Limitations

This report was prepared for the sole use of Renewal SA, the Crown in right of the State of South Australia and any site contamination auditor appointed to undertake a site contamination audit and should not be relied upon by any other person. None of BlueSphere Environmental Pty Ltd or any of its related entities, employees or directors (each a BlueSphere Person) owes a duty of care (whether in contract, tort, statute or otherwise) to any third party with respect to or in connection with this report and no BlueSphere Person accepts any liability for any loss or damage suffered or costs incurred arising out of or in connection with the use this report by any third party.

The report has been prepared with the objectives and scope of work outlined in the email proposal dated 1 April 2020. The work was carried out in accordance with the Panel Deed executed 29 September 2019.

The conclusions and recommendations provided in this report are based on available information and it is possible that different conclusions and recommendations could be made should new information become available, or with changing site conditions over time. These opinions, conclusions and recommendations are subject to uncertainty given the potentially complex nature of any subsurface environment. Variation in soil and groundwater conditions may vary significantly between the specific sampling and testing locations and other locations at the site.

The report will not be updated if anything occurs after the date of this report and BlueSphere Environmental Pty Ltd will not be obliged to inform any person of any matter arising or coming to its attention after that date.


14

References

BlueSphere, 2018a. Conceptual Site Model (CSM): Tonsley VSCAP Investigation – Revision 04, Tonsley Development, Former MMAL Site, Tonsley, SA, BlueSphere, 26 September 2018.

BlueSphere, 2018b. Section 17: Plating Shop Source Delineation Investigation Report. Tonsley Innovation District, Former MMAL Site, Tonsley SA. BlueSphere Environmental. 10 September 2018.

Greencap, 2016. Environmental Management Plan, Renewal SA, Tonsley Redevelopment Project, prepared by Greencap, dated 12 August 2016.


Figures

Figure F1 Site Location Plan

LLOYD STREETSHEPHERDS HILL ROAD

LYNTON AVENUE

KIRRA AVENUE

BAHLOOAVENUE

WINDSORAVENUE

SUTTON ROAD

MIMOSA TERRACE

MITSUBISHI

ACCESS

BROOKMANAVENUE

BRADLEY GROVE

QUINLAN AVENUE

EDISON ROAD

BURBANK AVENUE

HARKINCOURT

WATTSROADMAPLEAVENUE

MILLTERRACE

BIRCH CRESCENT

KELVIN ROAD

DEEPDENEAVENUE

ASH AVENUE

OAK AVENUE

LETCHFORD

STREET

PENRITH COURT

LANARK AVENUE

HANDLEYAVENUE

MILLS STREET

MAIDSTONEROAD

LINCOLN ROAD

MAIN SOUTH ROAD

TIMOTHY COURT

AYLIFFES ROAD

BRAYDENCOURT

MAB CIRCUIT

DRURY TERRACE

YORK AVENUE

TOBRUK AVENUE

SOUTH ROAD

PAUL STREETBYRON AVENUE

THE CRESCENTALAWOONA AVENUE

WOODLAND ROAD

SELGAR AVENUE

MYRTLE GROVE

F1Fig urePROJECT ID

DATE50130.178/04/2020

CREATED BY SK

SITE LOCATION PLAN

Addendum to EMP, Tonsley Innovation District – EPA Desig nated Source Area 3

Tonsley Innovation District,South AustraliaRenewal SA

Disclaimer: BlueSphere Environmental Pty Ltd. (BlueSphere) does not warrant the accuracy or completeness of information displayed in this map and any person using it does so at their own risk. BlueSphere shall bear no responsibility or liability for any errors, faults, defects or omissions in the information.G:\BlueSphere\Projects\50130_Tonsley_Source_Investigation\17\50130_17_F01_SiteLocation.mxd

Site Location

Leg endEPA Designated Source Area 3Tonsley Innovation District Boundary

0 50 100

Metres

1:4,000 when printed at A3 GDA 1994 MGA Zone 54

Imagery: Nearmap 09/05/2017

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