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SITE CONTAMINATION AUDIT SYSTEM SITE CONTAMINATION AUDIT STATEMENT

INSTRUCTIONS

Requirements relating to site contamination audit statements are prescribed in the Environment

Protection Regulations 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 a summary 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 out in Schedule 3 clause 8.

(2) A site contamination audit statement required under section 103Z(4)(b)(ii) of the Act in

relation to a site contamination audit must comprise—

(a) a copy of the summary in the site contamination audit report relating to the audit and

itself be certified by the responsible auditor in accordance with the directions contained in

the form set out in Schedule 3 clause 8; or

(b) a photocopy, faxed copy or electronic copy of the summary as certified by the responsible

auditor in 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 which the audit relates is situated and any prescribed body2.

Penalty: Division 5 fine.

Refer to the most recent version of the EPA publication Site contamination: Guidelines for the site

contamination audit system, for further information regarding audit reports and audit statements.

Please ensure that all sections of the form are completed, requested information and attachments

(where necessary) are provided and labelled as indicated. Please do not modify the form and do not

write within the areas for EPA USE ONLY.

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

Manager, Site Contamination Branch Environment Protection Authority GPO Box 2607 Adelaide SA 5001

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

Telephone: (08) 8204 2004 Email: <[email protected]>

1 Environment Protection Act 1993.

2 Refer to Regulation 68 of the Environment Protection Regulations 2009 regarding prescribed bodies.

mailto:[email protected]

Site contamination audit statement

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 site contamination audit report titled:

Site Contamination Audit Report (Amended), St Clair Recreation Reserve, Woodville Road (Allotment 1, Plan D84492), Woodville, SA 5011 Report (referred to in this form as ‘the report’)

dated: 28 March 2012

SECTION A: AUDITOR DETAILS

Name of auditor*: Warren Pump

Auditor’s accreditation number: 2009027

Name of auditor’s company or business: ERM Australia Pty Ltd

SECTION B: AUDIT SITE DETAILS

Auditor’s project reference: 0128973

EPA reference: 60486, 05/18938

Name of audit site [if applicable]: St Clair Recreation Reserve

Address of audit site: Actil Avenue and Woodville Road, Woodville, SA

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

City of Charles Sturt

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

** If insufficient space, details may be annexed to this form.

- certificates of title of all the relevant land and an indication of whether the audit site comprises all or part only of the land shown on or described in the certificates of title

CT Volume 6063 Folio 756

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

Allotment 1, Deposited Plan D84492 in the Area named Woodville, Hundred of Yatala.

Site AMG coordinates are 274962.38 E, 6138014.43 N.


3

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

- audit plans indicating the location and extent of the audit site (which must comply with the guidelines issued by the EPA from time to time) See attached Figure 1

SECTION C: AUDIT DETAILS

Name of owner of audit site: Land Management Corporation

Name of occupier of audit site: Vacant

Name, postal address and position of person who commissioned audit:

Land Management Corporation

GPO Box 698, Adelaide, South Australia 5001

Indicate authority of person who commissioned audit:

EPA Yes No

Owner Yes No

Occupier Yes No

Developer Yes No

Other [please specify]

Indicate reasons for audit [indicate all reasons]:

Required under the Development Act 1993

Yes No

Required under the Environment Protection Act 1993

Yes No

Other [please specify] To support a development application for a change in land use

If audit was required under the Environment Protection Act 1993, provide EPA reference number:

Not applicable

Indicate audit purposes [indicate all purposes]:

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

Yes No

Determining the suitability of the site for a sensitive use or another use or range of uses

Yes No

Determining what remediation is or remains necessary for a specified use or range of uses

Yes No

[NB: an audit may be required for all of the above purposes.]


4

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

Name of relevant planning authority:

Development application number [if known]:

Site zoning:

Proposed site use:

Date of commencement of audit: 16 February 2011

Date of notification of commencement of audit to EPA:

1 March 2011

Date of completion of audit: 28 March 2012

SUMMARY OF FINDINGS

A summary of the findings of the site contamination audit are presented below:

Auditor Determinations

The Auditor determinations are set out as follows:

The Phase 2 Environmental Site Assessment undertaken by AEC Environmental Pty Ltd (AEC) is

considered by the Auditor to be adequate to determine the contamination status of the Site.

The overall sampling frequency (i.e. test locations and selection of samples) is considered by the

Auditor to be acceptable to characterise the site. The analytical parameters are considered by the

Auditor to be sufficient to adequately characterise the site.

The quality assurance / quality control methodology and procedures employed by AEC are

considered by the Auditor to be acceptable for the purposes of this audit and provide adequate

confidence that laboratory data were representative of the conditions at the site.

The Auditor concludes that concentrations of chemical substances remaining in natural soils at the

site do not pose unacceptable human health risks, for the proposed mixed land use development.

The Auditor concludes that concentrations of chemical substances in natural soils on this site (other

than manganese) are such that ecological risks are low and acceptable for plants that have their

root systems in, or uptake nutrients from, site soils, and that site soils generally do not pose

unacceptable risks to ecological receptors. However, due to potential phytotoxicity issues arising

from elevated concentrations of naturally occurring manganese within soils, the Auditor

recommends the selection of native plants which are expected to be manganese tolerant.

Based on descriptions provided by the Site Assessor in the report AEC (2011), “Soil Leachability

Assessment’, the Auditor is of the opinion that there are no unacceptable aesthetic issues

associated with natural soils at the site.

The Auditor considers that there are no unacceptable asbestos issues associated with soils at the

site.

Although the soil samples were not specifically tested for sulphate or chloride, the Auditor has no

reason to suspect these are elevated. The Auditor therefore considers that the potential for impact

by these substances on buildings and structures in direct contact with soil is low and acceptable.

The Auditor considers that the audit site has not been a source of contamination to groundwater

beneath the Site. Groundwater was not intrusively assessed as part of either site investigation, but


concentrations of all constituents of concern were below adopted screening criteria in all natural

soils across the site.

Based on an audit report conducted on the neighbouring site located to the west on Actil Avenue

(GHD 2009), TDS concentrations in groundwater in the local area are expected to range between

760 - 6500 mg/L, with depth to groundwater in the region of 5.1 to 6.2 metres below top of casing

and the expected regional groundwater flow to be in a westerly direction. Additionally, the GHD

(2009) report indicated that groundwater quality to the west of the current audit site limits future

use of groundwater. The Auditor is of the opinion that:

other use of groundwater down-gradient of the current site for any purpose is unlikely; and

groundwater on the neighbouring site located to the west on Actil Avenue does not impact, and

is not likely to impact, any beneficial use of groundwater beneath the audited site.

Based on elevated concentrations of benzo(a)pyrene and total polycyclic aromatic hydrocarbons

above adopted health screening levels for standard residential land use in fill material located

broadly across the site, appropriate management measures need to be considered if the fill is to be

remain on the site (see details below).

Audit Outcomes

The nature and extent of any site contamination present or remaining on or below the surface of the site

The Auditor concludes that site contamination exists at the site.

The Auditor concludes that the nature and the horizontal and vertical extent of contamination on the audit Site has been determined.

Based on the proposed residential land use, the concentration of benzo (a) pyrene present in the fill material across the site (as discussed in Section 13.2 of the Audit Report), and some elevated concentrations of naturally occurring manganese within soil, site contamination of soil exists at the Site.

Fill material across the Site has been identified to be contaminated with benzo(a)pyrene and above adopted NEPM ‘A’ HIL assessment criteria. It was noted that contaminants of potential concern in natural Site soil are within adopted NEPM ‘A’ HIL assessment criteria.

Based on the data presented by other audit reports existing to the west and northwest of the Site boundary, the Auditor has concluded that contamination of groundwater is not considered to exist at the Site.

Due to regional salinity, and identified contamination of down-gradient groundwater associated with former industrial neighbours to the Site (GHD 2009), use of groundwater down-gradient of the Site is considered unlikely.

The suitability of the site for specified use

The Auditor concludes that in its current form, and in the absence of ongoing management measures, the audit Site is not suitable for sensitive uses such as the proposed medium to high density residential.

Based on the EPA Guidelines for the Site Contamination Audit System (2010), the following option is applicable to the Site to facilitate the uses mentioned above:

with conditions on the use of land to manage chemical substances at the audit site to ensure its

suitability for the proposed specified uses.

The Auditor concludes that in its current form, the portion of the audit Site proposed for park land as depicted on the concept plan by Land Management Corporation, “Woodville Village Masterplan”, (attached to this Statement) is suitable for recreation and open space use.


What remediation is or remains necessary for a specified use or range of uses

Contamination of soil exists at the site and ongoing management of the contamination remains necessary for the proposed residential use.

Furthermore, the Auditor recommends the selection of manganese tolerant vegetation to mitigate the potential phytotoxicity issues arising from elevated concentrations of naturally occurring manganese within soil.

Other than the site management measures described above, the Auditor considers that no additional site remediation work is warranted.

Audit Conditions and Recommendations

The following conditions and recommendations are made:

Planning and Development:

The Auditor is of the opinion that no conditions are required relating to planning and development.

Environmental Monitoring

The Auditor is of the opinion that no conditions are required relating to environmental monitoring.

Site Management

The Auditor considers that the following ongoing management measures must be instituted to manage

contaminated soil at the site:

1. The site must be covered with a physical barrier, so that the contaminated soil is capped

beneath at least 0.5 m of certified clean fill, or be covered by an impermeable barrier (for

example, concrete building slab, or hard paved landscaping), or be used as engineered fill

beneath hardstand areas;

2. Any landscaped area or garden bed must have at least 0.5m thickness of clean fill below the

finished surface, which is demonstrated to be suitable for the site and consistent with soil

classified as “waste fill” as defined in the EPA Publication: “Standard for the production and use

of Waste Derived Fill”; and

3. All physical barriers (as described above), if subsequently damaged or removed during

development or occupation of the site, must be reinstated as soon as possible and to the same

condition or better as they were prior to any disturbance.

Water Restrictions

The Auditor is of the opinion that no conditions are required relating to water restrictions.

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.

igned*: Warren Pump

Site Contamination Auditor accredited under Division 4 of Part 10A of the Environment Protection Act, 1993

Dated: 29 March 2012


* 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.

SOUTH AUSTRALIA

SITESITE

±0

5025

Metres

1:2,000

Figure 1. - Site Audit Boundary

Date: 08/02/2012

Drawing No:

Drawing size: A4

Land Management CorporationClient:

JC VLReviewed by:Drawn by:

St Clair Recreation Reserve Audit

This figure may be based on third party data or data which has not been verified by ERM and it may not be to scale. Unless expressly agreed otherwise, this figure is intended as a guide only and ERM does not warrant its accuracy.

Notes: Text here

25 50m0

Site Boundary

Legend

N

0128973m_C001_R0.cdr

Environmental Resources Management Australia Pty Ltd

Auckland, Adelaide, Brisbane, Canberra, Hunter Valley, Melbourne, Perth, Port Macquarie, Sydney

Source: Text here

Figure No. 2 - Proposed Development Plan

Date: 29/03/2012

Drawing No:

Drawing size: A4

Land Management CorporationClient:

CB WPReviewed by:Drawn by:

St. Clair Recreational Reserve Site Contamination Audit Report

This figure may be based on third party data or data which has not been verified by ERM and it may not be to scale. Unless expressly agreed otherwise, this figure is intended as a guide only and ERM does not warrant its accuracy.

Notes: Text here

10 20 30m0

Type text here

Type text here

Type text heresecond line example

Type text here

Legend

N

0128973m_C002_R0.cdr

Environmental Resources Management Australia Pty Ltd

Auckland, Adelaide, Brisbane, Canberra, Hunter Valley, Melbourne, Perth, Port Macquarie, Sydney

Source: Text here

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