BEFORE THE ENVIRONMENT COURT I MUA I TE KOOTI TAIAO O AOTEAROA ENV-2018-AKL-000078 IN THE MATTER of the Resource Management Act 1991 (RMA) AND IN THE MATTER of the direct referral of applications for resource consent for the necessary infrastructure and related activities associated with holding the America's Cup in Auckland BETWEEN PANUKU DEVELOPMENT AUCKLAND Applicant AND AUCKLAND COUNCIL Regulatory Authority EVIDENCE OF PHILLIP JOHN WARE ON BEHALF OF PANUKU DEVELOPMENT AUCKLAND (CONTAMINATED LAND AND GROUNDWATER) 7 AUGUST 2018 0827
Microsoft Word - 30973545_1.docxBEFORE THE ENVIRONMENT COURT I MUA
I TE KOOTI TAIAO O AOTEAROA
ENV-2018-AKL-000078
Act 1991 (RMA)
applications for resource
Auckland
Regulatory Authority
EVIDENCE OF PHILLIP JOHN WARE ON BEHALF OF PANUKU DEVELOPMENT
AUCKLAND
(CONTAMINATED LAND AND GROUNDWATER) 7 AUGUST 2018
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My full name is Phillip John Ware.
I am a Technical Director at Beca Ltd, and provide a lead technical
verification role in
contaminated land and environmental projects across
Australasia.
I hold a Bachelor of Science (Honours) with a double major in
Geology and Geography
from the University of Otago. I am a Certified Environmental
Practitioner and accredited
Contaminated Site Specialist (CEnvP, CS Specialist). I am a member
of the
Environmental Institute of Australia and New Zealand and a member
of the Australasian
Land and Groundwater Association. I operate as a Suitably Qualified
and Experienced
Practitioner (SQEP) as required under the Resource Management
(National
Environmental Standard for Assessing and Managing Contaminants in
Soil to Protect
Human Health) Regulations 2011.
I have seventeen years’ experience working as an environmental
consultant. Through
the majority of my environmental science career in New Zealand,
Australia, the United
Kingdom and Europe, I have specialised in hydrogeology and
contaminated land
investigation, focusing on assessment and management. My work has
included
undertaking site contamination assessments for a variety of large
and small projects
across a range of industries. I have authored and reviewed more
than 200 soil
contamination investigation reports both in New Zealand and
overseas. I am familiar
with the regulatory requirements in relation to contaminated land
in New Zealand,
including the assessment of risk to people and the environment and
the provision of
appropriate mitigation measures. I have a significant amount of
experience dealing with
the particular contaminants of concern involved in the project,
namely gasworks wastes
and petroleum hydrocarbons, from leading large-scale investigation
and remedial
projects in the United Kingdom and Europe.
During my degree studies I specialised in Hydrogeology and I have
undertaken
investigations into groundwater quantity, level, and quality
impacts throughout my career.
I have undertaken additional post graduate courses in groundwater
modelling (in Delft
the Netherlands) and contaminant transport in the United
Kingdom.
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I have been the lead contamination specialist on large road
projects such as the Puhoi
to Wellsford Road of National Significance: Puhoi to Warkworth
Section, the MacKays to
Peka Peka Expressway, Peka Peka to taki Expressway, and Penlink
Whangaparaoa
Peninsula Connection. I have led Contaminated Land services for
land development
projects such as the 650 lot Pacific Heights Development in Orewa
including mitigation
of the West Hoe Heights Landfill. I am currently providing
specialist advice to several
New Zealand and Australian Airports together with both the New
Zealand and Australian
Defence Departments on the contamination issues related to per and
poly-fluroalkyl
substances associated with use in firefighting foams.
I have undertaken a large range of environmental management roles
on numerous
significant earthworks projects. I am currently developing and
implementing dust and air
quality management for projects such as the Wynyard Quarter Road
upgrades and
Erosion and Sediment Control for Pacific Heights 650 lot
subdivision in Orewa.
I advise that I have read the Code of Conduct for Expert Witnesses
contained in the
Environment Court Practice Note 2014 and have complied with it in
preparing this
evidence. I confirm that the issues addressed in this evidence are
within my area of
expertise and I have not omitted material facts known to me that
might alter or detract
from my evidence.
2. BACKGROUND
I have been asked to provide evidence in relation to contaminated
land and groundwater
effects arising from construction and earthworks activities
required to build the bases on
land and infrastructure together with the human health mitigation
for the future use of the
facilities on land.
I have been engaged by Panuku Development Auckland (Panuku) since
2014 as their
lead advisor on contaminated land issues to facilitate the ongoing
developments within
the Wynyard Quarter. This role initially included drawing together
of all available and
relevant groundwater and contamination information obtained over
the last 20+ years,
progressing to additional investigations of both soil contamination
and groundwater. In
2015, I then led the production of Investigation Reports on the
Wynyard Central area and the surrounding road network. An
‘overview’ Remediation Action Plan (RAP) was then
produced which has formed the basis of all subsequent contamination
responses. I have
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been involved in the assessment of groundwater level impact across
Wynyard and the
modelling of effects.
3. SCOPE OF EVIDENCE
For the Americas Cup 36 project I have been engaged by Panuku to
prepare a Preliminary Site Investigation Report (PSI) (CBD Vol A,
CB32, page 1917) for the
disturbance of soils on land, and an initial RAP.
The initial RAP submitted as part of the application will form the
basis of subsequent
updates to be undertaken by the Wynyard Edge Alliance. At the time
of preparing this
evidence I note that a Draft Version of the first update has been
prepared by Mr Chris
Bailey (of Tonkin and Taylor) on behalf of the Wynyard Edge
Alliance. A copy of the updated RAP is attached to my evidence as
Attachment A. I have reviewed this
document and can confirm that it is consistent with the initial RAP
while providing
additional procedures and mitigation measures for the placement of
dredged materials,
asbestos controls, and general handling. The Wynyard Edge Alliance
RAP will continue
to evolve as additional data is obtained.
Evidence prepared by Mr Paul Kennedy covers the quality of sediment
in Freemans Bay
and Viaduct Basin. Mr Kennedy’s evidence also provides an
assessment of effects due
to disturbance of sediments within the Coastal Marine Area, and
Marine environments.
My evidence and the mitigation measures within the initial RAP and
the Wynyard Edge
Alliance update to the RAP uses the sediment quality data obtained
by Mr Kennedy’s
investigations.
Evidence prepared by Mr Stephen Priestley provides a description of
the main
engineering activities and processes including a description of the
dredging and
mudcrete process to stabilise sediments prior to the beneficial use
as fill on the landside
bases. I have not described this process again in my evidence. Mr
Priestley also covers
aspects of construction works, mitigation and stormwater control
which I have not re
addressed.
The provision of detailed construction management plans to address
standard good
practice construction procedures in the form of a construction
management plan, a
construction environmental management plan, an erosion and sediment
control plan and
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an emergency spill response plan, are recommended in the proposed
conditions of
consent.
a) Contaminated Land
iv. Remediation Action Plan
ii. Summary of Proposed Activities with potential for Impact
on
Groundwater
iv. Proposed Groundwater Monitoring
d) Comments on submissions;
f) Conclusions
ii. Groundwater
I have been involved in expert conferencing with Auckland Council’s
(the Council) experts in the areas of ground water, contaminated
land and earthworks, and air
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discharge. We prepared a Joint Witness Statement dated 1 August
2018, which
confirmed there are no areas of disagreement between myself and the
Council experts.
4. SUMMARY OF EVIDENCE
Contaminated Land
4.1 The sites proposed for the land bases and the area of Brigham
St that will be disturbed
as part of the project are known to be significantly contaminated
with a range of
contaminants. The mix and distribution of contamination is the
subject of further ongoing
detailed investigations, however the likely type and distribution
of contamination both in
groundwater and soil can be anticipated with a high degree of
certainty based on
available data and past experience in the wider area.
4.2 The depth of soil disturbance is mostly restricted to the top
1m of materials and therefore
the types of effects that need to be considered are significantly
reduced compared to a
deep basement excavation.
4.3 The approach to the mitigation of contamination effects adopted
has been successfully
used on other projects within Wynyard Quarter and if implemented
appropriately here
the construction-related effects arising from contamination
(including dust, odour, human
health, and environmental) should be no more than minor and
acceptable.
Groundwater
4.4 There is limited groundwater flow, and/or continuity between
the groundwater below the
site areas and surrounding areas. The majority of works will not
interact with
groundwater.
4.5 The only works with the potential to impact groundwater are the
proposed soil
stabilisation works along Brigham Street which go into and below
the groundwater table.
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4.6 I consider the potential for groundwater level changes to be
very minor and, if present,
isolated to close to the stabilised structures. These effects are
unlikely but should
nevertheless be monitored as provided in consent conditions.
5. RELEVANT FACTS AND CONTEXT
In this statement of evidence I do not repeat the project
description and refer to the
summary of the application in the evidence of Mr Rod Marler
(Panuku). I also do not
repeat the construction description provided by Mr Priestley.
The investigation of both contaminated land and groundwater is
ongoing. Data relating
to groundwater levels, contaminate concentrations in soils,
sediment, and groundwater
will continue to be obtained by the Wynyard Edge Alliance up to,
including, and post
construction. The initial RAP submitted with the application is
intended to be a living
document and additional controls will be required. It is intended
that a condition of
consent will require all amendments to be approved by Council
Specialists.
5.3 This evidence highlights the key points from the following
technical reports, which formed
part of the Assessment of Effects on the Environment (AEE). I
confirm the content and
accuracy of these earlier reports.
a) America’s Cup, Wynyard Hobson: Preliminary Site Investigation
(Contaminated
Land) Technical Report (With supporting Appendix Initial
Remediation Action
Plan) (CBD Vol A, CB32); and
b) America’s Cup, Wynyard Hobson: Groundwater Technical Report (CBD
Vol A,
CB31).
6. CONTAMINATED LAND
Contamination Present Onsite
The land use history of the Wynyard Point Area under investigation
has been bulk fuel
storage, food product storage, and chemical storage since the early
1900s (with part of
the site still used for these activities today).
A detailed list of previous site users, the areas they occupied and
a description of their
activities is provided within the PSI. The major site users
include: BP Oil Ltd, Marstel (a
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chemical storage company), a Zinc Recovery Plant and Plaster
Company, Bulk Storage
Terminals (BST), Caltex Oil, Castrol Oil Ltd, Stolthaven Ltd,
Southern Spars, ASB use
as a carpark, and various small storage uses.
The land was reclaimed from the harbour in the early 1900s using a
combination of
dredged harbour sediments and imported fill material. The nature of
the fill material is
highly variable across both the subject site area and the wider
Wynyard reclamation.
The majority of waste materials found both within investigations on
the subject site and
within the wider area occur in the upper 2m of the soil profile.
The waste materials can
contain by-products from the historical Victoria Park
Gasworks.
Petroleum hydrocarbons, gasworks waste, and, to a lesser extent,
inorganic compounds
(copper, cyanide, and lead) are prevalent within soils and
groundwater of the subject site
and the wider area.
Contamination by hydrocarbons has been identified widely across the
site, with measurable thicknesses of Separate Phase Hydrocarbons
(SPH) historically present in
approximately 50% of the development areas. The identified SPH was
in most locations
restricted to less than 50mm in historical studies. Hydrocarbons
degrade and disperse
over time and it is my view that a significantly smaller proportion
of the site will still exhibit
SPHs.
With the exception of dissolved cyanide, elevated concentrations of
inorganic
compounds are generally localised and are not observed consistently
either spatially or
vertically across the site.
Based on the information obtained through the PSI, including review
of historical
investigations, and knowledge of the wider Wynyard area where there
is a similar
contamination history, the following conclusions and development
assumptions can be
drawn:
a) Soils and groundwater within the development area proposed at
Wynyard Point
have been subject to contamination from hydrocarbons, oil spills,
gas works
waste, heavy metals and other chemical storage.
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b) The concentrations of contaminants are such that where the soils
are disturbed
management controls are required to mitigate human health and
environmental
risks.
c) Separate phase hydrocarbons may be present and, until further
investigations
provide evidence to the contrary, measures to mitigate effects of
disturbing SPH
will be required.
d) The potential for vapours to be generated from contamination
within the soils or
groundwater at such levels where they could generate a risk to the
human
health of occupants of the proposed base building is low based on
existing
testing data. The data however cannot rule out a potential effect
to an
unprotected building in some areas. The initial RAP therefore
includes
measures to mitigate effects of vapour intrusion into buildings.
These measures
will require further design based on detailed site data.
e) A number of well-established and proven vapour mitigation design
solutions are
available to mitigate low to moderate levels of hydrocarbon vapours
and include;
vapour barriers made of HDPE for an at grade building, passive
venting layers
that allow vapour under a building to be directed to the sides and
sometimes
the roof line, and active venting which incorporates automatically
controlled
pumps to achieve ventilation when required.
f) It is possible that further testing of contaminant
concentrations across the site
will enable the delineation of areas which do not present a vapour
risk. Should
this occur, evidence will be presented within a revised RAP for
Council approval.
Current proposed conditions require the identification of vapour
protection
measures within the revised RAP; I consider this an appropriate
mitigation
measure.
Imported Materials
It is intended to increase the site level across the area proposed
for land-based bases
(excluding the roads). The thickness is expected to vary but an
allowance is made for
approximately 0.5m. Some of the material proposed to facilitate
this increase may come
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from material that will be dredged from Wynyard Basin to facilitate
the desired water
depth for navigation and berthing.
At the time of preparing this evidence, the design did not call for
the reuse of stabilised
dredged material, however allowance to use such material is still
considered within this
evidence. If reuse of dredged materials is not required, this will
further reduce any effects
of the proposal.
The sediments proposed for dredging have been tested for
contaminant levels and the
results show a degree of spatial variability. With the exception of
one asbestos sample,
no results showed concentrations of contaminants over the relevant
human health or
environmental criteria. Concentrations above background
concentrations do exist in
some of the sediments and for selected contaminants.
The contaminants present within the harbour sediments are likely
the result of discharge
of stormwater to the marine environment over time. It has become
apparent through
increased sampling that low concentrations of dispersed asbestos
fibres at close to the
Western Australian Guidelines Screening Level (as the adopted
criteria for New Zealand)
is present throughout sediments within the Auckland Waterfront. The
general presence
of asbestos in these low concentrations is now being shown to be
ubiquitous.
Management of low levels of asbestos within mudcrete sediments was
encountered
within the Park Hyatt development and managed successfully. I
consider that low levels
of asbestos and other contaminants can be managed adequately within
a RAP.
The contaminant loading of the imported sediments is significantly
lower than that of the
current site material. Although the mass of contaminants will
increase slightly on the
site, the concentration of contaminants in surface materials is
likely to reduce.
It has been proposed that, prior to use onsite, the sediments are
mudcreted: a process
that mixes them with cement and effectively turns them into a
concrete like material. This
process reduces the permeability of the mass to a highly
impermeable state and reduces
the leachability of contaminants from original sediments.
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Assessment of Contaminated Land Effects
A Conceptual Site Model (CSM) was developed to inform the
investigation and to
describe the relationship between sources of contamination on site,
the human and
environmental receptors that may be exposed to those contaminants
during construction
and in the context of temporary commercial and/or industrial use of
the site, and the
pathways by which those receptors may be exposed.
The proposed activities that have potential to give rise to human
health or environmental
effects as a result of contamination present currently onsite or
from the low level residual
contamination present within imported dredged materials are
summarised in table 1
below. An in-depth CSM is provided within the PSI (CBD Vol A, CB32,
page 1978).
When handling, processing and spreading dredged sediments
(including those
sediments that have been mixed with cement to form ‘mudcrete’) the
primary pathways
of concern are creation of dust including the potential
mobilisation of asbestos fibres.
The use of harbour sediments, as either reclamation materials or
fill material, within the
Auckland waterfront has occurred almost continually from the
initial phases of
reclamation before 1900. Over time, the methods of dredging,
material preparation, and
subsequent placement have changed with the introduction of the
mudcrete stabilisation
process in 1993. Mudcrete derived from shallow harbour sediments
was used for the
creation of the land areas for Fishermans Wharf (10,000 m3), the
2000 Americas Cup
(150,000 m3), and Fergusson Terminal reclamation (1,000,000 m3). I
consider this
method to be a known proven practice with highly predictable
outcomes and manageable
effects.
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The following table describes the potential effect that could arise
from the proposed
construction processes:
Activity Potential Effect Pathway / Receptor
Handling, processing and spreading
dredged sediments including those
cement to form ‘mudcrete’:
contaminants in the sediments (albeit in
low concentrations)
initial set of earthworks on site including
a site strip.
ingestion, and inhalation.
earthworks are occurring on land based
sites and roadways.
pick up dissolved contaminants and
sediments from both site soils and
imported materials and convey these
contaminants via stormwater drains to
the marine environment.
historical services from the petroleum
industry.
tanks, or soil containing hydrocarbons
which may need removal and can
produce odours once uncovered.
Dewatering during limited deeper
runoff of contaminated groundwater.
Remediation Action Plan
Contaminated land effects are controlled by Proposed Conditions of
consent 85 to 92.
A copy of the Applicant’s Proposed Conditions of Consent (7 August
2018) is attached
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to the evidence of Karl Cook and Vijay Lala as Attachment A
(Proposed Conditions).
Specifically, Proposed Condition 86 requires the submission of an
updated RAP prior to
works. Proposed Conditions 87 and 88 require the RAP to be in
general accordance
with the RAP submitted as part of the application and also provide
guidance as to the
measures and items that need to be covered by the revised RAP. I
consider that the
Proposed Conditions are appropriate.
The construction effects associated with the disturbance of
contaminated land can be
mitigated through the avoidance or minimisation of the disturbance
of contaminated land.
In areas and for activities where disturbance of contaminated land
cannot be avoided,
mitigation is provided for by Proposed Conditions 85-89A ‘Detailed
Site Investigation and
Remediation Action Plan’. The RAP puts forward control measures to
mitigate and
manage the effects that have been identified in the PSI and
summarised in Table 1
above.
The implementation of the RAP should be overseen by a SQEP. A SQEP
is prescribed
in regulation 3 of the National Environmental Standard for
Assessing and Managing
Contaminants in Soil to Protect Human Health (April 2012) (CBD Vol
E, CB158, page
4092).
The objectives of the remedial strategy put forward for this
project are in general
accordance with the ‘Sea+City Projects Limited, Preliminary
Remedial Strategy’
prepared in 2010 for (now) Panuku to address the overall approach
to contamination
management in the Wynyard Quarter 1
The overall approach proposed by the ‘Sea+City Projects Limited,
Preliminary Remedial
Strategy, 2010’ and subsequently applied and consented for all
subsequent earthworks
and improvement projects within Wynyard Quarter, is a risk based
approach. The
approach allows contaminated materials to be retained onsite where
the risk to the final
users is manageable to acceptable levels.
1 “Preliminary Remedial Strategy, For External Distribution,”
Coffey Environments (NZ) Ltd (ref: ENVINEWP51014 R005 r5
[External].doc) for Sea+City Projects Limited, September
2010.
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Table 2: General Approach to Remediation for AC36 and for Wynyard
projects in general
Site Coverage Type
Roads, pavements
and pathways
Disposal of spoil generated by the installation of new
services.
Establish and maintain a continuous separation layer over the
site via the use of a hard standing road and footpath
pavement.
Appropriately control all construction works to minimise and
manage human health and environmental risks from
contamination during development.
of spoil, with vapour and/or dewatering control where
required.
Parkland and
Landscaping areas
Removal of the top 0.5m of existing surface soils/fill and
capping
with cleanfill and turf or pavement. In relation to the inclusion
of
pavement in the parkland setting this will be applied only in
areas
of turf or soft landscaping where paths or small areas of
pavement are present. In areas where a fully sealed
continuous
hard standing is achieved, within a public space area, the
‘Roads’ remedial actions will apply.
The assessment parameters and ‘status quo’ approach to remediation
has been
reviewed in light of the new data available which was not available
at the time of the
original assessments and in my opinion remains appropriate for this
project.
I consider that the potential effects that could arise from the
presence of contamination
can be appropriately addressed through implementation of the
proposed conditions of
consent and specifically through the provisions within the
RAP.
An updated version of the Draft RAP has been prepared by the
Wynyard Edge Alliance,
which adds further specific detail surrounding construction
methodologies and handling
procedures. This RAP is included as Attachment A. This document is
to be updated
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again post completion of a Detailed Site Investigation. I consider
this a robust and
effective process to allow all information to be utilised in
mitigation planning.
7. GROUNDWATER
In this part of my evidence I will briefly summarise the existing
groundwater regime and
the potential groundwater effects that might result from the
physical infrastructure
required to support the America’s Cup. Full details are provided in
the Groundwater
Assessment report entitled “America’s Cup Groundwater Technical
Report for Resource
Consent Application, Wynyard Hobson” prepared by Beca Ltd dated 4th
April 2018 and
lodged with the Application (CBD Vol A, CB31, page 1886).
I consider that the majority of activities required to support the
America’s Cup
development, such as piling, surficial excavations and / or
filling, will comply with the
permitted activity standards for the take and diversion of
groundwater, and as such will
have negligible effect on the groundwater regime and are not
considered further in my
evidence.
Ground improvements on Wynyard Point may not fully comply with the
permitted activity
standards and do require a permit for the diversion of groundwater
as a restricted
discretionary activity.
GEOLOGY AND GROUNDWATER REGIME
The reclamation fill overlies a variable thickness of Recent Marine
sediments and
Tauranga Group alluvial and estuarine sediments, that have infilled
an old valley system.
Waitemata Group rock is encountered at a variable depth, ranging
from -15 m to -23 m
Chart Datum with the axis of the old valley which is inferred to
run parallel to (and
beneath) the Wynyard Point reclamation.
The groundwater levels and direction of flow within the Wynyard
Point reclamation are
complex as a result of the heterogeneous nature of the fill and the
presence of seawalls,
both of which result in varying local conductivities, tidal lags
and tidal ranges over
relatively small distances.
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Groundwater levels under Wynyard Point are expected to be
principally controlled by
either:
a) The harbour (where the outer reclamation walls are permeable);
or
b) Local soil conditions, as well as the presence of service
trenches which may act
as a preferential flow path (where the outer reclamation walls are
less
permeable).
Groundwater levels are typically in the range of 1.4 m to 3.0 m
below ground level, based
on a typical ground level of 3 m RL. Previous monitoring suggests
slightly shallower
water level underneath the ASB carpark site, however this is not
considered to be
significant. The direction of flow is considered to be towards the
north or northeast,
however significant localised variation is likely.
SUMMARY OF PROPOSED ACTIVITIES WITH POTENTIAL FOR IMPACT ON
GROUNDWATER
The geotechnical report prepared for the project identifies that
ground improvements,
over an approximate 230 m length of Brigham Street will be required
for liquefaction
mitigation for the structures on or adjacent to the existing
Wynyard Point reclamation.
The exact nature of the ground improvements are not yet known, with
allowance made
within the application documents for any of the below:
a) Cement-stabilised columns (or stone columns) placed in a lattice
pattern and
extending some 20 m landward of the existing seawalls. These
columns would
likely extend to depths of 10 m to 15 m; and
b) A cement stabilised “raft” in the upper few metres of the soil
profile over the full
extent of the lattice; and / or
c) Piling at a diameter of up to 2 m.
At the time of writing this evidence the design for ground
improvements along Brigham
Street includes using cement stabilising a large block under the
existing road, to a depth
of at least 5m and with a width of 5m or greater.
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Pile holes (if required) are expected to be cased and either
locally dewatered for only
very short periods (days) or will be constructed as wet pours with
no dewatering.
Assessment of Effects of Ground Improvement on Groundwater
The greatest potential for effects, albeit that they are small, is
with regard to changes in
groundwater levels and direction of flow arising from the ground
improvements, and that
may potentially result in mounding (local rise of groundwater
level).
As the ground improvements are not perpendicular to the direction
of groundwater flow,
and given that groundwater can still discharge to the coast along
the north and western
boundaries of Wynyard Point reclamation, negligible changes in the
overall direction of
flow or mounding of groundwater levels are expected.
Monitoring of changes in groundwater level associated with previous
ground
improvements in the Wynyard Quarter area (albeit to shallow depths)
has not indicated
any mounding that can be attributed to ground improvements.
In the unlikely event that mounding does occur it is likely to be
of a similar order to that
which was calculated for elsewhere in Wynyard Quarter which is less
than 0.2 m and
hence may be indistinguishable from background variations (tidal
influence and seasonal
variations).
If that level of mounding were to occur, the groundwater levels
would remain deeper than
1.2 m below ground level (bgl) and no buoyancy effects on services
or surface structures
are anticipated.
I consider it unlikely that groundwater level mounding will occur,
however should it occur
above the expected levels, and to a degree which might cause an
adverse effect then
there are mitigation options available using an increase in
drainage to mitigate this effect.
Mitigation
I consider that Proposed Conditions 93 to 102 are sufficient to
avoid the potential
(negligible) adverse effects on groundwater.
Proposed Conditions 98 and 99 require the groundwater level
monitoring to be
undertaken and sets out the methodology for how these shall be
undertaken.
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Proposed Groundwater Monitoring
As no significant excavations are proposed, ground and building
settlement is not
expected to occur and for this reason, no survey monitoring, or,
building or utility
condition surveys are proposed.
Three shallow groundwater monitoring wells have been installed and
will allow
monitoring of groundwater levels prior to, during, and
post-construction in order to
confirm my assessment.
A Groundwater Monitoring and Contingency Plan (GMCP) will be
prepared which sets
out the details of the monitoring wells, results of baseline
monitoring, trigger levels and
contingency measures. The conditions require that the GMCP will be
submitted to the
Council for certification prior to works commencing on site. A copy
of the draft CMCP is
attached to the evidence of Mr Grant and is discussed further in
his evidence.
8. COMMENTS ON THE COUNCIL REPORT
I have reviewed the Auckland Council Section 87F report, including
the below
appendices:
a) Appendix K: Marija Jukic, Senior Specialist, Natural Resources
and Specialist
Input, Resource Consents (land contamination)
b) Appendix N: Richard Simonds, Senior Specialist, Natural
Resources and
Specialist Input (groundwater)
c) Appendix J: Rob Van De Munckhof, National Environment Standards
(Soil)
Report
d) Appendix S: Paul Crimmins, Air Discharges Report
In general I have no significant points of disagreement with any of
the content within the
four technical reports above.
9. COMMENTS ON SUBMISSIONS
None of the submissions received identify directly either
groundwater effects or air
quality, earthworks, or contamination effects as a matter of
concern or opposition.
Several Mana Whenua groups including Ngaati Whanaunga Incorporated
Society, Te
kitai Waiohua Waka Taua Incorporation, Ngti Tamater, Ngati Tamaoho
Trust, Te
Patukirikiri Iwi Trust, Ngai Tai Ki Tamaki and Ngti Maru Runanga
Trust have expressed
an overarching concern relating to the potential for water quality
and ecological effects,
and cumulative effects. The above Mana Whenua groups have also all
or in-part
expressed concern as to the sufficiency of information and time to
allow them to evaluate
effects to the Mauri of the proposed development area. In so far as
the above generally
expressed environmental concerns may relate to the presence and
handling of
contaminated soils, I have provided comment in the points
below.
I consider that all environmental effects potentially arising from
the development works
can be appropriately mitigated through controls provided for within
the RAP and the
proposed consent conditions. Additionally the same issues have been
successfully
mitigated on similarly contaminated sites with similar controls
within Wynyard.
I have been involved with many of the Mana Whenua groups during the
development of
public open space (roads and parks) and private developments
(Wynyard Central) within
the wider Wynyard area over the last 4 years. I consider the issues
relating to
contamination that were brought up during Hui of the Mana Whenua
Group for previous
Wynyard works are likely to be similar for the land development
works covered by the
AC36 Application.
My impression during many ‘iwi monitor’ visits to sites over the
last 4 years is that the
methods of handling of contamination was trusted by those iwi
members that attended
those sessions.
10. CONCLUSION
Contaminated Land
The contamination status of the soils and groundwater in the areas
proposed for
disturbance is understood sufficiently to enable confidence in the
mitigation measures
0845
19
proposed. Further proposed investigations and monitoring will
provide further
confidence and granularity to the mitigation response. The details
of historic
investigations are provided within the PSI (CBD Vol A, CB32 page
2005).
The expected contamination profile is highly likely to be similar
in its composition and
distribution to the ongoing Wynyard Central developments with a
strong basis to
conclude more limited quantities and thicknesses of separate phase
hydrocarbons on
the subject sites.
A similar set of controls and approach is proposed within the RAP
to those adopted and
implemented successfully at Wynyard central despite several of the
Wynyard Central
developments having the significantly complicating factor of
underground basements
which this proposal does not have.
The controls put forward within the RAP effectively mitigate water
migration and
contaminant transport away from the site during construction, limit
human contact with
soils and groundwater, and provides for monitoring and mitigation
of potential vapour
and dust effects during construction.
In my opinion, the America’s Cup project construction works and
ongoing (temporary)
use of the bases will present a negligible effect on human health
or environmental risk,
with the implementation of controls provided for within the RAP and
with any other
controls as is appropriate based on additional soil and groundwater
sampling results to
be included within a yet to be completed Detailed Site
Investigation, and updated RAP
(as per Proposed Conditions 85 through 92).
Groundwater
In my opinion, the Americas Cup project will have a negligible
effect on the groundwater
regime.
Monitoring of groundwater levels prior to, during and after
construction is proposed to
ensure any potential effects are identified and managed
appropriately.
Phillip John Ware
7 August 2018
0847
Remediation Action Plan (DRAFT)
WYNYARD EDGE ALLIANCE
This DRAFT management plan has been prepared for discussion
purposes only.
When reading this plan please note the following:
The plan is based on the amended proposed draft conditions dated 27
July 2018.
The plan is based on the design and construction methodology as at
July 2018 and these are subject to change as the design and
construction planning is progressed concurrently with the resource
consent process.
The plan is a draft for discussion with relevant submitters, other
stakeholders and Auckland Council specialists.
The plan will continue to be refined to reflect the agreed changes
to conditions, address key issues from the consent process and to
reflect the developing design and construction planning.
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Revision History
Revision Nº
Description Prepared By Reviewed by Approved on behalf of
Wynyard
Edge Alliance
A Draft plan for Auckland Council pre-submission comment
Items highlighted green indicates details still to be confirmed by
the Alliance
Penelope Lindsay
Chris Bailey
Bob Mawdsley
Brendon Barnett
Edwin Zwanenburg
Kurt Grant
Nicola Ridgley
B Draft plan for inclusion in evidence
Items highlighted green indicates details still to be confirmed by
the Alliance
Penelope Lindsay
Chris Bailey
Bob Mawdsley
Kurt Grant
Brendon Barnett
Disclaimer
This report has been prepared by the Wynyard Edge Alliance for the
benefit of the Panuku Development Auckland
Limited. No liability is accepted by the Alliance Partners or any
employee of or sub-consultant to the Alliance Partners
companies with respect to its use by any other person.
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Contents
Project description
..............................................................................................................
8
Earthworks and pile wall
...................................................................................................
10
Programme
........................................................................................................................
11
Site identification
...............................................................................................................
12
Site description
..................................................................................................................
13
Vapour risk
.........................................................................................................................
19
Primary contamination issues and their management
..................................................... 20
Additional testing requirements for secondary works areas
............................................ 21
Site Management
...........................................................................................
22
Excavation and spoil management
....................................................................................
24
Imported fill
.......................................................................................................................
25
Water management
..........................................................................................................
25
Odour management
..........................................................................................................
26
Vapour management
.........................................................................................................
27
Dust management
.............................................................................................................
27
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Decontamination procedures
............................................................................................
28
General
..............................................................................................................................
30
Emergency procedures
......................................................................................................
31
Monitoring Procedures
...................................................................................
32
Asbestos in air
monitoring.................................................................................................
34
Validation including sampling and testing
........................................................................
34
Contingency Procedures
.................................................................................
35
Validation sampling
...........................................................................................................
39
Appendix C
Figures
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Appendix D
Appendix E
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Relevant Consent Conditions
The consent conditions relevant to the Remediation Action Plan
(“RAP”) are summarised in Table 1.1 below. The conditions
referenced are as per in the proposed draft resource consent
conditions1.
Table 1.1: Summary of consent conditions relevant to the RAP.
Condition Number
Condition Requirement Section Referenced in the Plan
85 Prior to any excavation or soil disturbance in areas of known or
potentially contaminated land, the consent holder shall engage a
Suitably Qualified Environmental Practitioner (SQEP) to undertake
additional soil and groundwater testing for the assessment of
contamination within the areas proposed for soil disturbance. The
investigation is to be undertaken in general accordance with
Ministry for Environment (MfE) Contaminated Land Management
Guidelines No. 5: Site Investigation and Analysis of Soils (Revised
2011) and any amendments to this document. A Detailed Site
Investigation (DSI) Report is to be prepared and submitted to the
Team Leader Compliance Monitoring – Central for
certification.
Section 5.2 and forthcoming DSI
86 At least five (5) days prior to excavation or disturbance in
areas of known or potentially contaminated land, the consent holder
shall update the Draft Remediation Action Plan (RAP) included in
the consent application. The updated RAP shall be prepared and
submitted to the Team Leader Compliance Monitoring – Central for
certification in terms of the matters in Condition 88.
This Plan
a) Minimise harm from any potential human exposure from
contaminants;
c) Identify any unknown contaminated material.
Section 2.1
1 Unio Environmental, 27 July 2018. America’s Cup Wynyard Hobson
–Panuku Amended Proposed Conditions.
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Condition Number
Condition Requirement Section Referenced in the Plan
88 The RAP shall be in general accordance with the Draft
Remediation Action Plan
included in the consent application, and shall include:
Any soil, groundwater and gas (if required) investigations
undertaken
to characterise potential hazards associated with works in those
areas
and to inform development of the RAP;
The measures to be undertaken in the handling, storage and
disposal
of all contaminated material excavated during Construction
Works;
The soil verification testing that will be undertaken to determine
the
nature of any contamination in excavated material and the
potential
reuse or disposal options for that material;
Measures to be undertaken in the event of unexpected
contamination
being identified during construction activities, including measures
to:
(i) Assist with identification of unknown contaminated
material; and
(ii) Stop work or isolate the area once any such material is
identified.
The measures to be undertaken to manage contaminated land to:
(i) Protect the health and safety of workers and the public;
(ii) Control stormwater run-on and run-off; and
(iii) Remove or manage any contaminated soil.
f) Measures to monitor and mitigate discharges of odour,
volatile
organic compounds and asbestos (if required) during
excavations,
including criteria/action levels for triggering specific control
and
contingency measures;
g) Measures to manage the placement of dredge material on the
site
addressing:
of the dredge material within the site, and its management;
(ii) The management of the associated contaminant discharges
and the relevant effects on the receiving environment;
(iii) Description of the contingency plan procedures for the
management of unexpected contamination within the placed dredge
material.
Appendix B presents a review of the Application RAP requirements
and presents the location with this RAP where they are
addressed.
89 The RAP shall be implemented and maintained throughout the
entire construction period.
Section 6.1
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Condition Number
Condition Requirement Section Referenced in the Plan
89A If the DSI required by Condition 85 identifies the presence of
vapours from
contaminants in the ground a vapour risk assessment shall be
undertaken
to:
building occupants;
b) Undertake a risk assessment to identify if additional
mitigation
measures are required for the protection of workers or
occupants
on any enclosed buildings or structures; and
c) Identify appropriate mitigation measures for incorporation into
the
RAP or into the design of any proposed buildings or
structures.
Section 5.4 and to be addressed by DSI
89B The discharge of contaminants to land and water from the reuse
and stockpiling
of cement stabilised dredge material shall be carried out in
accordance with
the updated Remediation Action Plan referenced in Condition
88.
Section 6.6
89C Any dredge material that has not been cement-stabilised and is
placed within the
site shall be adequately bunded and covered to avoid the generation
of
contaminant discharges. Any seepages from the unstabilised
dredge
material shall be considered potentially contaminated, and shall
either:
a) Be disposed of by a licenced liquid waste contractor; or
b) Pumped to sewer, providing the relevant permits are obtained;
or
c) Discharged to ground provided testing of the discharge has
been
undertaken and any potential effects assessed and submitted to
the
Team Leader Compliance Monitoring – Central.
Section 6.6
90 All sampling and testing of contamination on the site shall be
overseen by a suitably qualified and experienced practitioner. All
sampling shall be undertaken in general accordance with MfE
Contaminated Land Management Guidelines No. 5 Site Investigation
and Analysis of Soils (Revised 2011) and any amendments to this
document.
Section 8.6
91 Where contaminants are identified that have not been anticipated
by the RAP, works in the area containing the unexpected
contamination shall cease until the contingency measures outlined
in the certified RAP have been implemented, and the discovery and
contingency measures undertaken have been notified to the Team
Leader Compliance Monitoring – Central.
Section 9
92 Excavation or soil disturbance in areas of known or potentially
contaminated land shall be managed to minimise the generation of
dust, asbestos, odour and volatile organic compounds and be carried
out in accordance with the certified RAP.
Sections 6.7, 6.8, 6.9, 6.10
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Introduction
This Remediation Action Plan (“the RAP”) forms part of a
comprehensive suite of environmental controls within the
Construction Environmental Management Plan (“CEMP”) for the
America’s Cup Infrastructure Project (“the Project”). It is an
update to the RAP prepared by Beca2 and submitted as part of the
consent application documents (Application RAP). The Project is
being delivered by the Wynyard Edge Alliance (“the
Alliance”).
Scope and Objectives of the Remediation Action Plan
The objectives of this RAP, in accordance with consent Condition
87, are to:
a) Minimise harm from any potential human exposure from
contaminants;
b) Manage environmental risk from contaminated material; and
c) Identify any unknown contaminated material.
The scope of this report is to provide the following:
A description of the current site condition and proposed
works;
Any soil, groundwater and gas investigations undertaken to
characterise potential hazards associated with works and to inform
development of the RAP;
Procedures for undertaking the works and for handling, storage and
disposal of contaminated spoil generated during earthworks;
Details of any soil verification testing undertaken to determine
the nature of any contamination in excavated material and the
potential reuse or disposal options for that material;
Procedures relating to exposure of potentially contaminated soils
and water to protect health and safety for workers and general
public, control stormwater run-on and run-off and remove or manage
any contaminated soil during the redevelopment works;
Measures to manage the placement of dredge material on the
site;
Measures to monitor and mitigate discharges of odour, volatile
organic compounds and asbestos during excavations;
Contingency measures should adverse effects become evident during
the works; and
Compliance monitoring and validation requirements.
It should be noted that additional design detail is required for
tender and construction purposes.
The report has been prepared in accordance with the MfE Guidelines,
No.13 and by suitably qualified and experienced practitioners as
required by the NES Soil regulations.This RAP addresses the matters
in
2 Beca Limited (Beca), April 2018, America’s Cup Draft Remediation
Action Plan for Resource Consent Application,
Wynyard Hobson, Prepared for Panuku Development Auckland (Client)
and Ministry for Building, Innovation and
Employment (MBIE)
3 Ministry for the Environment, 2011: Contamination Land Management
Guidelines, No.1 - Guidelines for Consultants
Reporting on Contaminated Sites in New Zealand
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Wynyard Edge Alliance |Remediation Action Plan (DRAFT) Rev B |
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Conditions 85-92 of the consent (refer to the quick reference guide
to conditions in Section 1 at the front of this plan).
The final version of this RAP will be, and is submitted to the Team
Leader Compliance Monitoring – Central in accordance with Condition
16 for certification.
This RAP will be updated if necessary to reflect changes in design,
construction methods or to manage effects. In accordance with the
consent conditions, any amendments are to be agreed by the Team
Leader Compliance Monitoring – Central in writing prior to
implementation of any changes. A copy of the original RAP and
subsequent versions will be kept for the Project records, and
marked as obsolete. Each update of the Plan will be issued with a
version number and date.
Project description
The project sites are the landside bases (C, D, E, F and G) located
on Wynyard Point. Secondary sites consist of areas south of Wynyard
Point, Halsey Wharf and Hobson Wharf where utility services’
connections are required. See Section 3.1 for discussion of spoil
generation.
As indicated in Figure 1 (Appendix C), Bases C and D are currently
tenanted by ASB for parking, Base E is currently tenanted by NZ
Sail and Stolthaven Terminals (Stolthaven), and Base G is currently
tenanted by BST. ASB will be vacating their site in October 2018.
Stolthaven and BST will not be vacating their properties until
February 2019 and August 2019, respectively.
For a description of the Project, refer to the Project Description
within the CEMP. Relevant construction details are described in
Section 3.1 of this RAP.
Associated Management Plans
The CEMP outlines the environmental management framework for the
Project and details the relationship between the CEMP,
environmental management plans, design certification requirements
and the resource consent conditions. It also provides an overview
of the management plans required by the conditions (their purpose
and content etc.) and other environmental mitigation measures to be
implemented during construction.
Associated management plans that are particularly relevant to the
implementation of this RAP include:
The Management Plan for Dredging and Placement of Mudcrete in the
CMA, as it relates to the use of mudcrete in the Wynyard Point area
ground improvements (Appendix C to the CEMP); and
The Erosion and Sediment Control Plan (Appendix D to the
CEMP).
Responsibilities
The Alliance Project Director has the overall responsibility for
meeting the requirements of this RAP.
The Alliance Construction Environmental Manager will have
responsibility for implementing the RAP, but may wish to delegate
responsibility to the Alliance Construction Team so that specific
requirements and provisions of the management plan will be under
the control of that team. Implementation of this RAP is mandatory
during the site construction works.
The Alliance will require personnel involved in the site
construction works to be made familiar with this plan prior to
commencing work on the site, that there are regular reminders about
its requirements, and that the requirements of this plan are
followed at all times.
The Alliance shall appoint a suitably qualified and experienced
practitioner (SQEP), herein referred to as the “Contaminated Land
Specialist”, as defined in the NES Soil Regulations. The
Contaminated Land Specialist (Contaminated Land Specialist) shall
liaise with the Alliance Construction Team during the course of the
works and to undertake the monitoring works required by this
RAP.
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The nominated environmental safety officer/s (ESO) shall be
responsible for ensuring that the contaminated land-related site
management and health and safety procedures are adhered to and that
the risks associated with the potential hazards are minimised. The
role of the ESO shall include ensuring that workers are wearing the
correct protective equipment and respond to new hazards as they
arise. The ESO shall be responsible for implementing instructions
given by the Contaminated Land Specialist.
Of particular note, the ESO shall be authorised to enact emergency
and contingency measures without delay. Should an incident occur on
site which may result in discharges, the designated representative
will take control of the situation and coordinate the efforts of
all on site to minimise the impact.
The Alliance shall appoint an Independent Competent Person who
shall be responsible for undertaking asbestos in air monitoring. A
Competent Person, (i.e. not necessarily independent) shall be
appointed to undertake clearance inspections of
plant/equipment.
Both the Independent Competent Person and the Competent Person must
meet the requirements of regulation 41(3) of the Asbestos
Regulations4, i.e. have acquired, through training and experience,
the knowledge and skills of relevant asbestos removal industry
practice and hold either a certificate from training (WorkSafe
specified) or hold a tertiary qualification in science or related
field.
The Independent Competent Person role can be fulfilled by the
Contaminated Land Specialist if they meet the requirements. The
Competent Person role can be undertaken by Alliance personnel, e.g.
the ESO, if they meet the requirements.
A copy of this RAP shall be kept onsite at all times during the
work. It is the responsibility of the Alliance to distribute the
RAP to all site subcontractors carrying out any land disturbance
works on the site.
The nominated person(s) is to be identified in Table 2.1 below. A
hard copy of this list is to be provided to Auckland Council (NRSI
Team and Licensing and Compliance).
Refer to the CEMP for more detail on roles and
responsibilities.
Project contacts
The contact details for key persons involved in implementing the
RAP are provided in Table 2.1.
Table 2.1: Project contact details
Project hotline TBC
Construction Environmental Manager Brendon Barnett 021 527
461
Contaminated Land Specialist Chris Bailey 021 663 096
Environmental Safety Officer To be nominated TBC
Health and Safety Manager Dave Young 021 224 9670
Further project contact details are contained in the CEMP.
4 NZ Government, 5th February 2016, Health and Safety at Work
(Asbestos) Regulations 2016.
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Proposed America’s Cup Infrastructure Works
Construction activities relevant to this plan
This RAP applies to development of the landside bases (C, D, E, F
and G), services/utilities, link road, Brigham Street piling works,
and landscaped and secondary works areas.
The landside development will consist in summary of the
following:
Establishment of environmental controls including bunding and a
trade waste treatment plant including connection to wastewater
network, subject to the granting of a Trade Waste Agreement by
Watercare.
Shallow excavations (to about 1m), mainly along the western edge of
the bases but also to build a new road link at the north end of the
bases between Brigham Street and Hamer Street. Brigham Street will
be permanently stopped where it traverses the bases.
Wharf infill support and ground improvement works consisting of a
piled “wall” along the eastern side of Brigham Street.
Ground levels are to be raised up to approximately 1.0m above
existing ground levels with cut to fill, imported materials and
also potentially with dredging spoil from the adjacent marine area
works. A barge with mudcrete mixing pug mill or excavator with
specialist mixing head will be required to convert the dredging
spoil to mudcrete which will then be loaded onto trucks to be
transported to the bases.
Each of the syndicate bases will have concrete floor slabs (total
area approximately 10,000m2).
New civil infrastructure will be installed to service the syndicate
bases including roading, forecourt areas, utilities, stormwater
management. The existing utilities will be diverted as
required.
Secondary sites consist of areas south of Wynyard Point, Halsey
Wharf and Hobson Wharf where services connections are
required.
Landscaping and planting is proposed in the public park area at the
south end of the bases, along Hamer Street and along the verge of
the new link road.
Earthworks and pile wall
The earthworks required for the development of the Syndicate bases
will be undertaken in a staged manner, timed to match lease exits.
Most earthworks are expected to occur above the groundwater
level.
As indicated in Figure 2 (Appendix C), the following earthworks
will be required to prepare the sites (to the proposed surface less
500mm):
Approximately 2,000 m3 cut; and
Approximately 5,000 m3 fill.
These volumes are approximate and subject to change. The new
sub-base, basecourse and topsoil are not included in these volumes.
The maximum depth of cut for the bulk earthworks is about 0.5m and
the maximum height of fill for the bulk earthworks is about
1m.
Wharf infill support and ground improvement will be achieved
through a piled “wall” along Brigham Street in line with the sea
wall Up to approximately 10,000m3 of spoil is expected to be
generated as a result of the piling and ground improvement
works.
Manholes and associated stormwater and wastewater pipes will be
installed along Brigham Street. Some of these are expected to
require excavations below the water table. A new wastewater line at
the south
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end of Brigham Street will require excavations to 3.5m depth, which
is expected to be below the water table.
Programme
As indicated above, the works programme will be dictated by site
availability and at this stage is expected to be as follows:
20 Nov 2018 – Construction commences Brigham/Hamer link road
(assuming receipt of resource consent).
28 Feb 2019 – Stolthaven site available
31 Jul 2019 – Base C&D handover for building construction (by
others)
30 Aug 2019 – BST site available
31 Jul 2020 – Base E, F, & G handover for building construction
(by others)
25 Mar 2020 – Landscape element completed, depending on whether
these works are required after building construction.
Sensitive receivers/receiving environment The Project is located on
reclaimed land immediately adjacent to the Waitemat Harbour, and
the stormwater drainage network throughout Wynyard Point drains
into the harbour. Immediate surrounding land is used for
commercial/industrial purposes, but the southern end of Brigham
Street features a children’s playground and restaurants.
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Site Setting and History
Site identification
The project site is located on Wynyard Point in the Wynyard
Quarter, Auckland, as shown in Figure 4.1 below.
Figure 4.1: Aerial Photo Showing the Wynyard Quarter (site
indicated as Wynyard Point Works)
The site addresses, legal descriptions, proposed bases and former
tenants are listed in Table 4.1 below.
Table 4.1: Street addresses and legal description
Street Address
56 Brigham Street
Lot 45 DP 27338, Lot 46 DP 27338, Lot 47 DP 27338, Lot 48 DP
27338
Bases C and D
90 Brigham Street
Lot 49 DP 27338, Lot 50 DP 27338, Lot 51 DP 27338, Lot 52 DP 27338,
Lot 53 DP 27338, Lot 54 DP 27338, Lot 55 DP 27338, Lot 56 DP 27338,
Lot 57 DP 27338, Lot 58 DP 27338
Base E Sail NZ and Stolthaven
Zinc oxide plant from 1937 to 1979. Redeveloped by Marstel in 1981
as tank farm.
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Street Address
8-34 Brigham Street
Lot 1 DP 119658 Base G BST Formerly Caltex Oil and acquired by Bulk
Storage Terminals in 1988 for the bulk storage of combustible and
corrosive liquids.
49-63 Jellicoe Street
SEC 4 SO 415995, Lot 2 DP 119658, SEC 5 SO 415995, SEC 10 SO
415995
Landscaped area
Site description
The properties that make up the project site total about 2.6
hectares. The topography is more or less flat with elevation
ranging from about 3m to 5m above mean sea level (AMSL).
As indicated in Section 2.1:
Bases C and D are currently used by ASB for parking.
Bases E and F are currently tenanted by NZ Sail and Stolthaven.
Sail NZ operate a boat servicing yard at the property. Stolthaven
Terminals operate a tank farm for bulk liquid storage.
Base G is currently tenanted by BST who operate bulk liquid storage
tank farm facility. A small area of landscaped vegetation is
located on the southern boundary of the BST tank farm accessible to
the public.
Brigham Street is a paved public roadway.
Land use in the vicinity is used for an array of commercial and
industrial activities. Further south, Wynyard Quarter land uses
include public access along North Wharf, Silo Park and Jellicoe
Street, and commercial activities, with residential development
some 300 m south of Brigham Street.
To the east is Wynyard Wharf and the Waitemat Harbour. To the south
of the site is a recreation area referred to as Silo Park which
includes a playground and basketball court. To the south west of
Wynyard Point Area are restaurants. To the north of the site is
another tank farm facility as part of Stolthaven North Terminals.
To the west of Wynyard Point Area is a cement truck wash down
facility/concrete batching plant owned by Firth Industries, as well
as a marine engineering boat yard and a service division for
Sanford Limited (a commercial fishing company).
The Wynyard Point Area is directly bound by Brigham Street on the
east and Hamer Street on the west.
Geology
Wynyard Point is located on land reclaimed in the 1920s and 1930s.
Material used for the reclamation predominantly comprises reworked
marine sediments, presenting as layers of grey silty sand and clay
with shell fragments. Additional fill materials include sandstone
from the cliffs adjoining Beaumont Street, and at shallow depths
more variable fill such as demolition debris and gasworks and
incinerator waste are often present.
Reclamation fill overlies Recent Marine Sediments, Tauranga Group
Alluvium and residual soils and rock of the East Coast Bays
Formation of the Waitemata Group. The RMS and TGA comprise sands,
silts and clay. The East Coast Bays Formation comprises alternating
turbidite sandstones and mudstones which weather
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in situ to form silts and clays. In places interbedded lenses of
volcaniclastic grits may be present. Deposits are generally
greenish grey when fresh and weather to light brown.
Hydrogeology
Numerous groundwater investigations have been undertaken at the
project site and in the surrounding area. The following is a
summary of the information presented in the consent
application5.
Groundwater is generally shallow but varies across the project site
with complex levels and flows as a result of the heterogeneous
nature of the fill and the presence of seawalls, e.g. Jellicoe
Street sea wall. Service trenches act as preferential flow
paths.
Historic monitoring indicates depressed groundwater levels within
the existing park at the south end of the project site and elevated
groundwater levels within the Stolthaven tenanted property, i.e.
bases E and F. Levels as low as -0.8m RL (3.8m depth) have been
measured in the park.
Stolthaven groundwater levels have been recorded between 2.0 to 2.5
m RL (1.5 m to 2.0 m depth based on a ground level of 4 m RL), with
an inferred overall flow gradient to the north. Elsewhere in
Wynyard Point, groundwater levels tend to be in the range of 0.0 to
1.6 m RL (1.4 m to 3.0 m bgl, based on a typical ground level of 3
m RL).
There is no abstraction of groundwater at the project site or in
the vicinity other than for construction dewatering on an
intermittent basis.
Site history
As indicated in Table 4.1, the proposed bases had various
industrial occupants as follows:
56-90 Brigham Street (Bases C and D): Used by BP Oil Ltd for bulk
storage of fuel since the 1930s. This site was known as BP East
Yard, with the West Yard located west of Hamer Street. Prior to
demolition in 1999, the site contained above-ground storage tanks,
product supply lines from Wynyard Wharf, an underground storage
tank, tanker wagon fill shelter, and dangerous goods storage.
Various spills and pollution incidents have been recorded including
a 30,000 L spill of kerosene in 1981, and residues from tanks was
reported to have been buried on the property up until the 1970s.
This site was closed and remediated in 2000 and has been used as a
car park since that time.
36-54 Brigham Street (Bases E and F): A zinc oxide plant operated
from 1937 to 1979. In 1981, Marstel developed the site for bulk
storage of flammable, toxic and corrosive chemicals, which were
transferred from Wynyard Wharf via pipelines. This site is now
operated by Stolthaven Terminals.
8-34 Brigham Street (Base G): Originally occupied by Caltex Oil.
Bulk Storage Terminals acquired the site in 1988 for the bulk
storage of combustible and corrosive liquids. Products were
transferred to the tanks via underground pipeline. A tallow spill
from the site was reported in 1992. Currently only edible oils are
stored.
49-63 Jellicoe Street (Landscaped area): Castrol Oil occupied the
site from the 1950s to process lubricating oil. Oils were
transferred to aboveground storage tanks via underground pipelines
from Wynyard Wharf. At least two spills of lubricating oil are
known to have occurred. In 2004 the site was decommissioned and
remediated by excavation of contaminated soils. The site was
redeveloped in 2011 for recreational use.
5 Beca Ltd, April 2018, America’s Cup Groundwater Technical Report
for Resource Consent Application, Wynyard
Hobson. Prepared for Panuku Development Auckland (Client) and
Ministry for Building, Innovation and Employment
(MBIE).
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Contamination
Preliminary Site Investigation As part of preparing to apply for
the consents for the project, a Preliminary Site Investigation
(PSI) was undertaken to identify potential contaminants in soils as
a result of current and/or historical activities6.
The PSI concluded that:
The Wynyard Point area has been used for bulk fuel storage, food
product, and chemical storage since the early 1900s, as well as a
plaster factory and zinc oxide plant which were removed around the
early 1980s to make room for a tank farm for chemical
storage.
Most of the contaminants in the area have originated from the
handling and storage of petroleum hydrocarbons and the historical
disposal of gasworks waste in the reclamation fill.
Petroleum hydrocarbons and gasworks waste including metals and
cyanide are prevalent within soils and groundwater within the area.
Groundwater monitoring indicated Measurable thicknesses of separate
phase hydrocarbons (SPH) are present about half the groundwater
monitoring wells.
With the exception of dissolved cyanide, elevated concentrations of
inorganic compounds are generally localised and are not consistent
spatially or vertically across the site.
Consent is required under the NES Soil as a Discretionary Activity
under Regulation 11. A Discretionary Activity resource consent is
required for the works under the Auckland Unitary Plan (AUP):
Operative in Part (OP), Rule E30.4.1(A7).
The PSI also concluded that a DSI will be required to characterise
the contamination and to enable refinement of the RAP, which was
provided as an appendix to this RAP. [Note: DSI not yet included as
awaiting the results of additional investigations being undertaken
by the Alliance]
Contamination investigations
5.2.1 Detailed Site Investigation (DSI)
A DSI report will be completed for Council review. In the meantime,
the following presents a review of the existing data and indicates
proposed additional investigations.
5.2.2 Historical data
The PSI reported that 24 investigations had been carried out across
the subject site. These historical investigations were undertaken
for BP, Marstel, BST and Stolthaven and focussed on assessing
hydrocarbon impacts as a result of past fuel storage releases. On
this basis, soil testing included total petroleum hydrocarbons
(TPH), benzene, toluene, ethylbenzene and total xylenes (BTEX),
polycyclic aromatic hydrocarbons (PAHs) but also included metals
and cyanide. No asbestos in soil testing was carried out.
Groundwater testing included volatile organic compounds (VOCs),
semi- volatile organic compounds (SVOCs) and soil gas
investigations included testing for similar suite of
analytes.
Locations of the soil and groundwater data points are presented on
Figures 2 to 8 in Appendix C.
6 Beca Limited (Beca), April 2018, America’s Cup Preliminary Site
Investigation (Contamination) for Resource Consent
Application, Wynyard Hobson Prepared for Panuku Development
Auckland (Client) and Ministry for Business, Innovation
and Employment (MBIE)
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Contaminant levels have been measured in the Wynyard Basin
sediments include polycyclic aromatic hydrocarbons, metals, DDT and
tributyl tin7.
Data contained within these historical reports has been collated
and compared against relevant human- health criteria for the
proposed land use, i.e. commercial and recreational. This
comparison provides an understanding of the potential for risks
which might be posed to both workers during the proposed
construction and for the completed development.
5.2.3 Recent and proposed contamination investigations
A number of recent contamination investigations have been
undertaken and are proposed. The recent investigations consist
of:
Six (6) boreholes at the ASB carpark
Five (5) boreholes along Brigham Street
Eight (8) hand augers and four (4) wells at the Stolthaven
site
Eight (8) sediment samples from four (4) locations along the
Sealink Wharf, five (5) sediment samples along the Wynyard Wharf
and five (5) sediment samples around Wynyard Basin.
Soil samples collected have been submitted to the laboratory for
analysis of asbestos, hydrocarbons and metals contamination for
assisting with disposal characterisation. Soil gas samples were
collected from the wells for analysis of volatile organic compounds
(VOCs). The full results are not available at the time of preparing
this RAP.
The proposed investigations consist of:
Ten (10) ten samples across each of the ASB, Stolthaven and BST
sites.
Groundwater samples will be collected from four (4) wells installed
in Brigham Street.
5.2.4 Relevant criteria
The historical soil results have been compared to the following
evaluation criteria, based on current applicable regulatory
framework:
NES Soil standards for commercial/industrial land use. The
commercial/industrial standard was adopted based on the current and
proposed use of the site and as a proxy assessing worker health
risks;
The Auckland Unitary Plan - Operative in Part (AUP) permitted
activity soil acceptance criteria (Table E30.6.1.4.1);
Published background concentrations8 for soils.
7 Golder & Associates Ltd, April 2018, America’s Cup 36,
Assessment of Coastal Environmental Effects Associated with
the Development of America’s Cup Facilities for the Wynyard Hobson
Option.
8 Auckland Regional Council, 2001. Background Concentrations of
Inorganic Elements in Soils from the Auckland
Region: Technical Publication No. 153.
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Where specific standards are not available, applicable standards
were selected based on the MfE Guidelines No. 29. This includes the
Hydrocarbon Guidelines10. For contaminants not covered by NZ
standards, international risk-based standards were consulted (see
Appendix D, table footnotes).
For asbestos in soils, the results were compared against the Tier 1
soil guideline values, as provided in the NZ Asbestos
Guidelines11.
In addition, as it is anticipated that surplus excavated materials
which cannot be reused onsite will require offsite disposal, the
soil results have been compared to the acceptance criteria of the
following fill sites defined as follows:
Cleanfill based on published soil background concentrations and as
defined under the AUP;
Managed fill based on the published acceptance criteria for managed
fill at Waste Management Services’ Redvale Landfill in Dairy
Flats12; and
Licenced landfill based on the published landfill acceptance
criteria of Waste Management Services’ Redvale landfill in Dairy
Flats and Envirowaste Services Limited’s landfill located in
Hampton Downs.
Groundwater results have been compared to inhalation protection
criteria and the ANZECC guidelines for the protection of 80% of
marine species as required under the AUP.
5.2.5 Historical soil data
The historical data includes 105 soil samples collected from across
the ASB site (bases C and D) and 55 soil samples collected from
across the Stolthaven site (bases E and F). The sampling was
carried out between 1995 and 2011.
Summary tables of the soil, soil gas and groundwater results are
presented in Appendix D, alongside a comparison to the relevant
human health criteria and disposal criteria.
For the ASB site (bases C and D):
Metal levels were elevated across the site, in particular arsenic,
cadmium, copper, lead, mercury, nickel, tin and/or zinc in the
majority of samples tested exceeded AUP discharge criteria. Two (2)
samples indicated arsenic concentrations above commercial land use
criteria and one (1) sample indicated a lead concentration above
commercial land use criteria. These were located at depth, i.e.
greater than 1m below ground.
Cyanide was present in most samples tested; but at levels well
below the commercial land use criteria. The AUP criterion of 8
mg/kg was exceeded in eight (8) of the samples tested, with the
maximum concentration of 662 mg/kg collected at 2 m depth.
PAHs were present in most of the soils sampled. Benzo(a)pyrene
equivalents (BaP eq.) were found above commercial land use criteria
(35 mg/kg) in two samples (160 mg/kg and 500 mg/kg). None of the
PAHs exceeded criteria protective of indoor air inhalation.
TPH testing indicated four (4) samples exceeded the commercial land
use criteria for C7 to C9 range hydrocarbons (500 mg/kg) with
levels up to 1100 mg/kg. Eight (8) samples exceeded the
commercial
9 Ministry for the Environment, 2011: Contaminated Land Management
Guideline No.2 – Hierarchy and application in
New Zealand of environmental guideline values.
10 MfE, 1999, Guidelines for Assessing and Managing Petroleum
Hydrocarbon Contaminated Sites in New Zealand
11 BRANZ, November 2017, New Zealand Guidelines for Assessing and
Managing Asbestos in Soils (NZ Asbestos
Guidelines).
12 Redvale is the closest landfill likely to accept soils from the
site.
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land use criteria for C10 to C14 range hydrocarbons (1700 mg/kg)
with levels up to 10500 mg/kg. A number of these samples were
shallower than 1m in depth. Two (2) of the samples indicated C10 to
C14 range hydrocarbons levels exceeding criteria protective of
indoor air inhalation (7,800 mg/kg). All samples complied with AUP
criteria.
Low level BTEX concentrations were present. None were above either
commercial land use criteria, criteria protective of indoor air
inhalation, or AUP criteria. The exception to this is one sample
which indicated a benzene concentration of 0.6 mg/kg compared with
the AUP criteria of 0.08 mg/kg.
For the Stolthaven site (bases E and F):
Eighteen (18) soil samples were tested for metals but only for lead
and zinc. NES Soil commercial land use criteria were not exceeded,
however there were two exceedances of the AUP criteria for lead and
one for zinc.
No cyanide testing was carried out.
Six (6) soil samples were tested for PAHs and these were present in
most of the soils analysed. BaP equivalents were below NES Soil
commercial land use and AUP criteria (35 mg/kg and 20 mg/kg
respectively). None of the PAHs exceeded criteria protective of
indoor air inhalation.
TPH testing did not indicate levels above the commercial land use
criteria, indoor air protection criteria or AUP criteria.
Low level BTEX concentrations were present. None were above either
commercial land use criteria, or indoor air protection criteria or
AUP criteria.
Given the level of contamination identified in the sampled soils,
cleanfill disposal will not be possible.
5.2.6 Sediment data
Contaminant levels have been measured in the Wynyard Basin
sediments and include polycyclic aromatic hydrocarbons, metals, DDT
and tributyl tin. The levels were all below the NES Soil
human-health guidelines for commercial land use, but copper and
lead in four samples were above AUP discharge criteria.
Additional testing has been undertaken since, indicating asbestos
is present at levels above the Tier 1 Soil guideline values. On
this basis, works in removing, processing and filling the Wynyard
Basin dredged materials would be considered asbestos-related works
under the Asbestos Regulations. Asbestos-related works do not
require an Asbestos Removal Control Plan but do require controls as
discussed in Section 7.
5.2.7 Historic groundwater data
The historical data includes 39 groundwater samples collected from
across the ASB site (Bases C and D), 18 groundwater samples
collected from across the Stolthaven site (Bases E and F) and 12
samples collected from the BST site (Base G and the landscaped
area). The sampling was carried out between 2002 and 2018.
For the ASB site (Bases C and D):
Cyanide was elevated in groundwater across the site with levels up
18 mg/L detected, which is well above the ANZECC guideline. Only
lead was also detected above both background and ANZECC guidelines
and only sporadically.
PAHs were widespread in groundwater at low levels, i.e. total PAHs
all less than 1 mg/L and compliant with ANZECC guidelines. BaP and
pyrene levels exceeded their low solubility in some instances.
Solubility exceedances do not necessarily represent an indoor air
inhalation risk.
Similarly TPH testing indicated levels exceeded their low
solubility in a number of samples but solubility exceedances do not
necessarily represent an indoor air inhalation risk.
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Only low level BTEX concentrations were present. None exceeded the
ANZECC guidelines or criteria protective of indoor air
inhalation.
Tetrachloroethene (PCE), trichloroethene (TCE) and vinyl chloride
(VC) were detected at levels of up to 0.042, 0.009 and 0.005 mg/L,
respectively near the centre of the site in 1994. The levels are
all well below groundwater acceptance criteria, derived to be
protective of indoor air for a standard commercial land use
scenario. The levels did not exceed the ANZECC guidelines for these
compounds.
For the Stolthaven site (Bases E and F):
Cyanide was elevated in groundwater across the site with levels up
0.49 mg/L detected, which is above the ANZECC guideline. Lead and
zinc were also detected above ANZECC guidelines.
PAHs were widespread; but detected at low levels. None of the
levels were above ANZECC guidelines or acceptance criteria
protective of indoor air inhalation.
Similarly TPH testing indicated levels exceeded their low
solubility in a number of samples but solubility exceedances do not
represent an indoor air inhalation risk.
Only low level BTEX concentrations were present. None exceeded the
ANZECC guidelines or criteria protective of indoor air
inhalation.
For the BST site (Base G and landscaped area):
Nitrate and nitrite were detected in low concentrations; within
background ranges for Auckland groundwater.
Sporadic groundwater monitoring since 1999 only indicated
hydrocarbons measured as TPH in one (1) well, MW4, located at the
north end of the boundary with Hamer Street. The levels exceeded
their low solubility but solubility exceedances do not represent an
indoor air inhalation risk.
The groundwater results for both the ASB and Stolthaven sites
indicate that dewatering effluent should not be disposed of to the
stormwater network but that trade waste disposal would be feasible,
if required. BST data was not sufficient to make an assessment for
disposal.
5.2.8 Historic soil gas data
Soil gas data was collected from across the ASB site (bases C and
D) in 2002. 36 samples were collected onto sorbent and ATD
(auto-thermal desorption) tubes. Testing for BTEX indicated
concentrations of up to 3850 µg/m3, 6.6 µg/m3, 1.6 µg/m3 and 7
µg/m3, respectively; all well below soil gas criteria protective of
indoor air.
Adequacy of data sets
Given the absence of testing for asbestos, an assessment of
contamination levels cannot be made. Experience on sites to the
south indicates that asbestos may be present at levels between
>0.001% and <0.01%, requiring disturbance to be undertaken as
asbestos-related works.
Given the number of sampling points for hydrocarbon testing at ASB,
it is considered that the additional testing would only be to
assist with characterising earthworks cut for disposal purposes.
Additional soil, soil gas and groundwater data is being sought at
Stolthaven and BST to better understand the risks at these
properties. In the interim, the management proposed should be a
conservative approach.
Vapour risk
As indicated above, the ASB site is the only property that is
considered characterised sufficiently to provide an assessment of
the potential for vapour impacts. The review of vapour risks is
therefore currently restricted to the ASB site.
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The levels of contaminants encountered in soil gas and groundwater
do not indicate a potential for indoor air inhalation risk (i.e.
vapour intrusion). This is on the basis that contaminants levels
are all well below the relevant indoor air acceptance
criteria.
The only contaminant levels which indicate potential for vapour
intrusion risk are two (2) soil samples which measured C10 to C14
range hydrocarbons levels above the criteria protective of indoor
air inhalation, i.e. 7,800 mg/kg. The exceedances were located at
R13, near the centre of the site, at 2.9 to 3m depth at
concentrations of 9,280 mg/kg and 10,500 mg/kg (primary and
duplicate samples). However, review of the derivation of the
criteria protective of indoor air inhalation indicates that a
vapour risk would not be feasible for C10 to C14 range
hydrocarbons. This is because vapour concentrations could not
increase over the soil saturation limit, i.e. the level that SPH
would form, which for silt soils is 16 mg/kg13. On this basis, it
is concluded that the contamination levels at the ASB site would
not be considered to pose a vapour risk to indoor air for standard
commercial land use.
Potential for odour emissions
Based on our past experience with properties in the Wynyard Quarter
including on adjacent sites, there is potential for odours to be
generated during development earthworks at the site.
Primary contamination issues and their management
It is likely that disturbance of soils at the site during the
proposed redevelopment will cause release of odours and these will
need to be managed using water misting and suppressants, as
necessary.
Given that that groundwa