Port of Melbourne - PCP Independent EMP Audit Annual ......Port of Melbourne Corporation Port Capacity Project Independent External EMP Audit Annual Report 2016 PCP Independent EMP

Port of Melbourne Corporation

Port Capacity Project Independent External EMP Audit

Annual Report 2016

March 2017

Port of Melbourne Corporation Port Capacity Project Independent External EMP Audit Annual Report 2016

PCP Independent EMP Audit Annual Report 2016 Final.docx



Contents

EXECUTIVE SUMMARY i

1 Background to the audits 1

2 Audit objectives, scope and methodology 32.1 Audit objective 32.2 Audit scope 32.3 Audit criteria 32.4 Audit methodology 4

3 Audit fIndings and conclusion 63.1 Audit findings 63.2 Audit conclusion 6

Appendix 1: Audit findings and actions 8

Version History

Version Date Issued Comment

Draft v1 24/3/2017 Initial draft

Final 29/3/2017 Minor revisions

File: PCP Independent EMP Audit Annual Report 2016 Final.docx

This report was prepared for the identified client for the purposes outlined in the report. No reliance should be placed on the report by any other person for any other purpose.



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EXECUTIVE SUMMARY

The Port Capacity Project (PCP) is a major infrastructure project to meet the needs of a projected increase in container trade through the Port. The PCP includes:

§ The development of additional container capacity for Victoria via the development of Webb Dock East as a new international container terminal

§ The development of Webb Dock West to accommodate Victoria’s roll-on, roll-off import and export automotive trade, including displaced trade from Webb Dock East.

The PCP works commenced in 2013 and were managed under a range of Port of Melbourne (PoM)1, Contractor, and Operator documentation, including the PCP Environmental Management Plan for Construction (EMP). Table 4 of the PCP EMP requires that the EMP be audited annually by an independent external environmental auditor. The audit is conducted as a number of Interim Audits over the annual audit cycle and is consolidated into a single annual audit (this report).

The scope of the 2016 audits covered the substantive construction activities from 1 January 2016 to the completion of construction activities. The main activities during the audit period were land and marine construction works. These works included activities under the:

• Roads and Services works package which continued on from 2014 and were undertaken by BMD;

• Maritime works package which continued on from 2014 and were undertaken by McConnell Dowell;

• Automotive Terminal works package which continued on from late 2014 and were undertaken for Melbourne International RoRo Automotive Terminal (MIRRAT) by CPB Contractors (formerly known as Leighton Contractors);

• Container Terminal works package which continued on from late 2014 and were undertaken for Victoria International Container Terminal (VICT) by BMD.

• Completion work package undertaken by McConnell Dowell (commenced construction activities on 2 March 2016); and

• Playscape work package undertaken by Baron Forge (commenced site activities on 19 August 2016).

All construction works were completed during 2016.

1 New ownership arrangements for the Port of Melbourne’s commercial assets and operations came into effect on 1 November 2016. References in this Annual Audit Report to ‘PoM’ or ‘Port of Melbourne’ are generally to the privately owned entity Port of Melbourne Operations Pty Ltd as trustee for the Port of Melbourne Unit Trust.



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EMP Table 4 requirements and Project Delivery Standard (PDS) 1 – 13, and 15 - 32 were audited by Lead Auditor, Zena Helman of Helman Environmental. Four Interim Audits were undertaken on:

• Interim Audit 1/2016: 17 and 23 March 2016

• Interim Audit 2/2016: 30 June, and 13 and 14 July 2016;

• Interim Audit 3/2016: 26 and 28 September 2016; and

• Interim Audit 4/2016: 21 and 22 November 2016.

All the audits included:

• Interviews with the PoM Manager Integrated Management System (IMS) and Project Manager Environment, and review of relevant PoM environmental records;

• Interviews with Contractor and Operator personnel, review of relevant environmental records, and inspection of site activities at the PCP project site; and

• Completion of the audit checklist.

PDS 14 Contaminated Material was audited by Lead Auditor, Anthony Lane and the Auditors Assistant of Cardno. Four Interim Audits were undertaken on:

• First Interim Audit: 24 February 2016

• Second Interim Audit: 12 May 2016;

• Third Interim Audit: 7 July 2016; and

• Fourth Interim Audit: 6 December 2016.

Where applicable, each of these Interim Audits included completion of the field audit checklist and the records audit checklist. A site walkover was undertaken during each Interim Audit to allow for an assessment of site conditions and to inspect soil management activities in progress at that stage of works.

The audit of PDS 14 was undertaken by a Victorian EPA Contaminated Land Auditor (not operating within a statutory capacity) as reported in the Cardno Annual Soil Management Compliance Audit 2. This annual EMP audit report relies on the information provided in the Cardno report. While the audit conduct and the results of the audit have not been verified by Helman Environmental they have been taken as a true and accurate record of the audit of PDS 14.

The Interim Audits did not find any evidence of non-conformance with the notification requirements of Table 4 of the PCP EMP, or the requirements of the Project Delivery Standards relevant to the works being undertaken. No non-conformances or partial non-conformances were raised during the 2016 Interim Audits.

2 Cardno Lane Piper. Annual Soil Management Compliance Audit. Port Capacity Project, Webb Dock, Port Melbourne, Victoria. March 2017 (Doc Ref 213159Report 27.2)



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A total of 13 minor audit findings were raised during the reporting period, comprising four Recommended Actions, and nine Improvement Opportunities. Nine findings related to PDS 14, with the other four findings related to the remaining PDS. The findings largely related to documentation and record keeping, with a minority of findings directly relevant to on-ground environmental management. None of the findings posed a risk to the environment or to effective environmental management.

All the audit findings from the 2016 audit period were closed out during the reporting period. The four audit findings which remained open from the 2015 audit period were closed out during the 2016 reporting period. Audit findings raised in this audit period and the findings which remained open from 2015 are provided in Appendix 1, together with the actions taken for close out.

PoM raised six Non-Conformances with the EMP during the 2016 reporting period. Four of the Non-Conformances were related to PDS 12 Stormwater and Groundwater Management, with three of the Non-Conformances associated with the uncontrolled discharge of stormwater. One Non-Conformance related to the management of groundwater. One Non-conformance related to PDS 15 Marine pests, and one to PDS 14 Contaminated material. All Non-Conformances were promptly reported to the relevant authorities as required by the EMP and did not result in harm or risk to the environment.

This report is the annual audit of the EMP Table 4 and PDS 1- 323 requirements (where applicable) for the period 1 January 2016 to the completion of construction activities. The conclusions of this annual EMP audit are based on the collation and consolidation of findings of the interim audits. This report only considers substantive works undertaken and audited during the 2016 audit period and information available for review during the audit period.

This report is the final PCP EMP Annual Audit Report.

3 PDS’ 28 and 29 were removed from the EMP in Revision 3.



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1 BACKGROUND TO THE AUDITS

The Port Capacity Project (PCP) is a major infrastructure project to meet the needs of a projected increase in container trade through the Port. The PCP will include major construction activities at Swanson Dock and Webb Dock and marine works at Webb Dock.

As outlined in the Port of Melbourne (PoM)4 documentation, the main components of the PCP are:

• the development of additional container capacity for Victoria via the development of Webb Dock East (WDE) as a new international container terminal

• the development of Webb Dock West (WDW) to accommodate Victoria’s roll-on, roll-off import and export automotive trade, including displaced trade from Webb Dock East.

The works commenced in 2013 and were substantially completed during the reporting period. PCP works were undertaken by PoM’s Contractors, Operators and Operators’ Builders and managed in accordance with contractor management plans and procedures.

An Environmental Management System (EMS) consistent with the requirements of the Australian and International standard, AS/NZS ISO 14001:2004 (Environmental management systems – Requirements with guidance for use) was developed to guide environmental management for the project. A key component of the EMS is an Environmental Management Plan for Construction (EMP). The EMP includes:

• Description of the main elements of the PCP EMS, their interaction and direction to key procedures (including legal requirements, risk management, induction and training, emergency response, incident reporting, measurement and evaluation, and management review).

• External notification and reporting requirements.

• Project Delivery Standards (PDS; incorporating environmental controls).

• Description of environmental monitoring programs and contingency plans.

Independent external environmental audits were undertaken throughout the works to assess the implementation of key elements of the PCP EMP in accordance with the requirements of Table 4. Interim Audits were conducted nominally four times a year and/or during key construction activities. The Annual Audit report is a collation and consolidation of Interim Audits. An Annual Audit report is prepared for submission to the

4 New ownership arrangements for the Port of Melbourne’s commercial assets and operations came into effect on 1 November 2016. References in this Annual Audit Report to ‘PoM’ or ‘Port of Melbourne’ are generally to the privately owned entity Port of Melbourne Operations Pty Ltd as trustee for the Port of Melbourne Unit Trust.



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Department of Environment, Land, Water and Planning (DELWP) which will summarise the key findings identified during the interim audits.

This report provides the outcomes of the Interim Audits conducted in 2016. This is the final PCP EMP Annual Audit Report.



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2 AUDIT OBJECTIVES, SCOPE AND METHODOLOGY

2.1 Audit objective

The overall objective of the 2016 audit cycle was to verify conformance with the following elements of the PCP EMP:

• Table 4 – Notification and reporting requirements

• Project Delivery Standards (EMP Annexure 4) as relevant to the works being undertaken.

2.2 Audit scope

The scope of the 2016 audits covered all substantive activities from 1 January 2016 to 31 December 2016. The main activities during the audit period were land and marine construction works.

PoM’s implementation of the external notifications and reporting requirements (EMP Table 4), and the relevant Project Delivery Standards (PDS) PDS 1 - 325, which relate to construction and maritime activities, were audited during the reporting period.

The audit period included the following activities and auditees:

• Roads and Services works package which continued on from 2014 and were undertaken by BMD;

• Maritime works package which continued on from 2014 and were undertaken by McConnell Dowell;

• Automotive Terminal works package which continued on from late 2014 and were undertaken for Melbourne International RoRo Automotive Terminal (MIRRAT) by CPB Contractors (formerly known as Leighton Contractors);

• Container Terminal works package which continued on from late 2014 and were undertaken for Victoria International Container Terminal (VICT) by BMD.

• Completion work package undertaken by McConnell Dowell (commenced construction activities on 2 March 2016); and

• Playscape work package undertaken by Baron Forge (commenced site activities on 19 August 2016).

2.3 Audit criteria

The audit criteria were:

5 PDS’ 28 and 29 were removed from the EMP in Revision 3.



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• Port Capacity Project, Environmental Management Plan for Construction, PCP IMS PLN 004 Rev 9 (21 September 2016)6.

• Port Capacity Project, Soil Management Methods Statement, PCP IMS MS 001 Rev 2.1(21 March 2014)7.

2.4 Audit methodology

The audit methodology was consistent with ISO 190118 and was implemented to meet the specific requirements of PoM.

EMP Table 4 requirements and PDS 1 – 13, and 15 - 32 were audited by Lead Auditor, Zena Helman of Helman Environmental. Four Interim Audits were undertaken on:

• Interim Audit 1/2016: 17 and 23 March 2016

• Interim Audit 2/2016: 30 June, and 13 and 14 July 2016;

• Interim Audit 3/2016: 26 and 28 September 2016; and

• Interim Audit 4/2016: 21 and 22 November 2016.

All the audits included:

• Interviews with the PoM Manager Integrated Management System (IMS) and Project Manager Environment, and review of relevant PoM environmental records;

• Interviews with Contractor and Operator personnel, review of relevant environmental records, and inspection of site activities at the PCP project site; and

• Completion of the audit checklist.

PDS 14 Contaminated Material was audited by Lead Auditor, Anthony Lane and the Auditors Assistant of Cardno. Four Interim Audits were undertaken, on:

• First Interim Audit: 24 February 2016

• Second Interim Audit: 12 May 2016;

• Third Interim Audit: 7 July 2016; and

• Fourth Interim Audit: 6 December 2016.

Where applicable, each of these Interim Audits included completion of the field audit checklist and the records audit checklist. A site walkover was undertaken during each Interim Audit to allow for an assessment of site conditions and to inspect soil management activities in progress at that stage of works.

This Annual Audit Report is the annual audit of the EMP Table 4 and the relevant PDS 1-32 requirements for the audit period from 1 January 2016 to the completion of

6 The PCP EMP was revised twice in 2016. The applicable version of the EMP for the scope of each Interim Audit was used as the audit criteria. 7 There were no revisions to the PCP SMMS during the audit period. 8 ISO 19001:2011. Guidelines for auditing management systems.



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construction activities. The conclusions of this annual EMP audit are based on the collation and consolidation of findings of the interim audits. This report only considers substantive works undertaken and audited during the 2016 audit period and information available for review during the audit period.

The audit of PDS 14 was undertaken by a Victorian EPA Contaminated Land Auditor (not operating within a statutory capacity) as reported in the Cardno Annual Soil Management Compliance Audit9. This annual EMP audit report relies on the information provided in the Cardno report. While the audit conduct and the results of the audit have not been verified by Helman Environmental they have been taken as a true and accurate record of the audit of PDS 14.

The audit adopted a graded assessment of compliance, following the PoM audit process, as follows:

• Conformance – activities comply with PCP EMP for Construction requirements

• Partial Non-Conformance – some activities do not comply with PCP EMP for Construction requirements

• Non-Conformance – activities do not comply with PCP EMP for Construction requirements

A finding of Non-Conformance or Partial Non-conformance may give rise to a Recommended Action, or an Improvement Opportunity. These may also be identified where full Conformance with the requirements of the EMP is determined, but a potential risk of a Non-Conformance is identified. A Positive Performance Recognition may also be identified. These categories are defined as:

• Recommended Action – Action to be undertaken to remedy or prevent a Non-Conformance or Partial Non-Conformance

• Improvement Opportunity – Action to be undertaken to improve environmental management or demonstration of conformance with PCP EMP for Construction requirements.

• Positive Performance Recognition – Recognition of actions or activities that exceed PCP EMP for Construction requirements or demonstration of Best Practice in environmental management.

9 Cardno Lane Piper. Annual Soil Management Compliance Audit. Port Capacity Project, Webb Dock, Port Melbourne, Victoria. March 2017 (Doc Ref 213159Report27.2)



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3 AUDIT FINDINGS AND CONCLUSION

3.1 Audit findings

The Interim Audits did not find any evidence of non-conformance with the notification requirements of Table 4 of the PCP EMP, or the requirements of the Project Delivery Standards relevant to the works being undertaken.

No Non-conformances or Partial Non-conformances were raised during the 2016 Interim Audits. A total of 13 minor audit findings were raised during the reporting period, comprising four Recommended Actions, and nine Improvement Opportunities. Nine findings related to PDS 14, with the other four findings related to the remaining PDS. The findings largely related to documentation and record keeping, with a minority of findings directly relevant to on-ground environmental management. None of the findings posed a risk to the environment or to effective environmental management.

All the audit findings from the 2016 audit period were closed out during the reporting period. The four audit findings which remained open from the 2015 audit period were closed out during the 2016 reporting period. Audit findings raised in this audit period and the findings which remained open from 2015 are provided in Appendix 1, together with the actions taken for close out.

PoM raised six Non-Conformances with the EMP during the 2016 reporting period. Four of the Non-Conformances were related to PDS 12 Stormwater and Groundwater Management, with three of the Non-Conformances associated with the uncontrolled discharge of stormwater. One Non-Conformance related to the management of groundwater. One Non-conformance related to PDS 15 Marine pests, and one to PDS 14 Contaminated material. All Non-Conformances were promptly reported to the relevant authorities as required by the EMP and did not result in harm or risk to the environment.

3.2 Audit conclusion

A summary of the compliance status of each element of the EMP in the audit scope is given in the following table.

EMP Ref Title Conclusion

2.3 Table 4 Notification and reporting requirements C

Table 5: Construction management (all activities) PDS

PDS 1 Hours of operation C

PDS 2 Construction airborne noise (except dredging) C

PDS 3 Construction airborne noise monitoring (complaints) C

PDS 4 Dust management C

PDS 5 Dust monitoring C

PDS 6 Waste management C



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EMP Ref Title Conclusion

PDS 7 Energy and greenhouse gases C

PDS 8 Equipment maintenance C

PDS 9 Fuels, oils, chemicals and hazardous goods C

PDS 10 Emergency response preparedness C

PDS 11 Heritage C

Table 6: Civil Works including Berthworks PDS

PDS 12 Stormwater and groundwater management PNC*

PDS 13 Decommissioned landfill site C

PDS 14 Contaminated material C

PDS 30 APA/WAG pipeline C

Table 7: Marine works including marine-based pile driving PDS

PDS 15 Marine pests C

PDS 16 Vessel bunkering C

PDS 17 Marine-based pile driving C

PDS 18 Cetaceans – vessel manoeuvring C

PDS 19 Cetacean sightings and log C

PDS 20 Heritage (marine-based) – identification of potential relics C

PDS 31 Temporary pad at Webb Dock West and Webb Dock Head C

PDS 32 Stormwater drain at Webb Dock Head C

Table 8: Dredging and dredged material management

PDS 21 Dredging C

PDS 22 Construction airborne noise C

PDS 23 Sediment sampling and analysis program C

PDS 25 Monitoring removal of contaminated sediments – backhoe and grab dredges C

PDS 26 Placement of dredged material at the PoM DMG C

PDS 27 Dredged material placement C

PDS 28 Capping of contaminated sediments at the PoM DMG NA

PDS 29 PoM DMG – maintenance and inspection (post-construction) NA

C: Complies PNC: Partial Non-conformance NA: Not applicable during the reporting period.

Notes: *PoM raised four Non-Conformances in relation to PDS 12. The Non-Conformances did not pose a risk of harm to the environment or to effective environmental management.

PDS 28 and 29 were removed from the EMP in Revision 3.



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Appendix 1: Audit findings and actions

PDS 1 – 13, 15 – 29 and 31 - 32 AUDIT FINDINGS (HELMAN ENVIRONMENTAL)

Legend: C – Conformance; N – Non-conformance; PNC – Partial Non-Conformance; IO – Improvement Opportunity; RA: Recommended Action; PPR - Positive Performance Recognition

Audit date

PDS Ref.

Finding No.

Finding Type

Finding Action Action status

Dec-15 9 1215/01 RA Fuels, oils, chemicals and hazardous goods. Small amounts of fuels and chemicals are held on the BMD site and generally stored appropriately. One unbunded jerry can of fuel was observed located on an unpaved surface. The minor volumes of fuel and chemicals at the site compound were stored appropriately, however the MSDS register did not include all items in the chemical store. All fuel and chemicals should be stored in bunded areas, and MSDS should be available for all chemicals held on site.

Sighted record of toolbox talk in 28/1/2016, noted subject of waste, MSDS, and hazardous substance containers raised. Included sign in sheet showing BMD and subcontractors attending.

Closed Mar-16

Mar-16 9 0315/01 IO Fuels, oils, chemicals and hazardous goods. The minor quantities of fuels and chemicals at the VICT works sites were generally stored appropriately. Several unbunded jerry cans of fuel and concrete curing agent observed in the Terminal Area, and an MSDS was not readily available for one chemical stored at the Hutchinson chemical store (Superdraulic 46). All fuel and chemicals should be stored in a bunded container, and MSDS should be readily available for all chemicals held on site.

The minor quantities of fuel and chemicals held on site were observed to be stored appropriately.

Closed Jul-16



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Audit date

PDS Ref.

Finding No.

Finding Type

Finding Action Action status

Jul-16 8 0716/01 IO Equipment maintenance. Plant Inspection Records for the Completion Work Package are not being maintained in the Plant & Equipment Register. The Register should be maintained to allow for tracking of servicing requirements.

The Plant & Equipment Register was sighted and is being maintained.

Closed Sep-16

Oct-16 9 0916/01 IO Fuels, oils, chemicals and hazardous goods. Several unbunded containers of diesel and form oil were observed around the VICT works site. All fuel and chemicals should be stored in a bunded container

Chemicals and fuel held on site were appropriately stored.

Closed Nov-16

Nov-16 7 1116/01 IO Energy and greenhouse gases, Fuel consumption is tracked, however electricity use at the Playscape site is not currently being tracked. Baron Forge should track the electricity used on site.

Sighted records of electricity used on site. Closed Nov-16

Nov-16 9 1116/02 IO Fuels, oils, chemicals and hazardous goods. Sikadur was held in the chemical store at the VICT site compound, however no MSDS was readily available on site. VICT should ensure that MSDS are readily available for all chemicals held on site.

PoM conducted an Environment Observation in December 2016 which noted that the SDS Register included documentation for all the chemicals checked.

Closed Dec-16



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PDS 14 AUDIT FINDINGS (CARDNO)

Completion Package

Audit date

SMMS reference

Aspect Finding type

Finding Actions Action Status

Dec-16 4.6 Off-site disposal of fill from which asbestos had been abated

RA Asbestos was encountered during works for Separable Portion 4 (SP4). - The asbestos was abated from the soil by a

licensed removalist and the soil was then loaded onto trucks for off-site disposal at a landfill (Hi-Quality landfill, Bulla). A hygienist’s clearance certificate (for the purposes of complying with OHS regulations) based on visual inspection, was issued for each truck prior to the soil being taken off-site.

- When this material was received at the landfill, the landfill operator (Hi-Quality Landfill) identified suspected asbestos and therefore quarantined the material and subsequently confirmed the presence of asbestos.

The landfill operator then disposed of the material in their cell licensed for the landfilling of asbestos. Given the advice of the landfill licensee Hi-Quality (email from Lance Ingrams of 8/12/2016) suggested that the issue be further discussed with the transporter (Fleet) and EPA Victoria, such discussion should be initiated by McConnell Dowell. The incident needs to be reported in the next monthly report and in the final soil report and should include a copy of correspondence from Hi-Quality confirming that the asbestos was managed in accordance with EPA regulations.

Hi-Quality has confirmed that the material was deposited into the designated asbestos waste cell. PoM, in place of MCD, have communicated this incident to EPA, who advised that further investigations regarding the transport of this material will be undertaken by EPA. The timing of the closure of this investigation is unknown and outside of the control of the independent third party reviewer and is expected to occur after the completion of the compliance audit for PCP. In consideration of the huge amount of soil being managed at the PCP site over the duration of 4 years, this single incident, which was managed responsibly and in good faith by the parties involved, can be closed out.

Closed Mar-17



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Audit date

SMMS reference

Aspect Finding type


Dec-16 4.4 Assessment report prepared by McConnell Dowell’s environmental subcontractor

IO An environmental assessment report, prepared by DRC Environmental (issue date of 28/11/2016), was reviewed during the audit and the following was noted: - The report does not provide a definitive and

unequivocal conclusion in regards to the findings of the assessment.

The chain of custody appended to the report does not include a sampler’s declaration in accordance with AS4482.1 The Chain of Custody template used by the assessor should show all information fields contained in Appendix I of AS 4482.1 including the “sampler’s declaration”. MCD to provide evidence for communication (e.g. in the form of an email) to the environmental subcontractor about the issues identified in their report in regards to the COC (including the subcontractor’s acknowledgement that they have received this communication).

It is acknowledged that the conclusion of the report has been revised based on the Preliminary Audit Findings provided during the Exit Meeting. A copy of the email communication between MCD and the environmental subcontractor was provided to the Auditor for review and has been considered to be appropriate.

Closed Dec-16



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Playscape Audit date

SMMS reference

Aspect Finding type


Dec-16 4.6 Off-site disposal of fill with asbestos: EPA waste transport certificate for 20m3 of soil with asbestos

RA On 3 December 2016 ATS, the asbestos removalist engaged by Baron Forge, removed approximately 20 m3 of fill with asbestos from the site. AST used their own licensed truck for the transport. There is no EPA waste transport certificate available for the off-site disposal of the fill with asbestos, although this is required for the transport of asbestos containing materials (PoM SMMS and relevant guidance therein, including EPA IWRG611.1, 2009, Asbestos Transport and Disposal and WorkSafe Victoria, 2010, Asbestos-contaminated soil). Baron Forge to provide evidence that a WTC was completed for the removal of this material and the WTC to be included in Baron Forge’s final soil report.

The Auditor sighted the completed WTC for the transport of fill with asbestos on 3 December 2016. A copy of the WTC has been included in Baron Forge’s final soil report.

Closed Feb-17

Dec-16 4.4 Assessment report prepared by Baron Forge’s environmental subcontractor

IO An environmental assessment report, prepared by Environmental Site Assessments (issue date of 25/10/2016), was reviewed during the audit and the following was noted: - The report is essentially a collection of

tabulated information and does not include a clear statement in plain English with the conclusion of the investigation undertaken.

- The report does not include a signatory page/section and there is no information provided in regards to who prepared and/or authorised issue of the report.

The chain of custody appended to the report does not include all relevant information (sampler’s declaration missing and complete trail of who relinquished the samples and who received them is not presented) in accordance with AS4482.1.

A copy of the email communication between Baron Forge and the environmental subcontractor was provided to the Auditor for review and has been considered to be appropriate.

Closed Feb-17



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Audit date

SMMS reference

Aspect Finding type


Baron Forge to provide evidence for communication (e.g. in the form of an email) to the environmental subcontractor about the issues identified in their report (including the subcontractor’s acknowledgement that they have received this communication).



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BMD/VICT

Audit date

SMMS reference

Aspect Finding type


Feb-16 4.6 Have any observations of suspected asbestos containing material (ACM) been made in soil or in connection with redundant services during the audit period?

IO ACM fragment was observed on the north west corner of the Gate Control Area on the 15 Dec 2015 at the base of a trench. The ACM consisted of a fragment of non-friable material. Prensa was engaged to collect the ACM sample for identification. Document and evidence is obtained from Prensa confirming that potential ACM fragments were collected and no residual suspected ACM were visible at the time of sampling. Also, Prensa to provide a confirmation that ACM samples were disposed as per current environmental guidelines for asbestos.

On the 11 April 2016 the Auditor was provided with a letter from Prensa, stating that a fragment of ACM has been removed from a trench in the north west corner of the Gate Control Area via sampling. The letter further stated that on 8th March 2016 a visual inspection of the final surface of the trench was undertaken by a competent person in relation to asbestos matter, and that no ACM was identified during this inspection. A copy of the corresponding EPA waste transport certificate, confirming appropriate off-site disposal of the asbestos, was provided to the Auditor for review on 3 May 2016.

Closed May-16

Feb-16 4.6 - Are records (EPA waste transport certificates) for off-site disposal of material containing suspected/known ACM available and include information about the type and volume of material taken off-site and the facility where the material was disposed at?

- Have any asbestos clearance certificates been issued and if so, provide an example?

IO While no asbestos containing waste had been disposed off-site during the audit period, an EPA waste transport certificate for asbestos (for 5 tonnes of ACM produced by Rafferty The Wrecker) was sighted for the audit period. This is inconsistent with the records of waste disposed off-site. Further clarification was requested in order to determine which period the EPA certificate is applicable for and the source of the ACM disposed off-site under this EPA certificate.

VICT/BMD provided clarification for the source of the asbestos disposed under the EPA waste transport certificate sighted during the audit. The asbestos source was a former substation. The corresponding asbestos removal clearance inspection certificates (for inspections undertaken on 16/11/2015 and 17/11/2015) were also provided for review.

Closed May-16



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Audit date

SMMS reference

Aspect Finding type


Feb-16 4.7 - Was an appropriate capping layer of clean fill or other appropriate covering used for the finished surface?

- Is there photographic evidence of the capping?

RA Appropriate surface capping was observed at the ECP and GCA areas. Photographic evidence was sighted for the soil placement area conducted on the north west corner of the ECP are on the 18 Feb 2016. The auditor noted that while no additional soil placement will take place on the soil mound at the ECP area, the soil mound has not had a final soil surface cover placed over it. The auditor recommends that expert advice be sought from a suitably qualified person for the final design of the mound with regards to stability (including the steep slopes on the northern batter) and associated erosion risks. The advice should also include details about the proposed soil surface cover layer.

Between 18 April 2016 and 29 June 2016 there was further communication between VICT and the auditor in regards to this close-out item. VICT provided a letter titled ‘Empty Container Park Stockpile Design and Stability’ (dated 12 May 2016) and further information (email of 26 May 2016). This information was satisfactory to close-out this item.

Closed June-16



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MIRRAT

Audit date

SMMS reference

Aspect Finding type


Dec-15 4.7 Were any finished surfaces that will not be covered by concrete generated during the audit period (e.g. buffers or other landscaping)?

RA Large rocks, concrete fragments and asphalt were visible in the capping layer of the Acid Sulfate Soils (ASS) permanent placement location. Remove this oversized waste material and exclude from future capping material for placement on mounds.

The Auditor sighted the December 2015 monthly report which included discussion with regards to the removal of excess large material on the 14 December 2015. The report also noted that following the removal of large materials the cap was re-instated. Photographic evidence was also sighted in the report.

Closed Feb-16

Dec-15 4.7 Was an appropriate capping layer of clean fill or other appropriate covering used for the finished surface.

RA While the final finished surfaces (proposed to be either topsoil, crushed concrete and/or cement stabilized sand) has not been placed on the ASS permanent placement areas, it was noted that the observed slopes are steep and prone to settlement, cracking and resultant erosion and exposure of the treated ASS. Seek expert advice with regards to the appropriateness of batter gradients and associated erosion risks for the capping layer and finished surfaces, and explore solutions for the management of slopes including batter stabilization.

The Auditor sighted documentation from Three Acres Landscape Architects which had the proposed landscape design (Drawing planning No. 15122, DWG No.: L203) dated 02 July 2015. Additional document was sighted which consisted of a correspondence from CPB Contractors (formerly Leighton Contractors) to Worley Parsons describing the soil physical properties and the intended landscape design. An engineer from Worley Parsons provided advice that based on the soil’s physical properties and in relation to potential erosion risks the proposed design was suitable.

Closed Feb-16

Dec-15 4.4 Are details of treatment prior to reuse or disposal of soil, where required, included in the summary report?

IO The October 2015 monthly report was reviewed and it was noted that there was no discussion with regards to treatment and to reuse of ASS. However, all records are available providing evidence of treatment, location of placement including photographic evidence. A proposed action will be recommended is that the details of treatment and reuse should be included in future summary report. It is recommended that the details of treatment and reuse to be included in future summary report.

The Auditor sighted the December 2015 monthly report which included a section with details about Acid Sulfate Soil (ASS) management. The report noted any changes observed where PASS was placed including photos and relevant observations regarding ASS.

Closed Feb-16



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Audit date

SMMS reference

Aspect Finding type


Feb-16 4.7 - Was an appropriate capping layer of clean fill or other appropriate covering used for the finished surface?

- Is there photographic evidence of the capping?

RA The Auditor notes that all 3 mound areas where CASS was permanently placed have been completed with various types of capping. Documents sighted by the Auditor show that the design of the mounds was provided by an engineer employed by CPB Contractors and its suitability in terms of stability and erodibility was endorsed by an engineer employed by Worley Parsons. It is recommended that a suitably qualified person verify in writing that the mounds have been constructed in accordance with the approved design. The design documents need to be properly referenced in this letter. This will provide assurance that the finished surfaces have been constructed in accordance with the approved design.

A copy of the as built verification record of the landscape mounds should be provided to the Auditor for review. On 9th September 2016 the Auditor received supporting documents in regards to this Recommended Action about the 3 mounds. The Auditor reviewed the supporting documents and concluded that they are satisfactorily to close the Recommended Action.

Closed Sept-16

Helman Environmental Consulting Ph //+61 3 9489 7957 M//0409 004 714 PO Box 314 Clifton Hill Vic 3068 [email protected] www.helmanenvironmental.com.au ABN 71 122 751 955