the Southern Plumes (from the former Solvents Plant and former Trichloroethylene (TCE) Plant);

Transcription

1 1 Introduction Introduction CHAPTER Background to the Project URS Australia Pty Ltd (URS) has been commissioned by Orica Australia Pty Ltd (hereafter referred to as Orica or the Proponent ) to prepare this Environmental Impact Statement (EIS) in relation to the construction and operation of the Botany Groundwater Cleanup Project (BGC Project) to be located at Banksmeadow, New South Wales (refer to Figures 1.1 and 1.2). The BGC Project provides for hydraulic containment and treatment of the contaminated groundwater plumes identified in the Notice of Clean Up Action (NCUA) issued by the EPA on 26 September These plumes lie within the geological formation known as the Botany Sands Aquifer Groundwater Contamination History In the early 1980s, during construction works on land between the Botany Industrial Park (BIP) and Southlands, high levels of organic contamination were found in the shallow groundwater. Subsequent tests of wells installed to the south-west of the BIP detected volatile chlorinated hydrocarbons (CHCs), leading to the Stage 1 Environmental Survey of the Botany Complex in 1989/90. Subsequent environmental investigations in the 1990s identified CHC contamination in shallow and deep groundwater in a number of areas around the BIP and in the vicinity of Southlands. Further investigation and groundwater monitoring works through the 1990s and early 2000s, as detailed in Chapter 2, identified several plumes of CHCs moving generally toward Botany Bay: the Southern Plumes (from the former Solvents Plant and former Trichloroethylene (TCE) Plant); the Central EDC Plume (from the former ethylene dichloride (EDC) Storage Tanks); and the Northern Plumes, comprising: a carbon tetrachloride (CTC)/tetrachloroethene (PCE) plume (from the former CTC/PCE Storage Tanks); and other plumes, containing predominantly 1,2 dichloroethane (EDC) (from wastes storage and handling activities in the northern part of the BIP). These previous investigations also identified a number of inferred contaminant source areas around the BIP and Southlands. These source areas (small underground pools of concentrated contaminant) are referred to as Dense Non-Aqueous Phase Liquid (DNAPL). As the groundwater flows past these pools, it becomes contaminated. The investigations and monitoring have revealed an extensive and complex distribution of contaminants derived from multiple source areas, which have developed overlapping plumes, both horizontally and vertically. In some instances, these plumes are mobile, moving at or near to the same rate as groundwater. Botany Groundwater Cleanup Project Environmental Impact Statement 1-1

2 CHAPTER 1 Introduction In February 2000, Orica entered into a Voluntary Remediation Agreement (VRA) with the NSW Environment Protection Authority (EPA), under the Contaminated Land Management Act 1997, which formalised Orica s existing and proposed containment and remediation activities to address the contaminant plumes. The activities under the VRA include: further source area investigations; ongoing monitoring of surface water, groundwater contamination and movement, air emissions and human health risk assessment; and the assessment, development and implementation of remediation approaches, including reactive iron barriers and in situ bioremediation. Annual reports under the VRA were prepared and submitted to the EPA, with the third Annual Report issued on 27 February High concentrations of CHCs in the Herford Street, Banksmeadow, production bore were noted in mid This, together with the EPA s concerns regarding the movement of the high concentration Central Plume and the potential discharge of contaminants to Botany Bay, led the EPA to issue an NCUA (reference number ), under section 91 of the Protection of the Environment Operations Act 1997, on 26 September 2003, to set a framework and timescale for action to contain the contaminant plumes. In response to the NCUA, Orica submitted its draft Groundwater Cleanup Plan (GCP) to the EPA, and commenced work implementing proposed actions. The EPA then issued Orica with a Variation to the initial NCUA (reference number ), authorising and requiring the implementation of the GCP. 1.2 The Proponent The proponent for the BGC Project is Orica Australia Pty Ltd. Following the subdivision of the Orica owned lands in 1998/99 to form the Botany Industrial Park (BIP), Orica s only remaining wholly-owned operation on the BIP is the Chlor-Alkali Plant. Qenos Pty Ltd, which runs the Olefines Plant, the two Alkatuff and Alkathene (Polythene) Plants and the Site Utilities Plants, is a 50:50 joint venture between Orica and Exxon Mobil. Orica also manages the site legacy issues, retained from ICI Australia when ICI plc sold its majority shareholding in ICI Australia in 1997, and retains full ownership of Block 1 and Block 2 of Southlands. Today, Orica supplies and manufactures industrial specialty chemicals, agricultural chemicals and fertilisers, explosives and mining chemicals, and plastics and paints. As an independent company, Orica has approximately 40 major operating sites in 14 different countries. Within New South Wales, Orica operates three major sites at Botany, Padstow and Newcastle (Kooragang Island) Regulatory Action Notice of Clean Up Action The original NCUA was issued by the EPA (now part of the Department of Environment and Conservation (DEC)) on 26 September A variation was issued on 17 February 2004, on the basis that: 1-4 Botany Groundwater Cleanup Project Environmental Impact Statement

3 Introduction CHAPTER 1 The EPA expects the remediation and investigation actions currently underway or planned for Stage 4 of the Voluntary Agreement to continue, but issues this notice (a) to ensure additional measures are taken for the more immediate containment of the contaminant plumes prior to the implementation of the treatment measure required by this notice and under the voluntary agreement; and (b) in the light of the results of the more recent monitoring data, to set revised targets for the reduction in the concentrations of the substances in the contaminant plumes. These notices are collectively referred to in this document as the NCUA. The first requirement of the NCUA was the preparation and implementation of a Groundwater Cleanup Plan (GCP), to be approved by the EPA. The NCUA is presented in full in Appendix A. Groundwater Cleanup Plan In response to the EPA s original notice, Orica prepared the Groundwater Cleanup Plan (GCP) that was submitted to the EPA on 31 October 2003, detailing the activities and actions to be implemented to address the requirements of the EPA. The areas identified in the NCUA and the GCP are as follows: Primary Containment Area (PCA): Block 2 of Orica Southlands. The main contaminant plume beneath this area is the Central EDC Plume. Secondary Containment Area (SCA): Located along Foreshore Road (hydraulically down-gradient of the PCA). The SCA is designed to intercept the high concentration core of the Central EDC Plume before it reaches Botany Bay or Penrhyn Estuary. Dense Non-Aqueous Phase Liquid (DNAPL) Contaminant Source Areas: A number of inferred areas around the BIP and Southlands. The GCP identifies activities and actions for containment in the short term and remediation in the longer term to achieve the timeframes defined by the NCUA. These various activities and timeframes are presented in more detail in Chapter 2. At the time of the preparation of the GCP (October 2003), Orica was investigating in situ treatment technologies, such as enhanced bioremediation and permeable reactive iron barriers, rather than ex situ treatment technologies. Bioremediation field trials were implemented on Southlands Block 2 to assess the potential effectiveness in delivering contaminant containment, with full-scale bioremediation works proposed along Foreshore Road and on the Botany Golf Course (within the SCA). At the time of the preparation of this EIS, the bioremediation trials on Southlands Block 2 are continuing and will be completed as a separate exercise with a view to possible subsequent application. The project modules within the GCP for full-scale application of bioremediation have been suspended. The BGC Project is currently the primary approach for achieving the required contaminant containment and treatment of the groundwater as specified in the NCUA. Botany Groundwater Cleanup Project Environmental Impact Statement 1-5

4 CHAPTER 1 Introduction The Botany Groundwater Cleanup Project The BGC Project is an extensive project with many inter-related components, including the Activity (which is described below), and other components which have been or will be separately approved and constructed to achieve the requirements of the NCUA. While this EIS is required only in respect of the Activity, it does consider the potential cumulative impacts of the overall BGC Project, including potential construction impacts for all those components yet to be constructed, and the potential impacts associated with the full operation of the BGC Project from groundwater extraction, through transfer, treatment and reuse/discharge. The following elements of the BCG Project comprise an activity ( the Activity ) for the purposes of Part 5 of the EP&A Act, for which approval will be supported by the assessment in this EIS: the extraction of groundwater from the wells installed in the three containment lines (primary, secondary and DNAPL); transfer of groundwater via pipelines to the Groundwater Treatment Plant (GTP); construction and operation of the GTP; transfer of treated water via pipelines to Botany Industrial Park (BIP) users or Bunnerong Canal and waste water to sewer ; and installation of a discharge point into Bunnerong Canal. There are a number of determining authorities for various aspects of the Activity. The environmental impact of the BGC Project (which includes the Activity) is assessed in this EIS. The broad objective of the BGC Project is to achieve hydraulic containment and reduction of the contaminants in the groundwater in and around the BIP, to meet the requirements of the NCUA. The groundwater will be extracted from the PCA, the SCA and the DNAPL containment line, and will be transferred to the GTP via three pipelines, as shown in Figure 1.3 and described below. Primary Containment Area: Extraction of groundwater from wells installed in Southlands and transfer of the groundwater in the primary pipeline to the GTP located on the BIP; Secondary Containment Area: Extraction of groundwater from wells installed on the median strip of Foreshore Road and transfer of the groundwater in the secondary pipeline to the GTP located on the BIP; DNAPL Containment Line: Extraction of groundwater from wells installed along and parallel to the western boundary of the BIP toward the northern end, and transfer in the DNAPL pipeline to the GTP located on the BIP; Groundwater treatment, using various liquid and gaseous process technologies in the GTP located on the BIP, to achieve a treated water quality based on the ANZECC Guidelines for marine water quality (ANZECC, 2000), Australian Drinking Water Guidelines (NHMRC & ARMCANZ, 2003), and process standards for BIP reuse; and Transfer of treated groundwater for use in process operations across BIP, with excess discharged to Botany Bay via Brotherson Dock, through a discharge pipeline into Bunnerong Canal. 1-6 Botany Groundwater Cleanup Project Environmental Impact Statement

5 CHAPTER 1 Introduction The GTP is a key part of the overall BGC Project. The potential cumulative impacts of the project are considered within this EIS. The design of the GTP is based on a total groundwater extraction rate of up to 15 ML/day across the three identified areas. The extraction rates for each area are estimated as: 3.38 ML/day groundwater from the Primary Containment Area; 2.45 ML/day groundwater from the Secondary Containment Area; and 9.17 ML/day groundwater from the DNAPL containment line. These extraction rates can be varied (within the design limit) as required, to respond to changes in groundwater movements and contaminant concentrations. Such changes would be monitored through the monitoring wells installed alongside the extraction wells (discussed in Chapter 12) Project Area The Project Area is located on land extending generally from Botany Bay in the south to the BIP in the north (refer Figure 1.3) Prior Element of BGC Project: Steam Stripping Unit Recommissioning Under approvals granted earlier in 2004 by various determining authorities and land owners, and to enable Orica to meet its obligations under the NCUA, Orica has recommissioned an existing Steam Stripping Unit (SSU) to enable the interim extraction and treatment of groundwater. These interim works have also required the following: installation of groundwater wells in the primary and secondary containment areas; transfer pipelines from the wells to the SSU; temporary storage of recovered waste EDC liquid in an existing EDC storage tank, at Terminals Pty Ltd s licensed bulk liquids storage facility at Port Botany; installation of a transformer on NSW Maritime Authority land south of Foreshore Road, to provide power to the secondary containment pumps. The EIS will provide a description of these interim works and will assess their cumulative impacts of their operation as part of the BGC Project. The SSU treatment process will recover from the groundwater approximately 500 tonnes of chlorinated hydrocarbons (CHCs) liquid, containing predominantly EDC. It will operate for a period of around 12 months, until the GTP is operational. This recovered waste EDC liquid will be temporarily stored in Terminals Pty Ltd s existing facility at Port Botany, and will subsequently be transported to the GTP site for treatment in the process alongside the contaminated groundwater, over an extended period of time (as discussed in Section 5.5.2). 1-8 Botany Groundwater Cleanup Project Environmental Impact Statement

6 Introduction CHAPTER Environmental Impact Assessment Process NSW Process Under State Environmental Planning Policy No. 55 Remediation of Land (SEPP 55), the BGC Project does not require development consent. Therefore, the various elements of the BGC Project must be assessed under Part 5 of the EP&A Act, since Part 5 of the Act provides for the assessment of proposals that do not require development consent. Under Part 5 of the EP&A Act, section 111 provides for a duty to consider environmental impacts by the relevant determining authority(ies). Section 112 of the Act requires an environmental impact statement for an activity which is likely to significantly affect the environment or threatened species, populations or ecological communities or their habitats. This EIS has been prepared in order to assess the potential environmental impacts of the Activity (as defined in Section 1.2.2), as well as the cumulative impact of the operation of the whole of the BGC Project Commonwealth Process The Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) provides for Commonwealth jurisdiction over matters of national environmental significance, which include impacts on Ramsar wetlands, migratory bird species and threatened species. The Act requires an assessment of the potential impacts of a project on these matters of national environmental significance. If a project is likely to have a significant impact on matters of national environmental significance, it is deemed a controlled action and approval is required from the Commonwealth. An assessment was conducted for this project and is discussed in detail in Chapter 20. A referral under the EPBC Act will be lodged with Environment Australia, seeking confirmation that the BGC Project is not a controlled action State Environmental Planning Policy (SEPP) 55 Remediation of Land The objective of SEPP 55 is to provide for a state-wide planning approach to the remediation of contaminated land and to promote the remediation of contaminated land for the purpose of reducing the risk of harm to human health or any other aspect of the environment. In order to facilitate the cleanup and remediation of contaminated land under nominated cleanup notices, SEPP 55 was amended on 30 July 2004 to allow works that are required by an NCUA to proceed without development consent. The relevant clause in SEPP 55 is as follows: 21. Clean Up notice remediation special provision (1) This Policy does not apply to or in respect of anything done for the purpose of complying with a cleanup notice, except as provided by this clause. Botany Groundwater Cleanup Project Environmental Impact Statement 1-9

7 CHAPTER 1 Introduction (2) Any development or activity carried out for the purpose of complying with a cleanup notice: (a) may be carried out without development consent, and (b) to the extent that it involves carrying out any remediation work, must be carried out in accordance with clause 17 (1) (paragraph (c) excepted). (3) In this clause, cleanup notice means: (a) a notice given under section 91 of the Protection of the Environment Operations Act 1997 that is specified in Schedule 1, or (b) if a notice so specified has been varied under section 110 of that Act, the notice as varied for the time being. (4) If this clause is inconsistent with another State environmental planning policy, a regional environmental plan or a local environmental plan (whether made before or after this clause), this clause prevails, subject to section 36 (4) of the Act. Schedule 1 lists Notice No dated 26 September 2003 and addressed to Orica Australia Pty Ltd, and hence this clause applies to the BGC Project, which can be implemented without development consent. The amended SEPP 55 is presented in full in Appendix B Planning Focus Meeting A Planning Focus Meeting (PFM) was held at Orica s offices at the BIP on 3 June 2004, and was attended by representatives of relevant NSW statutory authorities and the Council of the City of Botany Bay. The PFM provided a forum for discussion of the BGC Project and consideration of issues to be addressed by the EIS, which were to be formalised through the requirements of the Director-General of Infrastructure, Planning and Natural Resources. A request for these requirements for this EIS was made in June The Director-General s Requirements (DGRs) were issued on 12 July 2004, and are presented in Appendix C. The amendment to SEPP 55 was gazetted after the PFM and issue of the DGRs. The scope of the EIS was subsequently revised, and modifications made to the rate of groundwater extraction and the location of the GTP within the BIP. The scope of the EIS was further clarified to DIPNR following a change in the design limits and location of the GTP. The Director-General affirmed its requirements by a letter dated 1 November 2004 (see Appendix C) EIS Preparation and Exhibition This EIS has been prepared in accordance with Part 5 of the EP&A Act, under the provisions of Schedule 2 of the EP&A Regulation, which lists the matters to be addressed in an EIS Botany Groundwater Cleanup Project Environmental Impact Statement

8 Introduction CHAPTER 1 The EP&A Act requires that the EIS be placed on exhibition for public review for a minimum period of 30 days. 1.4 Related Investigations Eight detailed investigations relevant to this EIS were completed by specialists. These investigations were used as source materials for this EIS. Separate reports have been developed and included in full as appendices to this EIS. The investigations addressed the following issues: Hydraulic containment of groundwater (Appendix D); Hydraulic assessment of Bunnerong Canal (Appendix E); Acoustic assessment (Appendix F); Air quality impact assessment (Appendix G) Ecological impact assessment (Appendix H); Preliminary Hazard Assessment (Appendix I); and Human Health Risk Assessment (Appendix J). 1.5 Document Structure This EIS is divided into eight parts. The content of each part is outlined below: Project Background Part A (Chapters 1 and 2) briefly outlines the environmental impact assessment process, describes the background and context of the project, and provides an outline of the project. The Project Part B (Chapters 3 to 5) details the project needs, objectives and alternatives and provides a detailed description of the project. Statutory and Strategic Planning Part C (Chapter 6) contains a discussion of the relevant controlling Commonwealth and NSW legislation, and nominates the approvals required to enable the proposed BGC Project to proceed. Issues Identification and Prioritisation Part D (Chapters 7 to 9) summarises the issues raised during consultation with statutory and other relevant authorities, and the local community. The issues raised during the consultation process are then prioritised for discussion in the following chapters of the EIS. Environmental Impact Assessment Part E (Chapters 10 to 26) describes the existing environment, provides an assessment of the likely impacts of the project, and identifies appropriate mitigation measures to safeguard the environment. The cumulative impacts of the BGC Project are also addressed. Botany Groundwater Cleanup Project Environmental Impact Statement 1-11

9 CHAPTER 1 Introduction Environmental Management and Monitoring Part F (Chapters 27 and 28) outlines Orica s proposed environmental management measures to safeguard against any potential impacts, and describes ongoing monitoring activities. Justification Part G (Chapters 29 and 30) addresses the principles of Ecologically Sustainable Development (ESD) and provides the justification for the BGC Project. References Part H provides a list of materials referenced during preparation of the EIS Botany Groundwater Cleanup Project Environmental Impact Statement

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13 2 Location and Context Location and Context CHAPTER Site Location and History Site Location The BGC Project incorporates a number of activities on and in the vicinity of the BIP. The overall Project Area is located on lands largely enclosed within the boundary of the Department of Infrastructure, Planning and Natural Resources (DIPNR) Groundwater Extraction Exclusion Area, as shown in Figure 2.1. The Botany Sands Aquifer is classified as a high risk resource by DIPNR in terms of groundwater quality down-gradient of the BIP. DIPNR has given a direction not to use the groundwater until further notice. Similarly, issue of any new bore licences for groundwater extraction is restricted, except for cleanup and construction activities. The BIP is located within the Botany/Randwick industrial area to the north-east of Botany Bay, east of Sydney Airport and approximately 12 km south of the Sydney Central Business District (CBD). The blocks of land known as Southlands are owned by Orica, and are located just to the south-west of the BIP, with the Sydenham Botany goods railway line dividing the two (refer Figure 1.2 ). The proposed location of the GTP is on land owned by Orica within the BIP, previously the site of a Silicates Plant. The locations of other components of the BGC Project are: groundwater wells on Blocks 1 and 2 of Southlands; transfer (primary) pipeline for extracted groundwater from the wells on Southlands to the GTP on BIP; groundwater wells within the median strip of Foreshore Road; transfer (secondary) pipeline for extracted groundwater from the wells on Foreshore Road to the GTP; groundwater wells on the western boundary of the BIP; transfer (DNAPL) pipeline for extracted water along and parallel to the western boundary of the BIP; treated water distribution pipelines across the BIP; and transfer pipeline for treated water from the BIP to the Bunnerong Canal. The works associated with these components are subject to separate approvals and permits (as discussed in Chapter 6). The full operation of the BGC Project would integrate the operations of each of these components and the GTP. Details of the design, construction and operation of the BGC Project are described in Chapter 5. Botany Groundwater Cleanup Project Environmental Impact Statement 2-1

14 Location and Context CHAPTER 2 Land uses in and around the Project Area include: Industrial: The area is one of Sydney's main industrial regions, and a range of other industrial sites lie within a 2 km radius to the south, north, west, and north-west of the BIP, including the Mobil Oil Terminal, Kellogg s, Solvay Interox, Nuplex Industries Australia Pty Ltd, and Amcor; Infrastructure: There are a number of major infrastructure facilities in the vicinity of the BIP, with the Sydenham Botany goods railway line running along one boundary, Sydney Airport about 3 km to the west of the site and Port Botany to the south on the edge of Botany Bay; Residential/Retail: Principal residential areas are located to the north, east and west, with Banksmeadow and Pagewood to the north-west; Hillsdale, Matraville and Maroubra east of Denison Street; Botany residential area to the west, and Eastgardens shopping complex to the north-east; and Open Space: As well as a number of golf courses, parks and reserves, the area includes Penrhyn Estuary, to the south-west of the BIP; Botany Bay, located about 1 km to the south; and Botany Wetlands, located about 2 km north-west Site History Botany Industrial Park Industry was first established in the area from about the turn of the 20th century. The first industries were mainly tanneries, fellmongeries, wool scourers and a paper mill. The 1920s and 1930s saw the first establishment of major industries including Davis Gelatine, Kelloggs and Johnson & Johnson. Many of the chemical industries, including ICI and the then A C Hatrick, were established in the 1940s. Manufacturing began at the south end of what is now known as the BIP in 1942 under wartime conditions. The range of products manufactured increased rapidly in the early post-war years, when commodities of all types continued to be in short supply throughout the world. The 1960s saw the introduction of larger manufacturing plants and the Botany site became what is now known as a petrochemical complex. The development shifted toward the north end of the site and the area progressively developed as manufacturing plants were modernised, replaced or closed. Particular manufacturing operations that have since closed down include trichloroethene (TCE) and ammonia in the 1970s, Olefines I in the 1980s, and chlorinated solvents (carbon tetrachloride (CTC), tetrachloroethene (PCE) and EDC) and sodium silicates in the 1990s. The BIP incorporates approximately 73 hectares previously owned by Orica. Three principal companies now share the BIP, with a number of others providing additional services. Botany Groundwater Cleanup Project Environmental Impact Statement 2-3

15 CHAPTER 2 Location and Context In 1998, the site was subdivided to create the BIP. The principal plants now operating on the BIP, as shown on Figure 2.2, comprise: Qenos Olefines Plant, to the north of the site; Qenos Alkathene and Alkatuff Plants, in the central part of the site; Huntsman Surfactant Plant, at the southern part of the site; Orica Chlor-Alkali Plant, to the south-east of the site; and Qenos operated Site Utilities, including steam and effluent plants on the west side of the site. In addition, a number of tenants occupy portions of the site. Southlands Southlands (Block 1 and Block 2) is located just to the south-west of the BIP. It occupies a region once known as Veterans Swamp, part of the Botany Swamps that formed an important part of Sydney s water supply in the 1830s and 1840s. As water was drained, peat lenses were exposed, and peat cutting and sand extraction was carried out on a commercial basis into the mid 20th century. The pits and ponds resulting from the peat excavation (some of which remain on Block 1) were subsequently used for dumping of bottom end furnace ash from coal-fired boilers used by industry in the area (including Bunnerong Power Station). In the 1950s Southlands was acquired by Australian Paper Manufacturers (APM), and the site was used for the discharge of paper waste slurries and for the storage of waste paper. It was then purchased by ICI in 1980, providing a buffer between its Botany operations and the commercial and residential development to the west. 2.2 The Groundwater Issue Overview An extensive chronological history of the groundwater issue and the activities undertaken by various parties to investigate, assess and address the issue is presented on the Orica Botany Groundwater Site website, at Botany Groundwater Cleanup Project Environmental Impact Statement

16 CHAPTER 2 Location and Context This history is briefly summarised in Table 2.1, which provides the historical context for the regulatory activities and proposed works to be undertaken. Table 2.1 Summary history of the groundwater issue Dates Activities 1970s Potential contamination of groundwater by organic chemicals reported following initial investigations. 1980/81 High levels of organic contamination found in shallow groundwater during excavation work on State Rail Authority (now RailCorp) land between the BIP and Southlands. 1989/90 Stage 1 Environmental Survey of the BIP undertaken by ICI (now Orica). Survey identified volatile chlorinated hydrocarbons (CHCs) in soils, groundwater, surface water and sediments, and semi-volatile CHCs in soils, sediments and biota. Identified CHCs were all related to present and past products and by-products produced on the BIP. 1993/96 Second Stage of the Environmental Survey carried out, providing further information on the extent of CHC contamination. The second stage included the formation of the Community Liaison Committee for consultation with local communities, and initial evaluation of potential remediation strategies for cleanup of the contamination. Nov 1996 Third Stage of the Environmental Survey initiated. ICIA issued a proposed Stage 3 Remediation Plan to the NSW EPA. The third stage works included routine monitoring of groundwater, surface water, air and biota, and feasibility assessment of remediation technologies. Mar 1997 Mar 1998 Feb 1999 May 1999 June 1999 Feb 2000 Oct 2000 Feb 2001 Feb 2002 Aug 2002 Feb 2003 Consolidated Groundwater Report issued to the EPA, which included recommendations for further investigations and ongoing groundwater monitoring. First signs of Central EDC Plume migration detected on Southlands. Installation of pilot-scale reactive iron barrier to assess effectiveness in degrading volatile CHCs at elevated concentrations. NSW EPA directed Orica to identify options for containment of central EDC plume. Updated Consolidated Groundwater Report issued to the EPA, which reported three main plume groups: the Northern, Central and Southern Plumes. Orica entered into a Voluntary Investigation and Remediation Agreement (VRA) with the EPA under the Contaminated Land Management Act The VRA formalised the ongoing monitoring, investigation and remediation assessment activities being undertaken. Results from pilot-scale reactive iron barrier confirmed technology as appropriate for remediation of CHC contamination (not including EDC). First annual report under the VRA issued to the EPA. Second annual report under the VRA issued to the EPA. Development Application (DA) submitted to the Council of the City of Botany Bay for bioremediation field trials. Third annual report under the VRA issued to the EPA. 2-6 Botany Groundwater Cleanup Project Environmental Impact Statement

17 Location and Context CHAPTER 2 Dates Activities Mar 2003 July 2003 DA for bioremediation field trials approved by the Council of the City of Botany Bay. High concentrations of CHCs noted in the Herford Street, Banksmeadow production bore. Sept 2003 EPA issued Orica with a Notice of Clean Up Action (NCUA), reference number Oct 2003 In response to the NCUA, Orica submitted its draft Groundwater Cleanup Plan (GCP) to the EPA, and commenced work implementing proposed actions. Feb 2004 The EPA issued Orica with a Variation to the NCUA (reference number ), authorising and requiring the implementation of the GCP The Groundwater Cleanup Plan The GCP (October, 2003) was prepared in response to the NCUA, and presents the proposed actions to be implemented in response to each of the NCUA s major elements. Given the nature of the groundwater issue and the challenging requirements and time frames in the NCUA, the GCP was necessarily complex. Multiple options needed to be considered and, in many cases, possible parallel implementation of options needed to be reviewed and revised as appropriate at key milestones. The content of the GCP is summarised in the following sections, with the full document available on the Orica Botany Groundwater Site website, at The context of the BGC Project within the overall GCP is shown in Figure 2.3. Primary Containment Area The NCUA requires hydraulic containment and maximum reduction of concentrations in the PCA (target 80% by 31 October 2005), including use of ex situ treatment. The GCP included a number of options for short-term and long-term hydraulic containment and treatment: trial of groundwater extraction for short-term off-site disposal at Waste Service NSW s Lidcombe Liquid Treatment Plant; recommissioning of the former Vinyls Plant effluent stripping equipment (the Steam Stripper Unit (SSU)) on the BIP, to process extracted groundwater in the short term (with recovery of CHCs for subsequent treatment/disposal); active bioremediation trials, to assess the long-term effectiveness of in situ treatment providing full scale contaminant containment; and long-term implementation of full scale hydraulic containment (groundwater extraction) and ex situ treatment (in the proposed groundwater treatment plant). Secondary Containment Area The NCUA requires establishment of a secondary containment area for contamination that has migrated, or may migrate, from the primary containment area by 31 October Botany Groundwater Cleanup Project Environmental Impact Statement 2-7

18 Location and Context CHAPTER 2 The GCP proposed parallel implementation of various bioremediation and hydraulic containment/ex situ treatment projects: passive bioremediation barrier along Foreshore Road; active bioremediation barrier on Botany Golf Course (to be implemented in addition to a passive bioremediation barrier); and in the event of the bioremediation trials not being proven in time, secondary containment by groundwater extraction and treatment, in the SSU in the short-term, and in the proposed groundwater treatment plant in the long-term. DNAPL Identification, Containment and Removal The NCUA requires Orica to identify all DNAPL source areas on Orica premises by 31 May 2004, containment of all sources by 30 November 2004, and removal of identified sources areas to the extent practicable by 31 October The GCP proposed a number of actions to meet these requirements: staged approach for investigation of each inferred source area; implementation of appropriate options for contaminant containment, to be in situ wherever practicable, including bioremediation barriers, permeable reactive barriers, and hydraulic containment, as well as ex situ treatment (in the proposed groundwater treatment plant). It is noted that the GCP assumed DNAPL containment to be containment of dissolved phase contamination from DNAPL source areas. Monitoring The NCUA requires implementation of a comprehensive monitoring program within an area defined in the NCUA. The GCP proposes a detailed monitoring program to deliver this objective, including measurement protocols for assessing conditions against the ANZECC guidelines. 2.3 Proposed Groundwater Containment and Treatment Activities Short-term Containment/Treatment Off-Site Treatability Trials In the GCP, the first proposed short-term containment and treatment option for management of the Central EDC Plume was extraction and off-site treatment at NSW Waste Service s Lidcombe Liquid Treatment Plant. Botany Groundwater Cleanup Project Environmental Impact Statement 2-9

19 CHAPTER 2 Location and Context The initial treatability trials were undertaken in early 2004 to assess the feasibility of groundwater extraction at Southlands Block 2 and treatment at Lidcombe, with the potential to proceed as a short-term measure for groundwater containment and treatment in the event that the trials proved successful. Although the trials were completed successfully, it was concluded that this was not a viable ongoing treatment option, because there were problems with HCl emissions from the Lidcombe Treatment Plant s odour control system during treatment of the groundwater. Accordingly, this EIS does not assess off-site treatment impact at Lidcombe. Interim Containment: Steam Stripping Unit A second short-term containment and treatment option presented in the GCP was the recommissioning of the former Vinyls Plant effluent stripping equipment (the Steam Stripper Unit (SSU)) on the BIP, to process extracted groundwater and recover CHCs for subsequent treatment/disposal. This option had been implemented at the time of the preparation of this EIS, with transfer pipelines and groundwater wells installed on Southlands and at Foreshore Road, to enable extraction of initially 300 kl/day (increasing to 2,000 kl/day) of groundwater from the Primary Containment Area and the Secondary Containment Area for treatment in the SSU. The steam stripping process would transfer the organic contaminants from the groundwater to the steam, which in turn would be condensed to form a recovered CHC liquid, containing predominantly EDC. The SSU and associated infrastructure became operational in late October 2004, and is intended to operate until the proposed GTP is operational. It would then be shut down, and the groundwater transferred directly to the GTP for treatment. The estimated 500 tonnes of recovered waste EDC liquid generated by the process would initially be stored in the existing tanks adjacent to the SSU, then transferred to an existing aboveground storage tank located in Terminals Pty Ltd s bulk liquids storage facility at Port Botany. As described in Chapter 5, the stored recovered waste EDC liquid would subsequently be progressively transported back to the GTP once commissioned for processing with the extracted groundwater Bioremediation At the time of the preparation of the GCP, Orica s preferred approach (wherever proven and practical) was to use the in situ treatment technologies of enhanced bioremediation and permeable reactive iron barriers, rather than ex situ treatment technologies. Under a DA approved by the Council of the City of Botany Bay in March 2003, bioremediation field trials were implemented on Southlands Block 2 to assess the potential effectiveness of the in situ treatment to achieve contaminant containment and treatment for the PCA. Depending on the results of these trials, further works were planned for passive bioremediation (along Foreshore Road) and active bioremediation (on the Botany Golf Course) for the SCA. The development of the bioremediation works were to be undertaken in parallel to the development of the BGC Project, and Orica and the EPA would subsequently assess and agree on the best approach (i.e. either bioremediation or the GTP) for achieving the required containment and treatment Botany Groundwater Cleanup Project Environmental Impact Statement

20 Location and Context CHAPTER 2 However, at the time of preparation of this EIS, the bioremediation trials on Southlands Block 2 have not been concluded and the GTP is now the primary approach being implemented by Orica to achieve containment of the contaminant plumes and to prevent discharge into Botany Bay, in order to meet the requirements of the EPA s NCUA Full Scale Hydraulic Containment The full scale hydraulic containment comprises the extraction of groundwater from the primary, secondary and DNAPL containment lines for ex situ treatment in the GTP. 2.4 The Planning Context The BGC Project is an extensive project with many inter-related components, including the Activity (which is described below), and other components which have been or will be separately approved and constructed to achieve the requirements of the NCUA. While this EIS is required only in respect of the Activity, it does consider the potential cumulative impacts of the overall BGC Project, including potential construction impacts for all those components yet to be constructed, and the potential impacts associated with the full operation of the BGC Project from groundwater extraction, through transfer, treatment and reuse/discharge. The following elements of the BGC Project comprise an activity ( the Activity ) for the purposes of Part 5 of the EP&A Act, for which approval will be supported by the assessment in this EIS: the extraction of groundwater from the wells installed in the three containment lines (primary containment area, secondary containment area and DNAPL containment line); transfer of groundwater via pipelines to the GTP; construction and operation of the GTP; transfer of treated water via pipelines to BIP users or Bunnerong Canal and waste water to sewer; and installation of a discharge point into Bunnerong Canal. The environmental impact of the proposed BCG Project (which includes the Activity) is assessed in this EIS. Botany Groundwater Cleanup Project Environmental Impact Statement 2-11

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