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Raw Earth Environmental Pty Ltd (Raw Earth) were engaged to undertake multi scoped, site based contamination assessments and hazardous material surveys to support the Ballina Shire Councils Development Assessment (DA).
The following services and reports were also provided to the client:
The scope of this assessment included interior and exterior areas of the defined site that were to encounter potential impacts during site based redevelopment works to Building 1 and Building 2.
During the assessment undertaken by Raw Earth Environmental in May of 2023, Synthetic Mineral Fibres, Polychlorinated Biphenyls and Ozone Depleting Substances were presumed to be present in sections of Building 1 and 2 as well as surrounding areas on site.
Laboratory analysis of Asbestos Containing Materials from 12 samples was reported as being non-detect for asbestos, while lead paint and lead dust was assumed not to be present on site due to the Buildings 1 and 2 age.
Removal methodology and management of Synthetic Mineral Fibres, Polychlorinated Biphenyls and Ozone Depleting Substances on site should be undertaken with consideration to specific hazardous material legislation and guidelines.
In June of 2023, Raw Earth completed a Preliminary Site Investigation (PSI) at the property located at site. The investigation comprised of an inspection of the site and surroundings areas along with the collection of surface soil samples. A total of fifteen (15) soil samples were collected as a suitable representation of soil to identify if contamination was present in the shallow soils relating to proposed excavation areas.
Each of the 15 samples were analysed for metals and organochlorine (OC) and organophosphate (OP) pesticides. Analytical soil results were compared against the adopted Tier 1 NEPM 2013 Table 1A(1) HILs Res A Soil and NEPM 2013 Table 1B(5) Generic EIL – Residential A (most conservative) site specific land use criteria. Background metal detects were present, yet no exceedances were noted against the adopted criteria, while no OC or OP pesticide detects were reports. Based on this preliminary site investigation, potential contamination impacts to site construction works, site users, offsite receptors or ecological receptors was considered low and as such, a more detailed, intrusive investigation such as a Detailed Site Investigation was not required.
In June of 2023, Raw Earth were engaged by DWP Architects to conduct an Acid Sulfate Soil Investigation (ASSI) for the site. The ASSI outlined the procedures to determine whether Acid Sulfate Soils (ASS) are present as part of in situ soils at site and if an Acid Sulfate Soil Management Plan (ASSMP) was required to manage ASS during excavation works as part of the development. The ASSI was undertaken to meet the Ballina Shire Council (BSC) requirements relating to the site based construction DA.
Based off the works undertaken as part of this ASSI and field indicators outlined in ASSMAC 1998 and National Acid Sulfate Soils Sampling and Identification Methods Manual (NASSSIMM 2018), Raw Earth concluded the following:
• Potential and actual ASS were not identified in soils to a depth of 3.0 mBGL anywhere on site; and,
• If during excavation works subsurface conditions were encountered that exhibit physical indicators for Actual Acid Sulfate Soils and Potential Acid Sulfate Soils (AASS/PASS), the soil should be re-assessed against this criterion by a person suitably qualified to do so.
A Preliminary Risk Screening was undertaken by Raw Earth in accordance with SEPP 33, relating to the proposed redevelopment of Building A, refurbishment of Building B, and construction of Area C and Area D of the Rous County Council Ballina workplace project.
Under SEPP 33 – Hazardous and Offensive Development (DoP, 2011), a preliminary risk screening of the proposed development was required to determine the need for a Preliminary Hazard Analysis (PHA). The preliminary screening involved identifying and assessing the storage of specific dangerous goods classes that have the potential for significant off-site effects. If the risk level of a proposed development exceeded the acceptable criteria for impacts on the surrounding land use, and even with the presence of controls, the development has the potential to be classified as a "hazardous" and/or "offensive" industry. Such industries may not be permitted in certain land zones in NSW. A ‘hazardous industry’ under SEPP 33 is one which continues to pose a significant risk when all locational, technical, operational, and organisational safeguards are employed. An ‘offensive industry’ is one which, even when controls are used, has emissions that result in a significant level of offence, e.g., odour or noise emissions. A proposal cannot be considered hazardous or offensive until it is first identified as potentially hazardous or offensive and subjected to the assessment requirements of SEPP 33. Raw Earth were able to provide an initial Preliminary Risk Screening of the proposed development and, if required, a Preliminary Hazard Analysis in accordance with the Regulatory Framework. The analysis was undertaken to consider all planning requirements.
Following the review of SEPP 33 Guidelines, reviewing the potentially offensiveness and potentially hazardous criteria, the proposed development was considered to be extremely low in terms of offensiveness and hazardous. The preliminary risk screening identified that the proposed development is below the required threshold and SEPP 33 would not apply.
To assist with the project DA, Raw Earth were engaged to undertake a Land Use Conflict Risk Assessment (LUCRA). The assessment of Rural Land Use Conflict followed the approach detailed in the Land Use Conflict Risk Assessment Guide prepared by the NSW Department of Primary Industry. LUCRA is a system to identify and assess the potential for land use conflict to occur between neighbouring land uses.
The LUCRA aimed to:
• Identify and address potential land use conflict issues and risk of occurrence before a new land use proceeds or a dispute arises;
• Objectively assess the effect of a proposed land use on neighbouring land uses;
• Increase the understanding of potential land use conflicts to inform and complement development control and buffer requirements; and,
• Highlight or recommend strategies to help minimise the potential for land use conflicts to occur and contribute to the negotiation, proposal, implementation and evaluation of mitigation strategies.
All neighbouring properties were found to have sufficient separation distances from the site to mitigate noise, dust and odour. As the Rous County Council would operate on standard business hours it is envisaged that the increase in staffing levels will cause minimal impact to the surrounding community.
During consultation, many residents raised concerns relating to increased traffic. A report was conducted by Modus Transport and Traffic Engineering in June of 2023 which found the proposed development complied with all relevant codes and standards in relation to traffic management for the site.
Raw Earth recommended the clients implemented all Risk Reduction Controls to mitigate any potential future conflicts. It is envisaged that with adequate control and formulating a consultative and open relationship with the community, resolutions to any potential or unforeseen conflicts could be adequate managed and mitigated.
An Operational Waste Management Plan (OWMP) was required to be developed by Raw Earth to assist in the management of waste to be generated post construction works at the site and was based on projected figures of occupancy, workplace activities and waste generation. This was done to assist the project DA.
The objectives of the OWMP were to develop a plan for the management of wastes at the site in accordance with the NSW Waste Avoidance and Resource Recovery Strategy 2014-21 (WARR). This included managing waste in accordance with the waste hierarchy established under the Waste Avoidance and Resource Recovery Act 2001.
The NSW WARR aimed to maximise conversation of natural resources and to minimise environmental harm from waste management and disposal of solid waste.
The specific objectives of the OWMP were as follows:
Avoid/Reduce
• Reduce general waste at the source, determine changes in returnable delivery systems including packaging and purchasing;
• Require suppliers to use stackable/returnable/reusable boxes instead of disposable cardboard boxes;
• Reduce consumption of resources that have the potential to become waste through strategies such as green purchasing - purchasing items with reusable, recyclable, have no packaging or are biodegradable;
• Examining all processes to determine where wastes are produced and to devise measures for waste prevention or reduction;
• Partnering with others to assist with waste minimisation; and,
• Keeping track of changes and improvement.
Reuse
• Set up a reuse area for excess materials and promote the contribution and reuse of excess food;
• Implement the Enviro Bank program for bottles and cans;
• Reusing drums, cartridges and containers where possible; and,
• Selling or donating usable waste materials to other organisations.
Recycle
• Introducing recycling systems for major waste streams generated onsite including:
• Paper & cardboard;
• Bottles & cans;
• Packaging and plastic; and,
• Investigating alternative uses for organic waste that cannot be reduced or reused (composting, bio-gas from digester etc.).
• Explore opportunities of recycling waste types not included in primary waste streams including:
• Batteries;
• Ink Cartridges; and,
• E-waste.
Monitoring and Assessment
• Request waste contractor to provide monthly data and reporting on recycling and materials sent to landfill.
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