8. Solid Wastes - Department of Planning and Community Development The Minister for Planning has issued Terms of Reference, under which the Assessment Committee will assess the CIS and submissions in response.
Extract: (7) Terms of Reference: Conduct a Public Hearing, in accordance with Division 2 of Part 8 of the Act, to hear properly made submissions confined to the following matters.
(7) (h) Whether the risk from disturbance and disposal of solid wastes has been appropriately addressed.
EWL CIS documents for reference
All CIS documents
- From LMA - download individual CIS documents
- Fully searchable CIS in one pdf - 529 pages - shared via google drive
- LMA CIS Appendices - shared via google drive
- LMA CIS Mapbook - shared via google drive
Solid Wastes draft submission notes
From Kensington Association: CIS Scoping – Disturbance and Disposal of Solid Wastes
There are four areas of the nine EWL CIS Scoping directions of particular importance to Kensington: Land use, dwellings and infrastructure; Noise, vibration, air emissions and light spill; Minimising risks from disturbance and disposal of solid wastes from excavation works, including potentially contaminated materials and acid sulphate soils (especially if works are undertaken in the Moonee Ponds Creek); and Visual amenity.
Solid Wastes(from CIS Scoping Document 3.3.8 P20)
Draft evaluation objective: To minimise risks from disturbance and disposal of solid wastes from excavation works, including potentially contaminated materials and acid sulphate soils. Key risks
- Impacts associated with waste solid materials from excavation works, including those arising from off-site disposal of any acid sulphate soils or potentially contaminated materials.
Priorities for studies to characterise existing environment
- Identification of occurrence of acid sulphate soils, contaminated soil, landfills and other potential sources of contaminated materials in the project area.
- Identification of volumes and characteristics of waste materials to be excavated.
- Identification of suitable off-site disposal options for waste materials.
Design and mitigation responses to risks
- Opportunities for productive re-use of waste materials (in particular, tunnel spoil) in accordance with regulations.
- Potential ann any proposed measures to minimise the disturbance and need for off-site disposal of any acid sulphate soils and potentially contaminated materials
Assessment of likely impacts
- Assessment of possible capacity issues that could affect either the management of waste on-site or disposal off-site.
Approach to performance management
- Proposed performance requirements to guide management of waste.
Main Impact Site
East- West Link Authority intends to carry out massive excavation to construct exit and entrance walls at the depth of 100 ft then excavate ramps to allow heavy duty drilling equipment and trucks to gain access to the walls faces then tunnel construction would begin. The combined length of the walls would be the width of Hoddle St. This gives you an idea of the enormity of this project. According to E-W Link Authority engineer, entry and exit portals would be constructed near Gold St adjacent to the Shot Tower, tunnels would go under Wellington Street. This Tower built in 1882 is most certainly threatened.
A large storm water drain formerly known as the Reilly Street drain runs from Hoddle St Collingwood undemeath Alexandra Parade to Princess Street, Carlton. East bound exit tunnel would have to be located on the far north side of Alexandra Pde to allow suitable clearance from drain, this would put tunnel wall excavation critically close to Tower footings. Heritage Victoria intends to carry out a comprehensive impact assessment in the near future on the affects of severe vibrations on infrastructure in this vicinity.
Impact on Surrounding Area
The area in the vicinity of Bendigo, Forest, Alexander, Ballarat, Gold, and Hotham Streets is situated in an area where the stratum is already flawed due to the construction of the Eastern Freeway, this area will be dramatically affected by the massive excavation of earth proposed. Well over 100 properties would be affected, taking into account that many major foundation impacts do not occur until many years after completion of project. In the street where I reside Bendigo Street, seven of the twenty five properties have had major repairs in the form of foundation under pinning. One neighbour has spent nearly $50,000 on repairs, many others in the area have experienced similar heart breaking experiences.
Background to 1970s Eastern Freeway construction
In 1972 compulsory acquisition notices were served on residents and business proprietors who were situated in the vicinity of Hoddle St west side between Alexandra Pde and Victoria Pde and between Hoddle St and Gold St south side of Alexandra Parade Collingwood.
Ninety nine residential properties, five hotels and several factories were acquired, including Julius Marlow shoe manufacturers who employed over one hundred people.The eastern freeway environmental impact was devastating not only because of the compulsory acquisition but also the fact that the natural environment was drastically damaged.
- (1) 36 acres of Yarra Bend National Park lost.
- (2) Alexandra Parade median strip devastated, this green strip was 40 metres wide and extended the whole length of the Collingwood Nth boundary. This was the local children's recreation are4 there was no other open areas without crossing dangerous Hoddle Street.
- (3) Due to massive amounts of earth being removed fnom the main impact site starting at Yarra Blvd Park then going under Hoddle St connecting with Alexandra Pde geological faults began to appear causing damages ranging from minor cracking, major cracking. to critical major damage to foundations of residences and may I say are still occurring today 36 years after the F19 free way was opened.
- (4) Severe related impact events can be found in a 1.5 km radius from the main impact site in the districts ofAbbotsford, Collingwood, and Clifton Hill, total damage I would say in the tens of millions of dollars, one example where damage to a neighbours brick house four doors up from my house was $35,000, another brick two storey property in Hotham St virtually split in two.
- (5) These collateral damage events do not necessarily happen close to the time of construction many serious foundation problems occured 15 -20 years after the completion date. The Hamer Liberal Government of the day only paid out on collateral damage claims 18 months to 2 years after completion of the project.
- (6) Property values depreciated considerably during these projects and took many years to stabilise
Proposed East- West Road Tunnel- Environmental Disaster
Would it not be logical to presume that a sectionalised area that East-West Link Authority intends to excavate for the six lane road tunnel could have geological weaknesses due to previous excavations, remembering incalculable amounts of earth have been taken from this main impact site already, and seeing that the surrounding stratum is geologically flawed, this has all the hallmarks of an environmental disaster of massive proportions.
It is inconceivable that the Napthine government intends to spend $293,000,000 on consultancy fees for this project We the people of Collingwood know from past experience that engineers and consultants have shown to be neglectful regarding their duty of care for the environment and have found them to be people of little conscience who have no rcspect for the average working class people and make unaccountable decisions which directly affect peoples amenity and standards of living.
Residents Against the Tunnel - Solid Wastes
Here are some suggestions for the sort of things you might like to include about Solid Wastes in your submissions to the CIS Assessment Panel due 12 December 2013: “The potential impacts to human health & the environment due to construction activities & management of spoil (solid waste) have been considered at a local context with regard to contamination” (Technical Appendix N, p 11). Technical Appendix N, p.i goes on to say: “Potential Impacts documented in the CIS are
- Affect the maintenance of ecosystems, parks reserves, gardens residential, recreational open space etc.
- Adversely affect human health
- Cause the land to become corrosive & adversely affect the integrity structures or building materials
- Cause the land to be offensive to the senses.”
The CIS materially fails to address the objective to minimise the risks from disturbance & disposal of solid wastes because a comprehensive assessment of the risks was never conducted. The assessment of risk performed by the expert and detailed in the CIS was limited to a “desktop review” (Appendix 4.2.1) and accordingly can only be considered cursory and not comprehensive.
Minimisation of risk cannot occur if a comprehensive assessment was never performed.
This failing & weakness is acknowledged by the independent expert in their report (Appendix N Section 4.3) where they detail the numerous & extensive assumptions they draw upon in order to somehow assess & minimise risk. Clearly the expert details these assumptions, in order to materially qualify their opinion & to avoid challenge to their opinion by someone who had conducted a more comprehensive study. The need to make these extensive assumptions, highlight the limitations of the CIS surrounding solid waste management as they clearly outline the preferred method of the independent expert and that the desktop review of data provided has not been reviewed for accuracy or its interpretation.
Some of the assumptions (Appendix N Section 4.3) made by the expert give evidence to their failure to conduct a “comprehensive” assessment. In particular we refer to the following assumptions
- 1. “GHD relied on information supplied by others which may not have been independently verified. Intrusive investigation for the purpose of soil sampling, analytical testing and geological logging were not undertaken. It should be noted that soil contamination is not always obvious from visual inspection”. This is a clear admission that the preferred and more comprehensive method of undertaking an impact assessment was not performed.
- 2. "Image resolution issues may have led to uncertainties in interpretation of historical photos”. This is acknowledgment that there are severe limitations & interpretation concerns as to the desktop review.
- 3. The independent expert has relied upon & assumes geological mapping and surrounding information supplied by the proponent of the project (LMA) is reasonably accurate. Apart from the clear conflict of interest, it would appear a crazy “Catch 22” scenario where the LMA has engaged an independent expert because they have the expert skills and fact finding abilities to gather evidence and interpret data in order to make a comprehensive impact statement, but the expert has then relied upon the client to provide the necessary accurate and complete information. Are they an expert, if they are unsure of the accuracy of the information provided?
One would assume a true expert would know if the information and geological mapping was accurate. It would appear that the information supplied by the LMA to the expert can only be assumed to be “reasonably accurate”. What is the experts’ definition of reasonably accurate? When conducting risks assessment of contaminated soil with severe potential impacts, it is not comprehensive to “assume the information is reasonably accurate”. What error factor have they allowed for in forming their “comprehensive” opinion? How can any associated risk rating matrix be viewed with any confidence?
- 4. The expert has assumed “approximately 2.5 to 3 million tonnes of spoil material will be required to be managed”.
Is there no accurate measurement available? If not, then one should be conducted. An error factor of 20% or half a million tonnes suggests there has not been a comprehensive analysis. What if this assumption is inaccurate & the amount of material to manage is 4 million tonnes?
- “Previously completed bore holes, bore locations and associated logs and interpretations are accurate”.
It is incredulous that the expert has not reviewed the raw data & made their own interpretation if they are not prepared to conduct their own soil sampling, geological testing and analysis. Making the assumption that interpretations of data are accurate acknowledges that they may in fact be inaccurate or another interpretation of the data may be concluded. The experts clearly have concerns as to interpretation of the data and that data is subject to a mixture of interpretations.
With so much doubt surrounding the accuracy of both the data and its interpretation, how can the assessment of risk be considered comprehensive?
Other factors indicating the inadequacy of the CIS
1. The documents relied upon to perform this “desktop assessment” are not current. Many of the documents are in excess of ten years old. The Geological surveys being relied upon were performed in 1974 & 1980. (Appendix N 4.2.1)
2. The independent expert further qualifies their report in Appendix N section 4.5 by highlighting the severe limitations surrounding the availability of data & information. The summary of these further disclaimers / qualifications to their report in Appendix N Section 4.5 is that the independent expert is concerned about 6 factors which make it difficult to be sure of the impacts of the proposed project. The 6 factors affecting the accuracy of data & information are as follows
- “The level & distribution of contaminated soil, rock & groundwater within the construction footprint”. We can only interpret this to mean that they do not have enough data to accurately quantify (to an acceptable level of accuracy) the level & distribution of contamination in it various forms. Perhaps this is because the same expert in appendix M of the CIS has acknowledged that tunnel & portal works and the damming effect of the tunnel have the potential to mobilise existing highly contaminated water & hence spread contamination to currently relatively unaffected areas. We note that in Appendix M, the expert fails to quantify the potential geographical spread of this further contamination. Perhaps this concern for the unknown geographical spread of contaminated groundwater, explains the vagueness of estimated amount of spoil that will result from the proposed project.
- “Likelihood of disturbance of potential and actual acid sulfate soils given that the Reference project and method of construction has yet to be defined”. This is acknowledgement by the independent expert of the recurring theme we have highlighted throughout our response, that the comprehensive impact statement has not been performed because the proponent of the project has yet to define what the project is.
- “Quantities of contaminated soils and actual acid sulphate soils required to be treated prior to disposal to a licenced landfill facility”. As previously indicated, the expert is clearly unsure as to amount of contaminated water and soil that may need treatment prior to disposal. If the expert does not know the amount of soil requiring treatment prior to disposal, this also indicates they do not know the level of contamination that exists underground in the undefined proposed project area. Only soils with a contamination grade of “A” require such treatment on site.
The lack of reasonable certainty as to the level of contamination (all areas are contaminated) potentially raises concern for residents safety & amenity. Greater amounts of material requiring on site treatment could delay the project and hence extend the time residents may have to live within close proximity of a potentially dangerous construction zone. This impact has not been addressed by the CIS.
- “The likely volume of contaminated water that would require treatment & management during the tunnel construction”. Again the CIS has failed to address this issue. Again the safety and amenity of residents, workers will be compromised without adequate assessment of the risk.
- “The potential for vapour intrusion into the tunnelling void during construction and operation from the contamination present along the alignment particularly-in particular between Queens Parade & Gold Street Fitzroy. (I assume they mean Gold St , Collingwood). It is of particular concern that it is unknown whether there could be contaminated vapour intruding into the tunnel area both during & after construction. This indicates that this potential safety issue may never be resolved as it is acknowledged that it may continue into the operational phase of the proposed project. Do they plan to advise potential users of the tunnel of this problem? What are the potential safety concerns for residents?
“Locations of the laydown/ soil treatment areas for stockpile soil and rock material that may require additional sampling / treatment prior to disposal or treatment prior to transportation to another treatment facility. Again this highlights that the cursory approach taken to assessing the risk, has meant that neither the number nor location of contaminated stockpiles has been identified. This is understandable when the level of contamination and the amount of contaminated matter is unknown. Again the CIS has completely failed to give an appropriate assessment of the potential impacts.
The health of residents and builders could be placed at risk during construction of the east-west link, with the state government's own documents warning that contaminated soil, groundwater and asbestos may be dredged up as the controversial tunnel is built. Independent experts have found a range of potential contamination sources, including asbestos at Royal Park, bacteria and viruses from the Melbourne General Cemetery, and dirty water from the former Fitzroy North Gasworks site, which could enter the tunnel construction area near Alexandra Parade. The most significant danger is likely to be to "construction workers, human health, and the environment" as material is dug up and transported to make way for the Coalition's $8 billion tunnel between Clifton Hill and Flemington, public reports on the project's impact reveal. "Contaminated soil and groundwater may pose a risk to construction and maintenance personnel, as well as being potentially aggressive to construction materials, generating vapour risks and creating storage issues," says a report. "The residual risks for these impacts are rated as high."