Rehabilitation of UPSS within Road Reserve Dungog Shire Council Regional Contaminated Land Capacity Building Program – Council Roles and Responsibilities 9th February 2017
Or $200k to remove 4 tanks WHAT THA?
Background • POEO (UPSS) Regulation 2008 – 1 st June 2008 • Prior to commencement of Regulation Dungog Shire Council made submissions in relation to proposed Regs- • Cost to proprietors • Cost of compliance- cost shifting to Councils • Sought clarification over responsibility for UPSS on public land • Motion to LGSA conference that the Government be lobbied to address these issues.
Background • May 2011 NSW Environmental Trust approved pilot program- Derelict UPSS Pilot Program • 3 years – shared $2m funding with Innocent owners scheme and Council Gasworks scheme • Programs managed by DECC under the combined Contaminated Land Management Program • EPA shortlisted 37 Councils based on an assessment of sensitive environments, use of groundwater, number of potential derelict UPSS.
Background • October 2011 – Top 5 Councils on list invited to participate in First Stage of Pilot program • Dungog, Liverpool Plains, Muswellbrook, Wellington , Dubbo.
Why Dungog? • Selected due to high number of UPSS present under Public Roads.(12 known) • Dungog had also agitated since 2008 about impact of UPSS Regs, cost shifting and responsibility for redundant and abandoned tanks.
What did Dungog hope to achieve from Pilot Program? • Development of tools to assist future UPSS projects eg breifing notes/scope of work for consultants, standard contract templates. • Get an understanding of costs involved • Staff skills capacity building • Chance to eliminate at least one problem site.
Stage 1 of the UPSS Pilot Program • Preliminary investigation of 5 sites within each of the 5 council areas. • Objective to prioritise derelict sites for detailed investigation and subsequent remediation work • Passive Soil gas sampling- screening tool to identify extent of contamination and risk • Tank inspections – assess access, tank contents • $10,000 per site – Managed by OEH and funded by ET.
Results of Stage 1 Sites prioritised Investigations carried out in • February 2012 5 sites in Dungog Shire • EPA concluded that Modern • Motors- Dowling street Dungog was the highest priority Proximity to waterways • Possibly 4 derelict tanks within • road reserve as well as several derelict on private land adjacent Residential premises adjacent •
Progression to Stage 2 of the Pilot • EPA pre approved progression to Stage 2- Remediation. • Condition that this stage managed by Council • Funding of up to $200K- subject to lodgement and approval of grant application to ET • Council concerned that $200K insufficient if additional tanks found • EPA funded Ground Penetrating Radar (Pennoscan) for site
Learnings • GPR recommended to avoid surprises • Budget should have contingencies
Remediation Grant application • May 2012 grant application lodged to Env trust- EPA assisted • Remediation grant under Derelict Underground Petroleum Storage System Pilot Program • Stage to be managed by Council with assistance from EPA • February 2013 grant approved- funding received in full.
Learnings • The Environmental Trust takes a long time to determine grant applications (9 months) • The provision of 100% of funding upfront is rare but appreciated.
The Remediation Project • No experience within Council in relation to remediation projects • Decision made to contract the project • Scope of works developed in consultation with EPA • Close communication at all times with proprietor of Modern Motors
Tender process • Tender advertised nationally • 11 tenders received • Tendered amounts varied between $62K- $229K • Standard cost schedule simplified comparisons • Contract awarded to Robert Carr and associates ($104,000)
Learnings • Imperative that all tenderers use same costing schedules for comparisons • Remediation experts essential to assess tenders • Important to look for what isn’t included eg waste disposal fees, wet weather contingencies. • Qualifications and experience of tenderers needs to be analysed
Stage 1 (Pre- work) • Clarify some unknowns • C onfirm type and size of UST’s and their content • Establish if any contingencies or variations to scope of works was required. • Integrity testing of tanks • Consideration of Heritage status of nearby buildings including dilapidation survey of Service Station • Soil testing for pre-classification of material to be excavated.
Stage 1- Remediation Action Plan • RAP was prepared and submitted in December 2013 having regard to pre work carried out. • Removal of 4 tanks and supporting infrastructure • Excavation of contaminated soil to supporting bedrock for disposal at a licenced waste facility. • Backfill with VENM • Re-establishment of site • Note: Site no longer used for fuel sales and 6 redundant tanks to remain on private property
Stage 2 - Works • Remediation works considered to be Type 2 under SEPP 55 notwithstanding location on edge of heritage precinct. • Permits and plans – safe work method statements, WHS plans, Pedestrian and Traffic plan, Waste Management plan • Temporary fencing, underground service location and redirection (Telstra)
Stage 2 works • Removal of concrete driveway. • Excavation of UPSS pit – no space at working premises to store material- 100tonnes transported to hardstand area at Dungog waste facility • Removal and cutting of 4 tanks- disposal at waste facility. • Sampling of soil in excavated pit
Stage 2 works • Extreme rainfall whilst awaiting soil test results filled excavated pit. • 1000 litres of effluent removed by tanker disposed of at liquid waste facility • After soil test results received – excavation backfilled and compacted with VENM. • Disturbed area re-concreted by contractor 3 weeks later
Validation sampling results • Validation samples collected on walls and base of excavation • Some contamination ( benzine) remained in excess of human health and ecological criteria of the NEPM • Owing to transient use and intended concrete capping- consultant recommended no further remediation works
Stage 3- Assessment of downgradient impacts • Objective to determine migration of contaminants • Soil samples taken downgradient • 2 groundwater monitoring wells installed • Vapour monitoring carried out in subfloor areas of 2 nearby residences • Groundwater sampling
Stage 3 – Validation results • Samples for – • Soil • Vapour • Groundwater • All within NEPM criteria • No further down gradient remediation required. • Existence of redundant UST’s on private property noted.
Costs • Grant $200K • Total expenditure $195K • Consultant $116K • Re-establish site $35K • Waste disposal $27K • Council admin costs $17K
Challenges • Starting from scratch with no internal expertise in remediation projects • Reliance on external parties – EPA, Consultant and subcontractors • Evolving work environment- not all matters are known upfront
Opportunities • Development of tools – eg Scope of work and brief for consultants, template contract documents • Better understanding of applicable costs • Development of staff skills • Enhanced relationship with EPA • Example of project process for owners of UPSs (including council)
Recommend
More recommend
