Contamination Delivery Work Plan

Normanby Road Early Works Contamination Delivery Work Plan / Management Plan

CRL-MTE-RME-LKA-PLN-800011 Revision: 001 Date: 21 February 2020

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| Normanby Road Early Works

Contamination Delivery Work Plan / Management Plan

Document title CRL-MTE-RME-LKA-PLN-800011 This document is uncontrolled when printed. This document should be printed in colour

Revision Status Revision

Date

Version details

Prepared By

Approved By

Rev A00

15/11/19

Mana Whenua / CLG Review

Daniel Ware

Stephen Thomson

Rev A01

28/11/19

Draft to IPR and Auckland Council

Daniel Ware

Stephen Thomson

Rev 000

17/12/19

Final for submission

Daniel Ware

Stephen Thomson

Rev 001

21/02/20

Final

Daniel Ware

Stephen Thomson

Approval Status Name/Title Prepared by:

Daniel Ware Environmental Scientist

Signature

Date 17/12/19

PP

Reviewed by:

Stephen Thomson Principal Scientist

17/12/19

Approved by:

Peter Roan Consenting Lead – Link Alliance

17/12/19

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Table of contents Abbreviations .................................................................................................... 5 1. Introduction ................................................................................................ 6 1.1

Overview of CRL Works in Mt Eden ................................................................................... 6

1.2

Purpose of the Contamination DWP .................................................................................. 7

1.3

Relevant Conditions .......................................................................................................... 7

1.4

CDWP Review and updates ............................................................................................. 11

1.5

CDWP Authors ................................................................................................................. 11

2. Normanby Road Early Works .................................................................... 12 2.1

Overview of Works .......................................................................................................... 12

2.2

Construction Methodology .............................................................................................. 12

2.3

Key Personnel .................................................................................................................. 13

2.4

Summary of Anticipated Soil and Groundwater Quality .................................................. 13

3. Regulations ............................................................................................... 15 3.1 Resource Management: National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health (NES Soil) ........................................................... 15 3.2

Asbestos in Soils (BRANZ) ................................................................................................ 15

4. Environmental Site Management Practices .............................................. 18 4.1

Overview ......................................................................................................................... 18

4.2

Excavated Soil Management ........................................................................................... 18

4.2.1.

Oversight/Supervision ................................................................................................. 18

4.2.2.

Transportation of Soil .................................................................................................. 18

4.2.3.

Validation Sampling ..................................................................................................... 19

4.2.4.

Record Keeping ........................................................................................................... 19

4.3

4.3.1.

Cleanfill ....................................................................................................................... 20

4.3.2.

Managed Fill/Soil Material ........................................................................................... 20

4.3.3.

Contaminated Fill ........................................................................................................ 21

4.4

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Soil Disposal Classification ............................................................................................... 19

Water Management ........................................................................................................ 21

4.4.1.

Stormwater ................................................................................................................. 21

4.4.2.

Groundwater ............................................................................................................... 21

4.5

Dust Management ........................................................................................................... 22

4.6

Odour Management ........................................................................................................ 23

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Contamination Delivery Work Plan / Management Plan 4.7

Materials Importation ..................................................................................................... 23

4.7.1.

General ....................................................................................................................... 23

4.7.2.

Crushed Concrete ........................................................................................................ 23

5. Health and Safety Plan .............................................................................. 24 5.1

Control Measures ............................................................................................................ 24

5.2

Site Inductions ................................................................................................................. 25

5.3

Daily toolbox Hazard Identification ................................................................................. 25

5.4

Personal Protective Equipment ....................................................................................... 26

5.5

Personal Decontamination .............................................................................................. 26

5.6

Communication Plan ....................................................................................................... 26

6. Unexpected Discovery of Contamination ................................................. 27 6.1

General ............................................................................................................................ 27

6.2

Asbestos .......................................................................................................................... 28

7. Site Validation Report ............................................................................... 29 8. References................................................................................................. 30 Appendix A: Record of CLG, IRP and Auckland Council Comments ................ 31 A1. CLG Comments .......................................................................................... 31 A2. IPR Comments ........................................................................................... 31 A3. Auckland Council Comments .................................................................... 31

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Abbreviations Acronym

Meaning

ACM

Asbestos-containing material

ACoP

Approved Code of Practice: Management and Removal of Asbestos (WorkSafe NZ, Sept 2016).

ACZ

Active Construction Zone

AF/FA

Asbestos fines/Friable asbestos

ANZECC Guidelines

Australian and New Zealand Environment Conservation Council Guidelines for Fresh and Marine Water Quality (2000)

AUP

Auckland Unitary Plan – Operative in Part

AVF

Auckland Volcanic Field

BaPeq

Benzo(a)pyrene equivalence

bgl

Below ground level

CCP

Communications and Consultation Plan

CEMP

Construction Environmental Management Plan

CLP

Contaminated Land Professional

CRL

City Rail Link

CRLL

City Rail Link Limited

CSA

Construction Support Area

DWP

Delivery Work Plan

ECBF

East Coast Bays Formation

ESCP

Erosion and Sediment Control Plan

ESM

Environmental and Sustainability Manager

HSO

Health and Safety Officer

IS Rating

Infrastructure Sustainability Rating

ISCA

Infrastructure Sustainability Council of Australia

MfE

Ministry for the Environment

NAL

North Auckland Line

NES Soil

Resource Management (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health) Regulations 2011

NIMT

North Island Main Trunk-line

PAH

Polycyclic aromatic hydrocarbons

PPE

Personal protective equipment

SCS

Coil contaminant standards

SH1

State Highway 1

SQEP

Suitably qualified and experienced practitioner; in this context as defined in the NES Soil

SVR

Site Validation Report

TA

Tauranga Group

TBM

Tunnel boring machine

TPH

Total petroleum hydrocarbons

WDQMP

Water Discharge Quality Monitoring Programme

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1. Introduction The City Rail Link (CRL) project comprises the construction, operation and maintenance of a 3.4 km underground passenger railway, running between Britomart Station and the North Auckland Rail Line (NAL) in the vicinity of Mt Eden Station. The CRL also involves the construction of two new underground stations at Aotea and Karangahape and a redeveloped Mt Eden Station (refer to Figure 1-1). The design and construction of the CRL infrastructure between Aotea and Mt Eden Stations is being delivered by the Link Alliance.

This Contamination Delivery Work Plan (CDWP) has been prepared in relation to early works along and in the vicinity of Normanby Road, hereafter referred as the ‘Normanby Road early works’.

Figure 1-1: CRL Route and Location

1.1 Overview of CRL Works in Mt Eden The CRL works in the Mt Eden area involve the construction of the southern section of the tunnel structures and the tie-in to the existing NAL, including the construction of the redeveloped Mt Eden Station. The Mt Eden Active Construction Zone (ACZ) and Construction Support Areas (CSA) for the NAL Mt Eden section are generally located between State Highway 1 (SH1) to the east and Dominion Road to the west.

The works in this area include: • • • • • Page 6

Construction of an underground grade separation structure near Mt Eden Station; A new Mt Eden Station building incorporating passenger linkages; Modifications to the existing Mt Eden Station platforms; Road over rail bridges at Mt Eden Road, Normanby Road and Ruru Street with sections of road realignment; Grade separation structures and the east- and west-facing connections for the existing and new rail lines to pass-over and connect with each other;

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Contamination Delivery Work Plan / Management Plan • •

Pedestrian and cyclist bridge structures at Fenton Street and Porters Avenue; and New road linkages within the reinstated area post-construction.

Given the nature and scale of CRL works in Mt Eden, construction will be undertaken in a staged manner.

This CDWP only relates to one component of the CRL Mt Eden works, the Normanby Road early works, as described in Section 2 below.

1.2 Purpose of the Contamination DWP This CDWP has been prepared to outline measures that will be implemented to mitigate and manage the potential human health and environmental effects associated with potentially contaminated soil encountered during the Normanby Road early works.

The objective of the CDWP is to detail the best practicable options to avoid, remedy, or mitigate the adverse effects of contaminated soil discharges generated by construction activities.

CRL Designation 2500-6 (conditions 57 and 58) requires the preparation of a CDWP while conditions 131-150 of the discharge permit (R/REG/2016/1895) and land use consent (R/LUC/2016/1890) require a Contaminated Soils Management Plan. These two separate requirements have been combined and are addressed in this single CDWP. This CDWP has been prepared in consultation with Mana Whenua and the Mt Eden Community and Business Liaison Group (CLG) and reviewed by Independent Peer Review (IPR) prior to submission to Auckland Council (as per Conditions 7 and 11 of the designation, and Condition 19 of the resource consent).

A record of the consultation and review outcomes, including the Link Alliance’s response to matters raised, is included in Appendix A. This CDWP has been prepared in general accordance with Ministry for the Environment (MfE) ‘Contaminated Land Management Guideline No. 1: Reporting on Contaminated Sites in New Zealand’ (revised 2011, MfE 2011a), and forms part of the Construction Environmental Management Plan (CEMP) for the Normanby Road early works.

1.3

Relevant Conditions

Table 1-1 identifies the designation and resource consent conditions relevant to this CDWP and where they are addressed in the document.

Table 1-1: Contaminated Land Conditions and Location in the CDWP

Condition No.

Condition

Relevant section of DWP

CRL Designation Conditions 57.1

A Contamination DWP shall be prepared to manage the adverse effects relating to contaminated land during the construction of the City Rail Link or any part of it.

This Document

57.2

The objective of the Contamination DWP is to avoid, remedy or mitigate the adverse effects of construction on human health which may result from the disturbance of contaminated materials during construction.

This Document

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Condition No.

Condition

Relevant section of DWP

To achieve the above objective the following shall be included in the Contamination DWP and implemented as required: (a) A health and safety plan that addresses: (i) Worker safety in relation to hazardous substances; and

Section 5 Section 6

(ii) Worker training with regard to handling hazardous substances, identifying potentially contaminated soil / material, and notification procedures for discovery of contamination;

57.3

58.1

(b) Procedures for how erosion and sediment control, stormwater, dust, and odour control measures will manage the removal of contaminated soil / material;

Section 4.4 Section 4.5 Section 4.6

(c) Procedures for contaminated soil classification, management and disposal of contaminated soil / material;

Section 4.2 Section 4.3

(d) Where any trenches/excavations during civil works are to be sealed as a result of contamination and how this is to be recorded;

Section 4 Section 6

(e) How and which work areas are to be restricted to authorised personnel only and procedures to limit the presence of ignition sources in these areas (e.g. no smoking within or adjacent to construction area, no welding or open flames near areas with high concentrations of hydrocarbon contamination);

Section 5.2

(f) Procedures for the monitoring and management of the removal of contaminated soil / material by a suitably qualified environmental specialist;

Section 4.2

(g) How the placement of re-used contaminated soil / material will be recorded and tracked;

Section 4.2.4

(h) Where areas for stockpiling and storing contaminated soil / material will be established on the construction site and the procedures for managing the containment of the contaminated soil / material in these areas;

Section 4.2

(i) Cross references to the specific sections in the Communications and Consultation Plan which detail how the general public will be communicated with on the management of the adverse effects relating to the removal of contaminated soil / material.

Section 5.6

At the completion of construction works a validation report will be prepared in accordance with any Ministry for the Environment guidelines and submitted to the Auckland Council Consent Monitoring officer documenting the management of soil and evidence of appropriate disposal

This Document

Resource Consent Conditions

131

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At least 20 working days prior to the commencement of construction (earthworks), the Consent Holder shall provide a Contaminated Soils Management Plan (CSMP) to the Council (Team Leader Central Monitoring) for certification. The CSMP shall be prepared by a Contaminated Land Professional in accordance with the Contaminated Land Management Guidelines, No. 1 – Reporting on Contaminated Sites in New Zealand, Ministry for the Environment (revised 2011).

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Condition No.

Condition

Relevant section of DWP

132

The Consent Holder shall request that Council (Team Leader Central Monitoring) provide a determination to the Consent Holder, in writing, within 10 working days of receipt of the CSMP, whether the CSMP can be certified as per the requirements of the Condition 134.

Noted

133

No earthworks shall commence until a. certification is provided Council (Team Leader Central Monitoring) that the CSMP satisfactorily meets the requirements of Schedule 13(A4) of the ACRP: ALW and b. all measures identified in the plan as being required to be established prior to commencement of earthworks have been established.

Noted

134

The CSMP shall address the following matters: a. the areas within the project site designated for excavation works, and an updated map/s showing the land disturbance activity areas, b. excavation management, and disposal procedures for soil, sediment, dust, surface run-off water, perched groundwater, and groundwater if encountered. c. temporary containment, treatment, and testing procedures for any water getting in contact with contaminated material if the disposal option is to the stormwater system or the marine environment is considered. d. contingency measures for unexpected discovery of contamination. e. proposed sampling and analysis, if applicable. f. any proposed works summary reporting.

Section 1.2 Section 4 Section 6 Section 7

135

The Consent Holder shall notify the Council (Team Leader Central Monitoring) at least two working days prior to any earthworks activity on the site and provide the following details: a. name and telephone number of the project manager and site owner, b. site address to which the consents relate, c. activity to which the consents relate, and d. expected duration of works.

Noted

136

All disturbance of contaminated and potentially contaminated soil shall be carried out in accordance with the certified CSMP required by Condition 131 and any changes to the plan shall be submitted to the Council (Team Leader Central Monitoring) for certification prior to the change being implemented.

Noted

137

The Consent Holder shall ensure that all disturbance of contaminated soil shall be supervised by a suitably qualified and experienced Contaminated Land Professional whose responsibilities shall include making sure that the soil management and disposal practices, the contingency measures outlined in the certified CSMP required by Condition 131, and all relevant consent conditions are adhered to.

Section 1.7 Section 4.2.2

138

The Consent holder shall ensure that regular inspections of the works area shall be carried out by a suitably qualified and experienced Contaminated Land Professional. These inspections shall be documented, and the relevant records retained and provided to Council Team Leader Central Monitoring) in the Site Validation Report (SVR) required by Condition 149.

Section 1.8 Section 4.2.2

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Condition No.

Condition

Relevant section of DWP

139

The Consent Holder shall manage soil disturbance works to minimise any discharge of debris, soil, silt, sediment, or sediment-laden water from the site to either land, stormwater systems or the receiving marine environment. The implementation of erosion and sediment controls shall be in accordance with the ESCP required by Condition 53.

Section 4.2

140

The Consent Holder shall manage all soil disturbance works to avoid the potential for cross-contamination of materials to occur, in particular, movement of contaminated soil around the site or deposition of contaminated soil on other parts of the site shall be avoided. Where soils are identified for off-site disposal, they shall be loaded directed for removal, where possible, and all material shall be covered during transportation off site.

Section 4.2

141

To minimise the spread of contaminated material, any temporary stockpiles of excavated contaminated materials shall be located within the catchment of erosion and sediment controls for the site. All stockpiles shall be covered with either polythene or an equivalent impermeable material when the site is not being worked and during periods of heavy rain.

Section 4.2

142

At all times, dust shall be controlled in accordance with the publication titled Good Practice Guide for Assessing and Managing the Environmental Effects of Dust Emissions, Ministry for the Environment 2001.

Section 4.5

143

Excess soil or waste materials removed from the subject site shall be deposited at the disposal site which holds a consent to accept the relevant type of contamination.

Section 4.2

144

The Consent Holder shall implement the procedures for the management, treatment, temporary containment, testing, and disposal of groundwater and surface run-off water via the stormwater system in accordance with the report titled Auckland City Rail Link: Resource Consent Package 2: Aotea Station to North Auckland Line Construction and CRL Operation: Draft Erosion and Sediment Control Management Plan, dated 13 May 2016, prepared by Aurecon New Zealand Limited, and provided with the application.

Section 4.4

145

Any perched groundwater or surface run-off water encountered within the excavation area requiring removal shall be considered potentially contaminated, and shall either: a. be disposed of by a licensed liquid waste contractor; or b. pumped to sewer, providing relevant permits are obtained; or c. discharged to the stormwater system, provided testing demonstrates compliance with 50 times the Australian and New Zealand Environment Conservation Council (ANZECC) Guidelines for Fresh and Marine Water Quality (2000) for the protection of 95 percent of marine water species, and is free from petroleum hydrocarbons.

Section 4.4

146

Where contaminants which have not been anticipated by the application are identified, works in the area containing the unexpected contamination shall cease until the contingency measures outlined in the certified CSMP required by Condition 131 have been implemented, and have been notified to the Council (Team Leader Central Monitoring). Any unexpected contamination encountered during the works and contingency measures implemented shall be documented in Site Validation Report required by Condition 149.

Section 6

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Condition No.

Condition

Relevant section of DWP

147

All imported fill shall: a. comply with the definition of clean fill material Section J1 of the Auckland Unitary Plan (Operative in Part); and b. be solid material of an inert nature; and c. not contain hazardous substances or contaminants above recorded natural background levels of the receiving site.

Section 4.3 Section 4.8

148

All sampling and testing of contamination on the site shall be overseen by a suitably qualified and experienced Contaminated Land Professional.

All sampling shall be undertaken in accordance with Contaminated Land Management Guidelines, No. 5 – Site Investigation and Analysis of Soil, Ministry for the Environment (revised 2011, MfE 2011b).

Noted

149

Within three months of the completion of earthworks on the site, the Consent Holder shall provide a Site Validation Report to the Council (Team Leader Central Monitoring). The SVR shall be prepared by a suitably qualified and experienced Contaminated Land Professional in accordance with the Contaminated Land Management Guidelines, No. 1 – Reporting on Contaminated Sites in New Zealand, Ministry for the Environment (revised 2011).

Section 7

1.4

CDWP Review and updates

This CDWP is a live document that will be reviewed and updated as a result of a material change to the Normanby Road early works, or to address unforeseen adverse contamination effects arising from construction, or unresolved complaints. Refer to Section 6.7 of the CEMP for further detail on the review and updating process.

1.5

CDWP Authors

This CDWP has been prepared by Daniel Ware and reviewed by Stephen Thomson, both being Contaminated Land Professionals (CLP).

Daniel Ware is a Contaminated Land Scientist at WSP. Daniel has a Bachelor of Science Degree and Post Graduate Honours Degree in Chemistry.

Stephen Thomson is a Principal Contaminated Land Scientist at WSP. Stephen has a Bachelor of Science Degree and Post Graduate Diploma in Physical Geography. Stephen has over 23 years’ experience in the contaminated land industry, including considerable experience in undertaking investigations, managing, and reporting on contaminated land for public and private sector clients.

Stephen prepares and reviews technical reports and is considered a Suitably Qualified and Experienced Practitioner (SQEP) under the Resource Management (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health) Regulations 2011 (NES Soil).

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2.

Normanby Road Early Works

2.1 Overview of Works The Normanby Road early works involve demolition of the building at 11 Water Street, establishment of a Construction Support Area, construction of a temporary pedestrian bridge across the NAL and two retaining walls, and diversion of temporary and permanent utilities (such as water, wastewater, stormwater, gas, electricity and communications) along and in the vicinity of Normanby Road.

The early works are required in advance of the main construction works to provide adequate clearance between the CRL works and network utilities to enable construction of retaining walls, the Normanby Road grade separation bridge and the realigned Normanby Road / Boston Road / Nugent Street roundabout.

The Normanby Road early works are planned to extend over eight months, between February 2020 and September 2020. Figure 2.1 shows the area of these works.

Figure 2-1: Extent of the Normanby Road early works area

Refer to the CEMP for a detailed description of the works.

2.2 Construction Methodology The Normanby Road early works will be divided into stages as described in the CEMP and the Construction Staging Plans in Appendix B of the CEMP. Page 12

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2.3 Key Personnel The key personnel responsible for implementation of this CDWP are identified in Table 2-1. However, all site personnel are responsible for following the requirements of the CDWP. Refer to the CEMP for further detail on roles and responsibilities.

Table 2-1: Key Personnel and Contact details

Title Project Manager – NAL Mt Eden Section

Name Glen Kirk

Email glen.kirk@linkalliance.co.nz

Contact no.

027 500 1744

Construction Manager – NAL Mt Eden Section

Francois Pageron

francois.pageron@linkalliance.co.nz

022 547 9013

Communications and Engagement Manager Link Alliance Senior Communications and Engagement Advisor – Mt Eden Environmental and Sustainability Manager Normanby Rd Early Works Contaminated Land Professional (CLP) Link Alliance Health and Safety Manager

Rachel Blundell

rachel.blundell@linkalliance.co.nz

027 306 9156

Sonya Leahy

Sonya.Leahy@linkalliance.co.nz

021 223 5204

Sarah Sutherland

sarah.sutherland@linkalliance.co.nz

Stephen Thomson

Stephen.Thomson@wsp.com

029 355 1425

Joseph McCardle

joe.mcardle@linkalliance.co.nz

021 075 6883

021 956 397

2.4 Summary of Anticipated Soil and Groundwater Quality The Geology of the Auckland area map (Edbrooke, 2001) and limited investigation data from the wider CRL project indicates that the geology within the Normanby Road early works area consists of made ground using old construction waste and compressed clay (uncontrolled fill) overlying volcanic tuff (ash) and basalt.

Limited contaminated land investigation work has been carried out within the area of the Normanby Road early works and therefore the contaminant condition of the fill and underlying geology is unknown. Due to the presence of the uncontrolled fill and the current/historical surrounding commercial/industrial land use activities (plastic manufacturing and timber treatment), there is a risk soil contamination is present in the fill and could be encountered during land disturbance activities within the early works area.

Based on investigations undertaken across the wider CRL construction footprint (AECOM 2012, Golder 2016) and until confirmed otherwise, it must be assumed the uncontrolled fill contains elevated concentrations of: • • • • Page 13

Heavy Metals (As, Cd, Cr, Cu, Pb, Hg, Ni, Zn); Asbestos; Polycyclic Aromatic Hydrocarbons (Benzo(a)pyrene); and Total Petroleum Hydrocarbons. | Normanby Road Early Works

Contamination Delivery Work Plan / Management Plan Without sampling undertaken prior to works starting, all uncontrolled fill encountered and excavated within the Normanby Road early works area is assumed to be contaminated until otherwise proven.

In addition, asbestos is potentially present within the uncontrolled fill and in the underground wastewater and stormwater cement pipes.

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3.

Regulations

3.1 Resource Management: National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health (NES Soil) The NES Soil regulations provide a set of chemical specific soil contaminant thresholds that define an adequate level of protection for human health for a range of differing land-uses in New Zealand (referred to as soil contaminant standards or SCS). For the Normanby Road early works, the NES SCS for commercial/industrial land use has been adopted.

3.2 Asbestos in Soils (BRANZ) The management of asbestos in soils is regulated under the Health and Safety at Work (Asbestos) Regulations 2016 (Asbestos Regulations, Worksafe 2016). In order to help achieve compliance with the Asbestos Regulations, WorkSafe New Zealand has prepared an Approved Code of Practice (ACoP): Management and Removal of Asbestos (September 2016). The ACoP refers readers to the BRANZ Asbestos in Soil Guidelines (BRANZ 2017).

The key requirements of the Asbestos Regulations, ACoP and BRANZ are that works involving asbestos contaminated soils must be undertaken with appropriate asbestos controls in place and that contaminated soil removed from site must be taken to an approved disposal site.

Table 3-1 provides a summary of the controls indicated in the NZ Asbestos in Soil Guidelines for different concentrations of Asbestos Fines /Fibrous Asbestos (AF/FA) and ACM. As there is no indication that asbestos is present in the soils that are to be disturbed as part of the Normanby Road early works, the soil disturbance can be undertaken as “unlicensed asbestos works”. However, if additional information comes to hand that indicates that asbestos is present, or asbestos is discovered during soil disturbance then the works will need to be reassessed against the requirements of Table 3-1.

Table 3-1: Summary of asbestos requirements as detailed in the NZ Asbestos in Soil Guidelines

Scenario Class A works – non-friable

Class B works – non-friable

Asbestos-related works

Unlicensed asbestos work

>0.1% w/w AF+FA in soil

>0.01% w/w AF+FA in soil

>0.001% w/w AF+FA in soil

≤0.001% w/w AF+FA in soil

>1% ACM

>0.01 % w/w ACM

<0.01% w/w ACM

Additional documentation/ notification requirements

Asbestos removal control plan and WorkSafe notification for asbestos removal

Asbestos removal control plan and WorkSafe notification for asbestos removal

No additional notification required

No additional notification required

Oversight by a licensed removalist

Required

Required

Not required

Not required

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Scenario Class A works – non-friable

Class B works – non-friable

Asbestos-related works

Unlicensed asbestos work

>0.1% w/w AF+FA in soil

>0.01% w/w AF+FA in soil

>0.001% w/w AF+FA in soil

≤0.001% w/w AF+FA in soil

>1% ACM

>0.01 % w/w ACM

<0.01% w/w ACM

Personal protective equipment (PPE)

Disposable coveralls rated type 5, category 3, nitrile gloves, steel toe capped gumboots or safety footwear with disposable overshoes.

Disposable coveralls rated type 5, category 3, nitrile gloves, steel toe capped gumboots or safety footwear with disposable overshoes.

Disposable coveralls rated type 5, category 3, nitrile gloves, steel toe capped gumboots or safety footwear with disposable overshoes.

No asbestos-specific PPE as concentrations are unlikely to exceed trace levels in air.

Minimum respiratory protective equipment

Full-face P3 respirator with particulate filter.

Half-face P3 respirator with particulate filter.

Disposable P2 dust mask

No asbestos-specific requirements as concentrations are unlikely to exceed trace levels in air

Dust/asbestos fibre suppression

Water and polymer spray via localised points before and during works.

Water and polymer spray via localised points before and during works.

Water spray via localised points.

Water spray via localised points.

Air monitoring

Air monitoring required

Air monitoring not required but can be undertaken depending on the site setting and to confirm that concentrations are below 0.01 f/ml

Air monitoring not required but can be undertaken depending on site setting to confirm that concentrations are below 0.01 f/ml

Air monitoring not required

Decontamination facilities

Dedicated wet decontaminatio n area or trailer.

Consider powered and plumbed unit

Dedicated decontamination area and foot wash

Dedicated decontamination area and foot wash

Foot wash and used PPE collection area.

Vehicle (truck) protection

200 µm heavygauge polythene wrapped soil/lined trays and truck covered.

200 µm heavygauge polythene wrapped soil/lined trays and truck covered.

Truck lining/soil wrapping depends on the receiving landfill. All trucks will be covered.

Truck lining/soil wrapping depends on the receiving landfill.

All trucks will be covered.

HEPA filter system fitted for all occupied vehicles filter replaced or clean down with

HEPA filter system fitted for all occupied vehicles where friable ACM

Standard air conditioning.

Standard air conditioning.

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Scenario

Vehicle Washing Facilities

Class A works – non-friable

Class B works – non-friable

Asbestos-related works

Unlicensed asbestos work

>0.1% w/w AF+FA in soil

>0.01% w/w AF+FA in soil

>0.001% w/w AF+FA in soil

≤0.001% w/w AF+FA in soil

>1% ACM

>0.01 % w/w ACM

<0.01% w/w ACM

Visual assessment by a competent person* or SQEP following brush and or wash down

Visual assessment by a competent person* or SQEP following brush and or wash down

HEPA vacuum cleaner post work

on site (lagging, insulation, etc).

Visual assessment plus swab and air sampling inside the cab by an independent assessor

Visual assessment plus swab (if friable) by an independent assessor or independent competent person* or SQEP following brush and or wash down

Finishing surfacing/cap

No special finishing/cover requirements if soils are confirmed to meet health criterion (0.001% w/w). Otherwise: Hard cap - No depth limitation, no controls.

Soft cap – at least 0.2 m and should be delineated by a permeable geotextile marker layers between the cap and underlying asbestos/contaminated material.

Ongoing management

If validation testing shows any soil at the base of any excavation contains asbestos, even at <0.001% w/w, the Asbestos Regulations require the location of these to be recorded in an asbestos management plan.

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4.

Environmental Site Management Practices

4.1 Overview This section details the procedures for the management of potentially contaminated soil, stormwater and groundwater during land disturbance activities. It includes control measures for management and mitigation of potentially adverse human health effects associated with exposure to contaminated media, and the control of discharges to air, land and water.

Site management goals for the Normanby Road early works are as follows: •

To ensure that the land disturbance activities associated with the works are completed in accordance with designation and resource consent requirements;

•

To manage and mitigate potential risk to the health of the workers and neighbouring parties during proposed land disturbance activities;

•

To manage and mitigate potential environmental effects that may be generated as a consequence of the proposed land disturbance activities; and

•

To ensure that any spoil generated for off-site disposal is managed appropriately and is disposed to a licensed facility authorised to accept such materials.

4.2 Excavated Soil Management The protocols below will be applied to all earthworks associated with the Normanby Road early works: •

Erosion and sediment controls shall be implemented in accordance with the Erosion and Sediment Control Plan (ESCP) prepared for the Normanby Road early works before earthworks commence;

•

Where possible excavated soil shall be placed directly into a truck for off-site disposal. If stockpiling is to occur the material shall be stockpiled within the CSA (refer ESCP Drawing Area A) in accordance with the ESCP. At a minimum if stockpiling is to occur overnight or during rainfall the stockpiles shall be covered by an impermeable material and bunded.

•

Spillages of soil during placement in trucks shall be cleaned up as soon as practicable following the spillage. Spillages shall not be left unattended as contaminated soil could be trafficked by trucks and transported off-site; and

•

The earthworks shall be observed by the CLP. If unexpected contamination is encountered during works, the works shall cease in the immediate vicinity and the procedures documented in Section 8 of this CDWP shall be followed.

4.2.1.

Oversight/Supervision

The CLP for the Normanby Road early works will undertake regular inspection and/or supervise soil disturbance activities during construction. This will be a minimum of one inspection per fortnight by the CLP or a delegated person approved by the CLP.

4.2.2.

Transportation of Soil

The following measures shall be implemented to prevent soils (including any potentially contaminated material) from being dispersed onto roads or transported to another site (excluding transport to a disposal facility) as well as to minimise generation of dust: Page 18

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Any excess soil on vehicle tyres shall be removed before vehicles leave the works area. A wheel wash will be established on site and vehicles that have tracked over exposed soils will be required to exit the works area via the wheel wash;

•

Excess soil shall be removed from vehicles and plant before they leave the works area;

•

All trucks transporting excavated soil to the selected disposal facility shall be covered to prevent the spillage of soil and dust emissions; and

•

If sampling or site observations indicate the presence of asbestos, then additional controls (refer vehicle protection and vehicle washing facilities in Table 3-1) will be required for the disturbance of asbestos contaminated fill material.

4.2.3.

Validation Sampling

No validation sampling is planned to be undertaken as part of these works. The disposal facility may require sampling and analysis of the excavated material to meet their consent requirements. They will nominate the sampling required (each disposal facility holds individual requirements i.e. 1 sample per 500 m3).

4.2.4.

Record Keeping

The following reuse, off-site soil disposal management and record keeping measures will be implemented by the Link Alliance: •

A record of the works undertaken, soil location, depth, and volume of the material removed, and results of tests shall be kept for the purpose of being included in the Site Validation Report (SVR) to be prepared by the CLP, refer to Section 8. Records will also indicate whether the material was removed as cleanfill, managed fill or contaminated fill.

•

Irrespective of the disposal facility nominated, all vehicle movements including registration, estimated weight, and disposal location will be recorded.

•

Tracking documentation is to be signed prior to leaving the works area and checked at the waste disposal facility.

•

Transportation subcontractors are required to cover loads and take appropriate measures to control dust.

•

Trucks will be inspected prior to departing the site to ensure the load is adequately covered and any spillage is contained.

•

A record of any contaminated soil left in-situ including the soil location, depth and estimated volume shall also be recorded for the purpose of being included in the SVR. This includes the reuse of soil to back fill or make good any ground within the Normanby Road early works.

Receipts summarising soil disposal will be collated and provided to the CLP at the completion of the land disturbance activities for the works.

4.3 Soil Disposal Classification The majority of spoil material generated as part of the early works will likely be removed from the works area and disposed off-site. A summary of preliminary soil classifications for the project is provided in the following sub-sections.

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4.3.1.

Cleanfill

Cleanfill is defined in the AUP as follows: “Means natural material such as clay, gravel, sand, soil and rock which has been excavated or quarried from areas that are not contaminated with manufactured chemicals or chemical residues as a result of industrial, commercial, mining or agricultural activities. Excludes: •

Hazardous substances and material (such as municipal solid waste) likely to create leachate by means of biological breakdown;

•

Product and materials derived from hazardous waste treatment, stabilisation and disposal practices;

•

Materials such as medical and veterinary waste, asbestos, and radioactive substances;

•

Soil and fill material which contain any trace element specified in Table E30.6.1.4.2 at a concentration greater than the background concentration in Auckland soils specified in Auckland Regional Council (ARC 2002);

•

Sulfidic ores and soils;

•

Combustible components;

•

More than 5% by volume of inert manufactured materials (e.g. concrete, brick, tiles); and

•

More than 2% by volume of attached biodegradable material (e.g. vegetation)”.

Cleanfill material can be disposed at a facility where cleanfill material is accepted, but excludes: •

Storage and use of cleanfill material within an earthworks site for the purpose of engineering contours for specific activities,

•

Placement of cleanfill material associated with road construction and maintenance activities, and

•

Onsite storage and use of overburden or aggregate by-product that is cleanfill material associated with mineral extraction activities.

Natural soil materials including Volcanic Tuff and Basalt materials are required to be analysed prior to being classified as cleanfill and may be disposed at a consented disposal facility to accept volcanic cleanfill soils such as the Ridge Road Cleanfill (Pukekohe, Auckland); or to other project sites in the region.

4.3.2.

Managed Fill/Soil Material

Managed fill is defined in the AUP as follows: •

contaminated soil and other contaminated materials;

•

natural materials such as clay, gravel, sand, soil, rock; or

•

inert manufactured materials such as concrete and brick: and

That does not contain: •

hazardous substances or materials (such as municipal solid waste) likely to create leachate by means of biological breakdown;

•

products or materials derived from hazardous waste treatment stabilisation or disposal practices;

•

materials such as medical and veterinary waste, asbestos, or radioactive substances;

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combustible components; or

•

more than 2 per cent by volume of incidental or attached biodegradable materials (e.g. vegetation).

Managed fill typically contains concentrations of contaminants above cleanfill requirements but below the requirements of the contaminated fill landfill. However, acceptance requirements of facilities licensed to accept managed fill vary considerably and approval will need to be gained from each managed fill disposal facility prior to disposal. Additionally, disposal of managed fill must be to a facility authorised (by regulatory bodies such as Auckland Council or Waikato Regional Council) to receive the material.

4.3.3.

Contaminated Fill

For the purposes of this CDWP contaminated fill1 comprises: •

Hazardous materials in the form of household and industrial waste, organic waste or asbestos containing material, and / or

•

Soil with contamination present above managed fill criteria.

It is proposed that all contaminated fill disturbed as part of the earthworks will be removed from site to a licenced facility. Disposal of contaminated fill must be to a landfill authorised to receive the material. Landfill acceptance criteria vary between waste facilities and these should be confirmed prior to the removal of soil from site.

Any spoil materials generated within the works area which cannot be accepted at a managed fill site (due to site specific restriction) must be removed to a contaminated fill facility. Examples include Hampton Downs (Waikato) and Redvale landfill (Auckland) facilities. Pre-approval will be required for these disposal locations.

4.4 Water Management 4.4.1.

Stormwater

Separation and diversion of clean stormwater away from areas of ground disturbance is standard practice for any earthworks activity but becomes more important where contaminants are present. To minimise the potential for clean stormwater to encounter contaminated soil the stormwater and sediment controls detailed in the ESCP for the Normanby Road early works shall be implemented.

Where stormwater run-off has encountered soil originating from the Normanby Road early works, this water will be considered potentially contaminated until tested and proven otherwise. All run-off water that has encountered potentially contaminated soil will be disposed of via a licensed liquid waste contractor.

4.4.2.

Groundwater

Groundwater is not expected to be encountered during the works, however, for any groundwater that is encountered during the Normanby Road early works, this water will be considered potentially contaminated until otherwise tested. All groundwater will be removed be disposed of via a licensed liquid waste contractor or discharged to the stormwater system, where sampling has been undertaken 1

For the purpose of this Contamination Delivery Works Plan the term ‘Contaminated Fill’ is interchangeable with the terms ‘Contaminated Soil’ and ‘Contaminated Material’.

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Contamination Delivery Work Plan / Management Plan and results show compliance with 50 times the Australian and New Zealand Environment Conservation Council (ANZECC) Guidelines for Fresh and Marine Water Quality (2000) (ANZECC, 2000).

4.5 Dust Management Refer to the dust mitigation measures that are set out in Section 6.2 of the Air Quality Management DWP prepared for the Normanby Road early works.

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4.6 Odour Management Refer to the odour mitigation measures that are set out in Section 6.5 of the Air Quality Management DWP prepared for the Normanby Road early works.

4.7 Materials Importation 4.7.1.

General

Materials will be required to be imported to the works area to complete the subgrade. Two sources of material are proposed, clean quarry materials and recycled crushed concrete aggregate. Material sourced from a certified quarry or supplier does not require testing. This material is considered to meet the definition of cleanfill (refer Section 4.3.1). Any crushed concrete reused will be managed in accordance with the process outlined in Section 4.7.2.

4.7.2.

Crushed Concrete

Prior to acceptance of crushed concrete aggregate, the contractor will request the following information from the supplier to confirm suitability for use: •

Address of source site.

•

Copies of any pre-demolition asbestos surveys.

•

Copies of any asbestos clearance certificates prepared prior to demolition.

This information will be reviewed by the CLP, who will advise the Link Alliance regarding suitability.

The following verification and testing regime will be completed by the CLP in support of the acceptance of recycled crushed concrete aggregate.

•

The CLP will complete periodic site walkovers. Visual observations will be made for the presence of plastic, metal, or other waste fragments such as potential asbestos sheeting.

•

Testing will be completed from stockpiled materials at the site at rate of one sample per 500 m 3.

•

Bulk samples of suspect asbestos-containing materials will be analysed via an appropriatelyaccredited laboratory.

•

Soil samples will be analysed via the BRANZ guideline document New Zealand Guidelines for Assessing and Managing Asbestos in Soil (BRANZ 2017).

•

Samples may be analysed for asbestos presence/absence as a screening measure, at the discretion of the CLP.

The Link Alliance and the CLP will retain records pertaining to materials importation completed. These will be issued to the CLP for inclusion in the SVR (refer Section 8).

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5.

Health and Safety Plan

This CDWP provides procedures for site personnel working in and around contaminated and/or potentially contaminated soil and water during the excavation works. The following is designed to dovetail with the Construction Health and Safety Management Plan. The Link Alliance’s Health and Safety Manager will be responsible for ensuring these procedures are implemented.

The procedures have been developed to provide a framework for managing contamination related effects at the site. However, these procedures are not intended to relieve the owner or controller of the place of work of either their responsibility for the health and safety of their workers, contractors and the public, or their responsibility for the protection of the environment.

All parties working on the Normanby Road early works shall comply with: •

Applicable parts of the Health and Safety Policy;

•

Construction Health and Safety Management Plan;

•

Any requirements of WorkSafe New Zealand;

•

The Health and Safety at Work Act 2016 and Regulations (incl Asbestos Regulations); and

• Any other applicable legislation, regulations, codes and guidelines.

Sub-contractors engaged on the project are required to provide their own Health and Safety Plan for their equipment and workers.

5.1

Control Measures

When considering hazard and risk controls, the hierarchy listed below will be followed, in preference from one to five. Example questions are provided to illustrate each step.

1.

2.

3.

4.

ELIMINATION – does the task that creates the hazard need to be performed?

SUBSTITUTION – can a different tool be used?

ENGINEERING – can the hazard be guarded to protect people?

ADMINISTRATION – are there warning signs and a procedure to address the hazard?

Administrative controls include procedures to reduce the risks associated with identified hazards.

These controls include: a) Job Safety Analysis (JSA) or Task Analysis. b) Work plans. c) Training. d) Warning signs. e) Communication with the Site Manager/HSO. 5. PERSONAL PROTECTIVE EQUIPMENT – is the appropriate PPE being used? The following is noted: a) PPE is considered the lowest level of protection against a hazard. b) No single combination of protective equipment and clothing can provide protection against all hazards; PPE should be used in conjunction with other protective methods. c) The types of PPE will depend on the specific task undertaken. However, certain PPE is required in all work areas.

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Figure 6-1: Hazard hierarchy

5.2

Site Inductions

The provisions of this CDWP shall be outlined to all parties during the site health and safety induction and acknowledged formally as part of the works (i.e. signed project induction register) prior to personnel being allowed on site.

There will be limited access to the works area and only inducted personnel will have access. All personnel shall be inducted with full details of the following: •

Health and safety plan.

•

Daily toolbox meeting requirements.

•

Identification of all hazards, including roles relating to the hazard board and procedures.

•

Restricted areas and their associated requirements.

•

Measures to control exposure to identified hazards including required personal protective equipment.

•

Health and safety controls relating to potentially contaminated soil materials in the works area.

This should include procedures to limit the presence of ignition sources in these areas (e.g. no smoking within or adjacent to construction area, no welding or open flames near areas with high concentrations of hydrocarbon contamination).

•

Procedures relating to contingency measures for unexpected discovery of contamination and incident reporting, including asbestos awareness.

5.3

Daily toolbox Hazard Identification

Daily toolbox meetings shall include hazard identification for the proposed daily activities. A risk-based approach should be applied to the management of all hazards. Once a hazard is identified, it should be assessed to determine the level of risk and consideration should be made to the potential consequence of the harm and its likelihood for occurrence. Once the hazard has been assessed, reasonably practicable steps should be taken to control the hazard applying the following hierarchy of

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Contamination Delivery Work Plan / Management Plan controls (refer Section 7.1). The hazard board and review of controls should be completed daily in toolbox talks.

5.4

Personal Protective Equipment

The minimum PPE required for all persons engaged in any land disturbance activities (potential exposure to contaminated soil or water materials) includes: •

Nitrile gloves/leather gloves/PVC Palm or otherwise as appropriate to the task.

•

Safety boots (ankle high, steel capped with non-slip durable soles).

•

Hard hat.

•

Safety glasses.

•

Long sleeved shirts and long pants or coveralls.

The following additional PPE will be made available if required.

•

Dust masks.

•

Half face respirators fitted with organic and particulate vapour cartridges.

5.5

Personal Decontamination

The Link Alliance will provide a personnel decontamination station during land disturbance works.

This will include a space to remove and store potentially contaminated clothing and hand washing facilities.

A ‘clean zone’ will be provided for site workers to eat, drink, and smoke. Workers will be advised not eat, drink, or smoke outside the clean zone during the completion of land disturbance activities.

Staff must wash their face and hands at the completion of land disturbance activities and prior to eating, drinking, or smoking.

5.6

Communication Plan

Details of communication and consultation procedures are detailed within the Normanby Road early works Communication and Consultation Plan (CCP), including the way in which the general public are to be communicated with on matters relating to the early works, including the management of adverse effects relating to the removal of contaminated fill, and the process for public and affected parties to register a complaint. Refer to Sections 6 and 7 of the CCP.

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6.

Unexpected Discovery of Contamination

6.1 General It is possible that unexpected contamination or hazardous materials could be discovered during the excavation works – including but not limited to the following: •

Intact or broken drums and containers.

•

Soil materials with unusual odours.

•

Indicators of coal tar, e.g. strong naphthalene (moth ball) odour and texture ranging from viscous tar to low density clinker rock.

•

Discoloured or stained water seeps and soils.

•

Hydrocarbon contaminated soil and/or free product.

•

Liquid waste and any material that normally would be sent to a licensed landfill.

During land disturbance works site, workers will actively monitor works areas for the conditions/materials specified above. In the event that one of these is identified, the following actions shall be taken: •

Work will cease.

•

The Link Alliance will contact the CLP.

•

Health and safety restrictions will be implemented including limiting access to the area, shut down equipment to reduce potential ignition sources and move workers to an upwind location.

•

The CLP will advise on the appropriate course of action. This may include the completion of additional soil testing. All sampling and testing shall be completed in general accordance with Contaminated Land Management Guidelines, No.5 – Site Investigation and Analysis of Soils, Ministry for the Environment (revised 2011, MfE 2011b).

•

The Link Alliance/Construction Contractor will notify (in writing) the Team Leader of Central Monitoring of the identification and the proposed course of action recommended by the CLP.

•

Work shall not resume unless authorised by the Link Alliance under advice of the CLP.

•

Record all details on an incident form, including GPS of location, what steps were undertaken, and details of material encountered. If impacted material is to remain on site, the location and type of material observed, along with any analytical sampling results, shall be recorded for inclusion in the Site Validation Report.

•

If the CLP considers it appropriate, the suspected contaminated material may be excavated into a covered bin to allow works to continue with minimum delay.

•

If excavation into a covered bin is inappropriate, construction work should proceed to an area clear of contamination indicators until material testing as necessary defines the material characteristics.

•

If unsuitable material is to be directly loaded into trucks for disposal at a licensed landfill, all appropriate information such as location, quantity and off-site weighbridge dockets must be recorded.

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6.2 Asbestos Should asbestos be observed or suspected during the land disturbance works, all work shall cease, and an asbestos professional will be engaged to review site conditions and provide guidance as to how to proceed.

The following regulations and guidelines should be followed with respect to asbestos management: â&#x20AC;˘

Health and Safety at Work (Asbestos) Regulations 2016.

â&#x20AC;˘

New Zealand Guidelines for Assessing and Managing Asbestos in Soil (BRANZ 2017).

Works can recommence once asbestos has been appropriately managed/safely removed as advised by the asbestos professional.

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7.

Site Validation Report

The CLP will prepare a Site Validation Report (SVR), to be provided to Auckland Council within three months of the completion of the earthworks associated with the Normanby Road early works. The report will include the following: •

A summary of the works undertaken, including a statement confirming whether the excavation of the site has been completed in accordance with the certified CDWP.

•

A summary of inspections and oversight completed by the CLP.

•

The location and dimensions of the excavations carried out, including a site plan.

•

A summary of testing undertaken (if applicable), including tabulated analytical results and interpretation of the results.

•

Records of any unexpected contamination encountered during the works and contingency measures undertaken (if applicable).

•

Details of any validation soil sampling completed in areas of unexpected soil contamination and vicinity of fill material previously identified as exceeding the adopted soil acceptance criteria (if applicable).

•

Copies of the disposal dockets for the contaminated fill and ‘cleanfill’ material removed from the site.

•

Copies of the CLP site inspection documentation.

•

Details regarding any complaints and/or breaches of the procedures set out in the certified CDWP, and how any incidents or complaints were addressed.

•

Results of testing, if required, of any spoil disposed offsite.

•

Results of testing of any imported fill material.

•

Identification of any areas which need on-going monitoring and management.

The SVR will be submitted to Auckland Council for their records. Once within the Auckland Council records system, the public will be able to access this report as part of a property file request.

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8.

References

AECOM 2012: Contaminated Land Assessment City Rail Link. AECOM New Zealand Limited, 2012.

ANZECC 2000: Guidelines for Fresh and Marine Water Quality. Australian and New Zealand Environment Conservation Council, updated 2000.

Air Quality Management DWP 2019: Normanby Early Works: Air Quality Delivery Work Plan. Link Alliance, October 2019.

Auckland Council 2019. Auckland Unitary Plan Operative in Part, updated 10 May 2019.

ARC 2002: Background Concentrations of Inorganic Elements in Soils from the Auckland Region.

Technical Publication No. 153, Auckland Regional Council, October 2001 (reprinted April 2002).

BRANZ 2017: New Zealand Guidelines for Assessing and Managing Asbestos in Soil. Building Research Association of New Zealand, 2017.

CEMP 2019: Normanby Road Early Works: Construction Environmental Management Plan. Link Alliance, October 2019 Edbrooke 2001: Geology of the Auckland area: scale 1:250,000. Institute of Geological & Nuclear Sciences 1:250,000 geological map 3, 2001.

ESCP 2019: Normanby Road Early Works: Erosion and Sediment Control Plan. Link Alliance, October 2019.

Golder 2016: Auckland City Rail, Link Aotea Station to North Auckland Line, Construction and CRL Operation, Contaminated Land Assessment. Golder Associates, 2016 ISCA 2017: City Rail Link IS Technical Manual Version 1.2. Infrastructure Sustainability Council of Australia, 2017 MfE 2001: Good Practice Guide for Assessing and Managing the Environmental Effects of Dust Emissions, Ministry for the Environment 2001.

MfE 2011a: Contaminated Land Management Guidelines No. 1. Reporting on Contaminated Sites in New Zealand. Ministry for the Environment, Revised 2011.

MfE 2011b: Contaminated Land Management Guidelines No. 5. Site Investigation and Analysis of Soils.

Ministry for the Environment, Revised 2011.

NES: Resource Management Act (National Environmental Standard for Assessing and Managing Contaminants in Soil to Protect Human Health) Regulations, 2011.

WasteMinz 2018: 2018. Technical Guidelines for Disposal to Land. Waste Management Institute New Zealand, 2018.

Worksafe 2016: Health and Safety at Work (Asbestos) Regulations 2016.

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Appendix A: Record of CLG, IRP and Auckland Council Comments A1. CLG Comments A CLG was held at 97 Mt Eden Rd on 25 November 2019. Methods to manage potentially contaminated material are acceptable to the CLG. No specific concerns raised.

A2. IPR Comments From a technical perspective, the IPR panellist has no comments; all required elements are adequately addressed.

A3. Auckland Council Comments Section of DWP 4.3.2

4.7.2

Comment

Query to address

Addressed

This section provides a definition of managed fill taken from the WasteMinz Technical Guidelines for the Disposal to Land (2018). However, Auckland Council has not yet adopted this document, in part because it is still being revised and has not been endorsed

by Ministry for the Environment.

Accordingly, could the consent holder please revise this section to include the definition of managed fill as provided under the Auckland Unitary Plan (Operative in Part) for any materials to be disposed of within the Auckland region.

Yes

Accordingly, we would be grateful if this section could be revised to reflect this.

Yes

Accordingly, could this section please be revised to reflect this.

Yes

Accordingly, the managed fill description provided in this section is not considered appropriate for materials being disposed of within the Auckland region, and may only refer to soils to be disposed of outside this region At present this section nominates a sampling frequency of 1 sample per 1500m3 of crushed concrete material imported to site. However, we consider that this rate is too low, and note that a sampling rate of 1 sample per 500m3 has been agreed upon for other CRL project areas recently assessed by Council.

Additionally, we note that the section states that sampling will be analysed via the Western Australian (WA) Department of Health Guidelines for the Assessment, Remediation and Management of Asbestos-Contaminated Sites in

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Contamination Delivery Work Plan / Management Plan Western Australia (May 2009) methodology. However, this guideline has been superseded by the BRANZ (2017) guideline document New Zealand Guidelines for Assessing and Managing Asbestos in Soil, for asbestos assessment and management in New Zealand.

6

Whilst weâ&#x20AC;&#x2122;re generally satisfied with this section of the CDWP, it is noted that no reference is made to the requirement that the Team Leader of Central Monitoring is notified upon the unexpected discovery of contamination as required under condition 161 of the consent.

Could the applicant please revise this section in the same or similar manner.

This has been requested in review comments for the CDWP for other components of the CRL project, and has been addressed by CRL by the inclusion of the following bullet point: The Link Alliance/Construction Contractor will notify (in writing) the Team Leader of Central Monitoring of the identification and the proposed course of action recommended by the CLS Overall feedback: Whilst I am generally satisfied with the documents provided, I note a few discrepancies between the draft CDWP and the CDWPs for other CRL project areas.

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Yes