What is a Construction Environmental Management Plan?
Our work must be carried out in line with the environmental management measures specified in the Construction Environmental Management Plan (CEMP). The CEMP is a plan that includes all work activities and environment protection measures to minimise environmental risks and is overseen by the Department of Planning and Environment (DPE), the Environment Protection Authority (EPA) and an independent Environmental Representative.
The CEMP has been reviewed and approved by DPE and the independent Environmental Representative, prior to the commencement of construction activities on-site. A waste management procedure for the project has been prepared as part of a CEMP prior to construction. The plan also includes waste management measures and procedures for managing unexpected finds and handling and storing all project spoil, including potentially contaminated substances.
How will you manage the potential for erosion and runoff during construction?
The health and safety of our workers, the public and the environment is our priority and we are committed to building the M1 Pacific Motorway extension to Raymond Terrace in a way that effectively manages the potential waterway pollution from erosion and runoff.
Construction activities associated with building support sites and upgrading surface roads typically involve excavation and earthmoving, which can temporarily expose soil to wind and rain. Our contractors will use a comprehensive suite of erosion and sediment management and mitigation measures at all work sites to manage the potential for exposed soil to be carried offsite.
Erosion and sediment measures will be implemented in accordance with the principles and requirements outlined in Managing Urban Stormwater – Soils and Construction, Volume 1 and Managing Urban Stormwater: Volume 2D Main Road Construction.
What is the potential for dust and exhaust emissions from construction activities?
We know how important it is to manage the potential impact of construction on air quality and we will have measures in place to minimise dust and will monitor air quality every day. As with any building work, creating dust is unavoidable, however we will have an experienced construction team who will plan and carry out work to avoid (where practicable) or minimise the generation of dust and vehicle emissions. They will use effective dust suppression methods including stabilising loose material, watering the site and covering material when it is transported in trucks. We will be monitoring dust around our work sites to ensure our methods are allowing us to meet the limits of our Environment Protection Licence and inform us if we need to make changes. We will maintain all vehicles and plant in accordance with manufacturer specifications to reduce excessive emissions.
How will you be minimising potential construction impacts on air quality?
Construction to build the M1 Pacific Motorway extension to Raymond Terrace will be carried out under an Environment Protection Licence (EPL), issued by the NSW Environment Protection Authority (EPA) which will include limits relating to air quality and dust. When we are building, we will be monitoring dust around the sites to ensure our methods are allowing us to meet the terms of our EPL and inform us if we need to make changes.
Our work must also be carried out in line with the environmental management measures specified in our Construction Environmental Management Plan (CEMP), overseen by the Department of Planning and Environment, the EPA and an independent Environmental Representative.
Some of the standard construction air quality mitigation and management measures to be implemented during construction include:
Reasonable and feasible dust suppression and/or management measures, including the use of water carts, dust sweepers, sprinklers, dust screens, site exit controls (e.g. wheel washing systems and rumble grids), stabilisation of exposed areas or stockpiles, and surface treatments
Selection of construction equipment and/or materials handling techniques that minimise the potential for dust generation
Selection of construction equipment and/or materials handling techniques that minimise the potential for dust generation
Adjustment or management of dust generating activities during unfavourable weather conditions, where possible
Minimisation of exposed areas during construction
Internal project communication protocols to ensure dust-generating activities in the same area are coordinated and mitigated to manage cumulative dust impacts of the project
Site inspections to monitor compliance with implemented measures
To further mitigate potential cumulative project impacts, additional measures may include coordinated scheduling of construction activities and deliveries.
What is land contamination?
Land contamination means chemical substances or waste are present in soil that present a potential or actual risk to health and/or the environment.
Discovering contaminants in soil does not automatically mean a site is dangerous to health. Soils can naturally contain minerals at levels which may be above what is normally expected. Some contamination also occurs naturally such as acid sulfate soils. Not all contamination affects land in such a way it cannot be used productively for industrial, commercial, agricultural, residential or other purposes and where required, soil can often be removed or treated and reused.
While contaminated soil is a potential source of harm, we can eliminate or reduce the risk associated by preventing or minimising human exposure during the construction of the M1 Pacific Motorway extension to Raymond Terrace project.
Will you disturb contaminated soil to build the project?
Soil contamination is typically caused by past industrial activity, use of agricultural chemicals, or disposal of waste, but can also occur naturally. The Hunter Region’s industrial heritage has left potentially contaminated sites across the area and the M1 Pacific Motorway extension to Raymond Terrace extension project has the potential to encounter contaminated soil, rock and groundwater.
We have assessed the potential for land to be contaminated as part of the Environmental Impact Statement before starting construction so any contaminated soil can be adequately planned for. Our Contractors will be using well-established techniques to appropriately manage any contaminated land in accordance with relevant contaminated land legislation and industry standard best management practices to minimise risks and avoid potential impacts.
How will your work at contaminated sites be monitored?
A NSW Environmental Protection Agency (EPA) accredited site auditor will be engaged for the entire duration and extent of the project to ensure that the assessment, remediation, reporting and validation of our work is completed in accordance with Commonwealth and NSW legislation, policy and guidelines.
How will you manage contaminated soil to protect workers, the community and the environment?
The health and safety of our workers, the public and the environment is our priority and we are committed to building the M1 Pacific Motorway extension to Raymond Terrace in a way which effectively manages the risks associated with land contamination.
Contractors will use well-established industry standard techniques and measures to reduce the potential for exposing workers, the community and the environment to contaminated soil or material. These measures will be outlined in the Contractor’s Construction Environmental Management Plan (CEMP) which will be available on the project’s interactive portal once completed. These measures will aim to avoid disturbing contaminated soil, however, in cases when it needs to be moved or is unexpectedly encountered, these best practices will minimise the risks and impacts of the disturbance and ensure the material is handled, treated or disposed of safely and in accordance with relevant Commonwealth and NSW legislation, policy and guidelines.
All work will be carried out in line with the Ministers Conditions of Approval, Environmental Protection Licence and CEMP approved by the Department of Planning and Environment.
What screening and investigations have been done so far?
A screening process along the 15-kilometre project area was completed by experienced geotechnical engineers and environmental scientists that included 288 investigation locations (both on land and in water) during the geotechnical investigations between 2017 and 2021.
The screening process included assessing borehole logs, test pits and well materials. These assessments informed a broadscale understanding of the site conditions. In addition to this screening process, we carried out a detailed environmental sampling program where groundwater quality across the site and its surrounds was sampled from 2017 to 2021. This was completed by installing and monitoring project specific piezometers (devices used to measure liquid pressure) as well as installing 27 wells along the project corridor.
What are the Areas of Potential Contamination Risk (AOPCR) or areas of environmental interest (AEI) along the project corridor?
The contamination assessment completed as part of the M1 Pacific Motorway extension to Raymond Terrace Environmental Impact Statement (EIS) categorised most sites within and next to the project area as representing a low risk of exposing contaminated soil during construction.
The assessment did identify some locations within or near the project’s footprint with a moderate to high risk of exposing contaminated soil during construction. These potential Areas of Environmental Interest (AEIs) include a waste burial site at Tarro, the former mineral sands processing facility at Tomago (RZM), areas along the Hunter River, as well as unsealed areas (i.e. ground that isn’t under concrete, asphalt or other sealed surface).
The risk ranking of moderate to high was based on the potential for contamination to be present and the likelihood of excavation occurring - not on the level of risk to human health or the environment. While a potential hazard has been identified in these AEIs, these areas do not automatically pose a current risk to health as the soils are covered with an adequate barrier (i.e. grass).
The project team will further investigate the AEIs in accordance with the Detailed Site Investigation (DSI) process before disturbing land in these areas. This will enable the project team to appropriately plan for and manage any contaminated material. More information about these locations and the types of potentially contaminated material are provided in Chapter 16 (Soils and contamination) of the Environmental Impact Statement.
How did you identify potentially contaminated land in the Environmental Impact Statement?
We referred to several sources and carried out site inspections during the EIS to determine the potential for land within and next to the project to be contaminated. The sources and investigations included:
Historic and current aerial photographs
NSW Environment Protection Authority Contaminated Sites Register and Record of Notices
Yellow Pages business directory search
Review of previous sediment, soil, groundwater and contamination site investigations carried out within the project area
Visual inspections of surface areas by an environmental scientist
Ongoing consultation with community members.
The objective of these investigations was to find potential AEIs to help the project team identify potential limitations on construction and possible management options.
How will the project determine if land is contaminated?
We are undertaking a staged process to determine if land is contaminated before we start work which disturbs the ground surface. The first stage, completed as part of the Environmental Impact Statement (EIS), identified areas with a potential moderate to high risk of exposing contaminated soil during construction. As outlined earlier, these potentially contaminated areas are referred to as potential areas of environmental interest (AEIs).
Areas which have unsealed ground (i.e. ground that isn’t under concrete, asphalt or other sealed surface) will undergo a second stage Detailed Site Investigation (DSI) by a certified Contaminated Land Consultant before the ground is disturbed. The investigations will provide further information about the extent and level of contamination in the area and recommend if further investigations are required.
The DSI will include assessments of samples taken from within the project construction footprint and will provide an indication of the likely sub surface conditions. The DSIs are intended to enable the project team to appropriately plan for and manage contaminated material.
DSI reports will be completed by the M1 Pacific Motorway extension to Raymond Terrace contractors to gather information to a level appropriate for the early works program.
The DSI reports will be made available on the project’s interactive portal. The third stage will include further Detailed Site Investigations of these areas again before main works start.
What constitutes work that could disturb the ground in a potentially contaminated area?
Any work that exposes underlying soils which could then result in direct contact with project personnel or indirectly with the public or environment via discharges (for example via dust or sediment flows) is considered by the project team to be work that could ‘disturb’ the ground.
Will detailed investigations be undertaken again before main work starts if an investigation has occurred during the early works program?
Detailed Site Investigation (DSI) reports will be completed by the contractor for a number of areas to gather information to a level appropriate for the M1 Pacific Motorway extension to Raymond Terrace early work program.
The M1 Pacific Motorway extension to Raymond Terrace main works contractors will carry out DSIs for all of these work areas again to assess the risk associated with their scope of works.
They will also be responsible for identifying where remediation of contamination is required to complete project works, preparing a remedial action plan where remediation is required, and completing any remediation validation and Site Audit Statement(s) so any remediated land handed back upon completion of the project is suitable for its intended land use.
What happens if you encounter contaminated land during construction?
Any contaminated land encountered during the construction of the project will be managed and treated using well-established techniques, in accordance with relevant contaminated land legislation and industry standard best management practices.
The health and safety of our workers, the public and the environment is our priority and we are committed to building the M1 Pacific Motorway extension to Raymond Terrace in a way that effectively manages the risks associated with land contamination.
What is the process for handling contaminated land?
The first step in appropriately managing contaminated soil is to know that it is there and plan for its safe handling, by assessing the potential for contamination and undertaking detailed site investigations, if required. If contaminated soil is found, it is then classified based on the level of contamination and the physical and chemical properties of the soil.
It is then necessary to manage how the material is handled to make sure no contaminated materials are carried off-site, and workers and the community are adequately protected. All identified contamination risk areas will be managed during construction using a comprehensive suite of environmental management measures outlined in the contractor’s Construction Environmental Management Plan (CEMP) and in accordance with guidelines made or approved under section 105 of the Contaminated Land Management Act 1997.
If required, appropriate remediation action plans and/or environmental management plans may then be developed and implemented to remove, or suitably reduce, the contamination exposure risks during construction. Contaminated soil in small volumes may be managed under a different process. If contaminated material is removed from the site, it will be transported in sealed and covered trucks and disposed of at an appropriately licensed waste facility in accordance with the NSW EPA Waste Classification Guidelines.
What is a remediation action plan?
Remediation can involve removing, reducing or containing contamination or eliminating or reducing any hazard arising from the contamination. There are many different approaches to remediating contaminated soil and the appropriate treatments vary depending on the type of chemicals present in the soil, as well as the extent of the contamination.
A remediation action plan (RAP) outlines the measures to be taken to treat or remove contaminated material to ensure a site is suitable for its intended use. The RAP also details how any risks will be managed. This may include industry best practice dust prevention, control and suppression measures to manage and minimise the impacts of dust emission, minimising the extent of spoil stockpiles and revegetating or sealing areas of disturbed soil as soon as practicable.
During early works, contractors will remove contaminated soil, make good any areas that have been disturbed and identify them for the main works contractor.
The main works contractors will obtain a Site Audit Statement from NSW Environment Protection Authority accredited Site Auditor before starting any soil remediation work. This will certify the RAP is appropriate and the site can be made suitable for use. The Site Audit Statement and its accompanying Site Audit Report will be submitted to the Department of Planning and Environment and relevant Councils after the contaminated material is remediated.
Where is contaminated soil disposed?
The levels and mobility of chemical compounds in contaminated soil can render it hazardous waste, preventing it from going to landfill. This triggers a requirement for the soil waste to be disposed of at a licensed facility that can lawfully receive or treat it to lower the levels of contamination or immobilise the contaminants.
While most of the soils encountered on the project will be clean, some material is anticipated to be contaminated as a result of previous industrial activity. Where required, this waste will be disposed of at facilities licensed to accept the waste or to a treatment facility that can reduce the concentrations of contaminants prior to disposal.
What will you do if you find unexpected contaminated material in an area being used for construction?
Many kinds of unexpected materials can be encountered during excavation works including buried waste, discoloured and odorous soils and asbestos. These unexpected finds are likely to be associated with poor waste disposal and/or construction activities undertaken historically at the site.
Because the potential for encountering unexpected contamination exists in every project involving excavation, the project team will prepare an unexpected finds procedure to follow in these scenarios.
In the event that previously unidentified contaminated material is discovered, all relevant work would stop near the discovery and the unidentified contaminated material would be managed in accordance with the unexpected finds procedure.
Material which displays some or all of the following characteristics will be considered by the project team as possibly contaminated and will trigger the unexpected finds procedure:
unusual odour from soils that are not detected in other similar areas
discolouration or staining of soil or rock
seepage of unusual liquids from soil or rock
unusual odours, sheen or colour on groundwater and/or surface water
unusual metal objects
unexpected underground storage tanks, buried drums or machinery
presence of waste or rubbish above or below ground
potential asbestos containing material.
The Contractor’s Construction Environmental Management Plan (CEMP) will also consider the potential for odorous soil to be encountered during any subsurface excavation work and specify appropriate procedures to minimise odour generation and/or exposure including containing and removing the material.
What is a construction environmental Management Plan?
Our work must be carried out in line with the environmental management measures specified in the Construction Environmental Management Plan (CEMP) overseen by the Department of Planning and Environment (DPE), the Environment Protection Authority (EPA) and an independent Environmental Representative.
The CEMP will be reviewed and approved by DPE and the independent Environmental Representative, prior to the commencement of construction activities on-site. A waste management procedure for the project will be prepared as part of a CEMP prior to construction. The plan also includes waste management measures and procedures for managing unexpected finds and handling and storing all project spoil, including potentially contaminated substances.