SISCO and SEPR Pilot Trial – Barangaroo
MP10_0087
Response to Preferred Project Report
Submission to the Department of Planning 14 February 2011
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
City of Sydney ABN 22 636 550 790 GPO Box 1591 Sydney NSW 2001 Australia Town Hall House 456 Kent Street Sydney NSW 2000 Australia Phone +61 2 9265 9333 Fax +61 2 9265 9222 TTY +61 2 9265 9276
[email protected] www.cityofsydney.nsw.gov.au
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
1.0 Executive Summary... 2
2.0 Structure of this submission ...4
3.0 Health ... 5
4.0 Traffic and Transport... 7
4.1 Construction Traffic Management Plans ... 7
4.2 Pedestrian Amenity... 8
4.3 Attachment H of the Environmental Assessment: Construction Traffic Management Plan ... 9
5.0 Tree Management and Protection ... 10
6.0 Conclusion ... 11
Contents
Attached Report Environmental Strategies Review of Technical Risk, Former Gasworks Site, 110001RP01_v1, February 2011
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
1.0 Executive Summary
Project Application MP10_0087 seeks approval for the pilot trial of in-situ technologies to remediate soil and groundwater contamination at Barangaroo, in particular Block 5 and a part of Hickson Road (DECCW Declaration Area).
This submission provides comment on the pilot trial alone and does not comment on or imply support for any excavation or construction works that might occur at the same time as any remediation trial. Concurrent activities are regarded as entirely separate issues involving high levels of concern.
To inform the City of Sydney’s response, a completely independent risk review has been commissioned from a suitably qualified auditor1. This submission refers to, and is guided
by this specialist advice.
In principle, the City of Sydney supports remediation of contaminated land in situ2 (i.e., in
the location it was contaminated rather than excavated and dumped ex-situ) utilizing green technology, but only following a successful sequence of lab testing, pilot trials (with results made known to the interested community prior to proceeding) and installation of
safeguards during the actual remediation work, and monitoring. The City’s support is highly dependent on stringent safeguards and clearly developed contingencies, planned for and agreed to, prior to the commencement of works. This is also particularly relevant as the Hickson Road and adjoining sub-surface site conditions will be noticeably divergent from laboratory testing conditions which do not reproduce the highly variable sub surface conditions found at Barangaroo resulting from an uncompacted, in-filled harbour shoreline. While the proposed pilot trial is supported conceptually, its acceptance and implementation must first address gaps in details contained in the publicly available plans and reports prior to planning approval as discussed in the Attached Report to this submission. In-situ contamination plans must ensure that the works are cautiously carried out with any anticipated side effects (particularly vapour release and leaching) being controllable, and that the completed work is subject to validation and ongoing monitoring after completion. It is noted that the proposed SISCO methodology by Verutek has been deployed at a former contaminated gasworks site in New York3 and many other sites that were not
gasworks (refer to Attached Report). The ground conditions however were not the same. This does not mean that this technological approach should not be investigated and evaluated, but it does mean that high level safeguards and contingencies need to be well worked out and made clear exactly when and how they would apply.
1 Environmental Strategies Review of Technical Risk, Former Gasworks Site, 110001RP01_v1, February 2011 2 Technology of surfactant in situ chemical oxidation based on organic compounds
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
The Preferred Project Report (PPR) by JBA Planning on behalf of Lend Lease dated January 2011 unfortunately does not detail safeguards and contingencies to an adequate level despite high levels of concern raised by the community and the City of Sydney. One of many reasons for this concern includes evidence of ongoing contaminated groundwater leaching under the adjoining Hickson Road residential redevelopment site basement as a result of earlier remediation in the same context.
Summary
1. It is the City’s conclusion that the PPR does not sufficiently address the risks associated with the specific site conditions (highly variable and inhomogeneous mix of tidally influenced rock and fill) including the possible extent of vapour release (although addressed but response not sufficient). It also does not address the specific remediation for the final intended land use (residential and publicly accessible
recreational water body) compared to satisfying DECCW satisfaction. This must also be addressed before any approval is given. The PPR should distinguish between satisfaction of the Remediation Action Plan (RAP) requirements in order to lift the DECCW Declaration and satisfaction of the need to separately ensure that the same ‘remediated’ land is actually suitable for the intended land use from a human health and ecological perspective.
2. The PPR and other documents do not appear to address the possible reuse of remediated spoil at the Headland Park from a human health and ecological perspective.
Both of these aspects (points 1 and 2 - satisfaction of intended land use at
Barangaroo South and reuse of spoil at Headland Park) should be addressed by the applicant to the satisfaction of the City of Sydney and the Department of Planning through the requirement for Human Health and Ecological Risk Assessment(s) prior to approval or commencement.
3. A number of safeguards and contingencies remained unresolved or undocumented and need to be included in any publicly available Plans before approval is issued (or the commencement of any work).
To assist with understanding the issues and arriving at recommendations, the City of Sydney commissioned a Review of Technical Risk (ES Report) by Rod Harwood, Site Auditor of Environmental Strategies. This report responded to a brief to provide an independent assessment of the publicly available documentation. The ES Report 11001RPO1_v1 dated February 2011 forms the Attachment to this submission.
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
In summary, it recommended that the following be required by the Department of Planning before any approval is given (or if any approval is given, as a condition precedent of a deferred commencement):
4. Recommendations as per the ES Report: an amended Final Work Plan
an amended Waste Management Plan
an amended Noise and Vibration Impact Assessment an amended Geotechnical Assessment
an amended Soil and Water Impact Assessment including ground water flow diagrams to show the relative positions of in situ treatment wells and monitoring wells
an amended Air Quality Impact Assessment
a Risk Management Matrix de developed in accordance with AS/NZS 4360
further investigations in regards to the potential for bedrock fractures and the potential for contaminant migration.
5. Recommendations of the City of Sydney:
completion of a Human Health and Ecological Risk Assessments (HHERAs)
separate Plan associated with meeting the requirements of the intended use over and above satisfaction of the Declaration
acid sulphate management plan
post completion testing and ongoing monitoring with suitable responses amended Construction Traffic Management Plan
2.0 Structure of this submission
The five previous Recommendations in the earlier submission by the City of Sydney provide a consistent framework approach for this February 2011 Response, with additional commentary directly related to the January 2011 PPR.
The PPR and supporting documentation was referred to various technical units within the City of Sydney. Technical comments have been taken into consideration in the formation this response.
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
3.0 Health
Original Recommendation 1 (submission 24 December 2010)
The following health related issues should be resolved as part of the Preferred Project Report or as conditions of consent:
1. A separate Health and Safety Plan (HSP) should be prepared in accordance with table 4.2 of the Interim Advice Letter, prior to any works commencing. The HSP should be certified, peer reviewed and independently endorsed by an occupational health and safety expert.
2. An accredited Site Auditor should review and comment on the Air Quality Assessment and Human Health Impact Assessment provided by AECOM and provide a further updated Interim Advice Letter prior to commencement of any works.
3. Clarification should be sought from the Site Auditor as to whether there will be any adverse impact on the existing groundwater treatment system already installed and operational at 38 Hickson Road.
4. The hours of work are kept within the standard hours of work from 7am-7pm Mondays to Fridays and 7am-5pm on Saturdays.
5. Upon finalisation of the project a separate Site Audit Statement from an accredited Site Auditor should be submitted to Council.
Comment: In regards to point 1, it is noted that the Proponent has committed to the preparation of a site specific HSP, its certification and review, prior to commencement of works.
Noting the outstanding issues raised in the ES Report, including insufficient detail in regards to the Final Work Plan, Waste Management Plan, Noise and Vibration Impact Assessment, Geotechnical Assessment, Soil and Water Impact Assessment, Air Quality Impact Assessment, Risk Management and the
potential for bedrock fractures and the potential for contaminant migration, Council’s concerns regarding points 2, 3 and 5 above remain.
Council is also of the opinion that in addressing the issues identified in the ES report, the Department of Planning should also ensure that Human Health and Ecological Risk Assessment(s) (HHERA) are completed, a separate Plan associated with meeting the requirements of the intended use over and above satisfaction of the Declaration; an acid sulphate management plan is provided and a documented methodology in regards to post completion testing and ongoing monitoring with suitable responses is provided.
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
Until such time as the outstanding matters identified in ES Report and above are adequately addressed to the satisfaction of Council, Council’s contentions remain.
The Department of Planning should formulate an appropriate condition in relation to hours of construction, limiting the Proponent to the hours provided in point 4.
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
4.0 Traffic and Transport
4.1 Construction Traffic Management Plans
Original Recommendation 2 (CoS submission dated 24 December 2010)
The following traffic/transport issues should be resolved as part of the Preferred Project Report or as conditions of consent:
1. A route for construction vehicles is to be formulated and adopted for the entire Barangaroo development in conjunction with the City (Traffic Operations and Transport Strategy) and the Roads and Traffic Authority (RTA).
2. All construction staff should be encouraged to use public transport to access the area. Secure provision for storage of tools on-site should be recommended in order to further limit the need to drive to the area by construction staff. Any parking for required vehicles should be catered for on-site.
Comment: The Proponent’s commitment to reviewing and refining the Construction Traffic Management Plan (with future amendments including adoption of a single route for construction vehicles for the entire Barangaroo development) is supported by the City.
The Department of Planning should ensure that this commitment is reaffirmed via conditions of consent, with the final, and any amendments to any
Construction Traffic Management Plan formulated and approved by the City (Traffic Operations and Transport Strategy) and the Roads and Traffic Authority (RTA) prior to works commencing.
In regards to point 2, it is noted that the Proponent has committed to
encouraging workers to utilise public transport, providing on-site storage and parking for required vehicles.
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
4.2 Pedestrian Amenity
Original Recommendation 3 (CoS submission dated 24 December 2010)
The following issue should be resolved as part of the Preferred Project Report or as a condition of consent:
1. The City is concerned about any bike route changes in the area especially given the existing speed cushions that are located along Hickson Road. Further consideration needs to be given on how bike riders in the area will be impacted.
Comment: The Proponent has stated that Traffic Control Plans detailing the proposed signage and line marking of the cycle lanes and alternate paths will be provided as part of any Construction Traffic Management Plan at road
occupancy licence stage. Given Council is no longer the Roads Authority for
Hickson Road, it appears Council has been removed from the road
occupancy licensing approvals process. This is inappropriate from a strategic point of view considering Council is the appropriate agency to consider the contextual impacts such licences can have on essential networks such as cycle, pedestrian, traffic, parking, parking metre and loading.
Council’s previous point is reiterated, that the final and any amendments to any Construction Traffic Management Plan be formulated and approved by the City (Traffic Operations and Transport Strategy) and the Roads and Traffic Authority (RTA) , prior to works commencing. This includes any changes to cycle, pedestrian and vehicle networks.
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
4.3 Attachment H of the Environmental Assessment: Construction Traffic Management Plan
Original Recommendation 4 (CoS submission dated 24 December 2010)
The following clarification should be sought as part of an amended CTMP to be submitted with the Preferred Project Report:
1. There should be no short-term disruptions that impact on the operation of the temporary wharf. This includes all days when a cruise ship is expected to be berthed at the facility. Details should be provided.
2. The description of the “On-street construction zones” which are to be implemented 'when needed', is unclear and needs to be clarified.
Comment: The Proponent has reiterated a commitment to not cause unreasonable impact on the operation of the temporary wharf but has not provided any details of how this will be managed (especially in relation to cruise ship berthing days). The Department of Planning should ensure an appropriate condition of consent is imposed requiring an amended Construction Traffic Management Plan to be lodged that specifically addresses this issue and provides an appropriate methodology.
Council’s previous concern is reiterated that the final, and any amendments to any Construction Traffic Management Plan, be formulated and approved by the City (Traffic Operations and Transport Strategy) and the Roads and Traffic Authority (RTA) , prior to works commencing.
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
5.0 Tree Management and Protection
Original Recommendation 5 (CoS submission dated 24 December 2010)
The following information should be provided to the City’s Tree Management unit prior to commencement of works and should inform any conditions of consent:
1. A qualified Consultant Arborist who holds the Diploma in Horticulture
(Arboriculture), Level 5 under the Australian Qualification Framework shall assess the proposal and provide specific tree protection measures if required. This information must be provided to the City’s Tree Management unit prior to commencement of works.
2. Tree Protection Measures prepared by a Consultant Arborist must accompany all hoarding applications.
3. Street Tree Canopy Protection
a. Construction vehicles must drive appropriately to maintain an adequate clearance of 500mm from all street tree canopies (including major branches and/or tree trunks) located along the construction access route, at all times. b. If any pruning is required to accommodate vehicles utilising the approved
construction access routes or to accommodate the loading/unloading of vehicles, the City’s Street Tree Contract Coordinator (9265 9333) must be contacted immediately to assess the tree/s and determine if pruning is required. Street trees must not, under any circumstances, be pruned to provide clearances for construction vehicles without obtaining prior written consent from Council.
4. Tree Protection during Construction
c. Stockpiling, storage or mixing of materials, washing of equipment, vehicle parking, disposal of liquids, machinery repairs and refuelling, disposal of building materials such as cement slurry, siting of offices or sheds and the lighting of fires, must not occur within 5 metres of the trunk of any tree to be retained.
d. Excavation must not occur within 5 metres of the trunk of street trees located on Hickson Rd. If excavation is proposed within this zone, the applicants Site Arborist must provide specific tree protection measures and construction methodology, to the City for review and approval, to ensure trees are not damaged.
e. All protection measures are to remain in place for the duration of the development works, and shall be removed at the completion of the project. Comment: The Proponent’s commitment to the above points is supported by the City. Council reiterates that all of the above should be provided to Council for our approval prior to works commencing on site. The Department of Planning should ensure appropriate conditions of consent are imposed to this effect.
DRAFT STATUS - City of Sydney Submission to Department of Planning MP10_0087 – SISCO and SEPR Pilot Trial– Barangaroo
6.0 Conclusion
The City of Sydney supports the remediation of the contaminated land and the intent of the Project Application in principle with clear qualifications. Post consideration of the
Environmental Assessment, the City of Sydney obtained completely independent advice from a contamination expert Site Auditor. The findings of the Site Auditor are supported by Council. The identified outstanding issues by Rod Harwood are of great concern to Council.
It is recommended that the Department of Planning seeks clarification and additional information on the matters identified in the ES Report and matters detailed in this submission before any approval is given (or if any approval is given, as a condition precedent of a deferred commencement).
Attachment
Environmental Strategies
Review of Technical Risk
, Former Gasworks Site
Review of Technical Risk:
Proposed S-ISCO & SERP Remediation System
Former Gasworks Site
Barangaroo, NSW, 2000
11001RP01_v1
Prepared for City of Sydney Council > February 2011
es
Environmental
Strategies
PROVIDING BENEFITS
www.environmentalstrategies.com.au
> PROVIDING BENEFITS
es
Environmental
Strategies
PROVIDING BENEFITS
www.environmentalstrategies.com.au
> PROVIDING BENEFITS
Review of Technical Risk ‐ Barangaroo 1 11001RP01_v01
Issue/Revision Issue 1 Revision 1 Revision 2
Remarks Final
Date February
Prepared by Rod Harwood
Signature
Checked by Rod Harwood
Signature
Authorised by Rod Harwood
Signature Project Number 11001 File Reference 11001RP01_v01
Review of Technical Risk ‐ Barangaroo 2 11001RP01_v01
Table
of
Contents
1
Executive
Summary
...
3
2
The
Process
...
4
3
Literature
Review
...
6
4
Summary
of
Environmental
Issues
...
10
4.1
Waste
...
10
4.2
Impact
to
Water
...
10
4.3
Chemicals
...
11
4.4
Impacts
to
the
Unsaturated
Zone
and
Potentially
to
Air
...
11
4.5
Potential
Health
Impacts
...
11
4.6
Residual
Contamination
...
11
4.7
Possible
Geotechnical
Issues
...
12
Review of Technical Risk ‐ Barangaroo 3 11001RP01_v01
1
Executive
Summary
The technology of surfactant enhanced insitu chemical oxidation makes sense in that the surfactant may remove
the contaminant out of the soil matrix into an emulsified or liquid form, when the oxidant can break the double
bonds and chains, and create less toxic by‐products.
A treatability trial demonstrated strong breakdown from laboratory studies, which used homogenised samples
which are unlikely to be replicated in an insitu process.
Initial Research has indicated that the VeruTEK S‐ISCO process has only been used in pilot trials to date with no full
scale clean ups currently documented. We reserve the right to vary such an understanding pending receipt of a
formal response from VeruTEK.
Our research indicates that the New York Gas works pilot study contained much more uniform and permeable
subsurface conditions than the Barangaroo site, which contains heterogeneous fill and potential impact to the
Hawkesbury Sandstone bedrock. Such conditions may render the proposed pilot trial to consider both applications
to fill as well as the bedrock. The degree of impact to the bedrock from the existing gas holder requires further
study and has not been covered within the reports reviewed.
The review of the Final Work Plan and Construction Management Plan from VeruTEK states that a soil vapour
extraction system will treat gases generated but there appear to be no conceptual design calculations in relation to
capture zones, the number and configuration of extraction wells and the amount of gas (and the compound
concentrations or mass) that will be removed. Appendices (figures) in the Final Work Plan are not annotated
appropriately nor have text accompanying them to understand design in more detail. Information regarding the
spacing of vapour extraction points and the efficacy of removal of gas is not provided.
The Audit report does not review the Lab treatability report and states that the soil vapour extraction be used as a
contingency and that water injection tests should be completed before the trial to assess interconnectivity of the
groundwater system. This review considers that the soil vapour extraction data and the behaviour of the
groundwater need to be understood now and not as a contingency.
The ERM report (overarching RAP) states that a human health and environmental risk assessment (HHERA) will be
used to determine clean up levels. The DECCW review of the pilot test does not mention that this process will be
used although DECCW were commenting specifically on the pilot trial and therefore may not have wished to
address this issue.
More details are also required to ensure that the monitoring is suitable to determine potential connection, or lack
thereof, of the pilot study to the sensitive areas of Hickson Road, or to the deep excavation.
The review cannot comment on the success or otherwise of the pilot trial but stresses the need for more design
details before the pilot trial progresses. There appears to be no appropriate discussion in any of the reviewed
Review of Technical Risk ‐ Barangaroo 4 11001RP01_v01
2
The
Process
The treatment objectives for in situ chemical oxidation (ISCO) vary from site to site and include, among others,
reduction in contaminant toxicity/mass/concentration, and/or a reduction in contaminant mass flux across a site
boundary. ISCO (in situ chemical oxidation) is a source‐depletion technology that is capable of removing
substantial amounts of DNAPL in source zones at sites with favourable hydrogeological conditions. ISCO is capable
of achieving partial DNAPL depletion, which may provide other performance benefits including eliminating the
mobility of the DNAPL, and reduction in the mass discharge rate of DNAPL constituents from the source zone,
which may reduce environmental risks.
Due to significant challenges required of ISCO to meet stringent Regulatory clean‐up standards, monitored natural
attenuation is an integral component in the overall remedial strategy for source zone and downgradient plumes.
ISCO involves the introduction of a chemical oxidant into the subsurface for the purpose of transforming
groundwater or soil contaminants into less harmful chemical species. Several different forms of oxidants have been
used in the ISCO process, however the focus of this review is on the proposed oxidation process at Barangaroo
using a proprietary form of hydrogen peroxide oxidation in conjunction with a surfactant enhanced chemical
oxidation.
The type and physical form of the oxidant indicates the general materials handling and injection requirements. The
persistence of the oxidant in the subsurface is important since it affects the contact time for advective and
diffusive transport and ultimately the delivery of the oxidant to the targeted zones in the subsurface.
VeruTEK have developed a surfactant enhanced in situ chemical oxidation process called S‐ISCO (Surfactant
Enhanced In Situ Chemical Oxidation) which depends on them choosing the correct surfactant or
surfactant/cosolvent mixtures that will create the most effective soluble micelle or microemulsion with the NAPL
present in the soil. Once the soluble micelle or microemulsion has formed and the apparent solubility of the NAPL
is thereby increased, the increased‐solubility micelle or microemulsed NAPL can enter “aqueous phase reactions”
and, in the case of the C‐ISCO remediation, it can be oxidised by a chemical oxidant such as hydrogen peroxide.
The process is reported by VeruTEK to be a new field‐verified coelution technology capable of reducing the amount
of source NAPL present in soils and reducing the flux of groundwater constituents associated with these sites. It
uses biodegradable food‐grade surfactants, and has been used by VeruTEK in situ and ex situ remediation projects
for several years. VeruSOL is an entirely bio‐based mixture composed of citrus‐based compounds and plant oil‐
based surfactants. They are generally recognised as safe (GRAS) by the US Food and Drug Administration (USFDA),
or are approved as indirect food additives. VeruSOL has excellent capability, when dissolved in water, to bring
most hydrocarbons and oils into oil‐in‐water microemulsions, which creates its capabilities as a component to
simultaneous in situ chemical oxidation. VeruSOL is reported to solubilise immiscible organic compounds into
groundwater, and free radical‐based chemical oxidants such as sodium persulphate and hydrogen peroxide, are
used to simultaneously destroy the contaminants.
VeruTEK report that the S‐ISCO process takes advantage of increased solubility of NAPL or sorbed contaminants
without the need for extraction‐well recovery of injected and treated liquids. It eliminates the necessity of
complete liquid pumping and extraction recovery of the solubilised NAPL. Elimination of extraction systems avoids
challenges associated with the capture of complete plumes; above‐ground treatment Systems; requirements to
recycle surfactant or surfactant/cosolvent mixtures; and disposing of the bulk liquid.
According to VeruTEK, during S‐ISCO remediation, contaminants made more soluble are not mobilised and will not
migrate from the treatment area. The co‐eluted surfactant/co‐solvent and oxidant fronts move through the
Review of Technical Risk ‐ Barangaroo 5 11001RP01_v01
place. The type of behaviour seen in this process reportedly makes it useful in remedying gas plant sites, as well as
sites with hydrocarbons and other contaminants.
VeruTEK use another proprietary process called Surfactant Enhanced Product Recovery (SEPR). It is a technology
platform which uses plant‐based natural surfactants and hydrogen peroxide to enhance product recovery of non‐
aqueous phase liquids (NAPL). Surfactants and hydrogen peroxide are injected into the subsurface, and NAPL,
along with the solubilised NAPL, are extracted. SEPR is used as a pre‐treatment for S‐ISCO to enhance the
efficiency and cost‐effectiveness of the process.
Chemicals used in the S‐ISCO and SEPR processes are hydrogen peroxide, sodium persulphate and sodium
hydroxide, as well as proprietary products VeruSOL and FE‐TAML. These products as well as the products of their
chemical reaction are reported to be harmless to the environment. For the Pilot Trial, hydrogen peroxide will be
used at low concentrations, ranging from 2% to 16%.
Potential by‐products of the reaction from use of S‐ISCO and SEPR, VeruSOL and Fe‐TAML include hydrogen
peroxide, sodium persulphate, sodium hydroxide, and products of their chemical reactions are reported by
VeruTEK to be harmless to the environment. When hydrogen peroxide reacts with contaminants, the products of
the reaction are water, oxygen and carbon dioxide.
If the soil naturally contains high levels of iron, hydrogen peroxide can potentially become over‐reactive. Tests
using Barangaroo site soils indicate that concentrations of iron in site soils are not sufficiently high to consume the
peroxide and the potential for over‐reactive conditions is considered by VeruTEK to be highly unlikely.
Sodium persulphate used with sodium hydroxide to activate the persulphate and balance pH, decomposes to into
sodium ions, sulphate ions and hydroxide, and are considered by VeruTEK to have no impact on adjacent
properties or Darling Harbour.
VeruTEK report that Fe‐TAML is a stable, highly reactive Green catalyst able to utilise hydrogen peroxide to destroy
contamination. It was developed by the Institute for Green Oxidation Chemistry at a University in Pittsburg, USA.
It is composed entirely of biochemically common elements, including carbon, hydrogen, oxygen, nitrogen, and
iron. Neither Fe‐TAML or its degradation products are considered capable of generating toxicity concerns. It is
considered to be an efficient and selective peroxide activator, is water‐soluble, and is effective in minute quantities
over a broad pH range.
It is reported by VeruTEK that there is no known potential for S‐ISCO chemicals to react with unknown
contaminants or non‐toxic chemicals which may be present in the treatment area to form a hazardous or
Review of Technical Risk ‐ Barangaroo 6 11001RP01_v01
3
Literature
Review
(a) VeruTEK
VeruTEK was incorporated in 2006 with headquarters in Bloomfield, Connecticut. It reportedly has a staff of 15
and a capital value in the order of $US33M. It provides green nanotechnology solutions for cleaning up the
environment and is reportedly leader of a new industry – green solutions for environmental remediation. The
company has developed soil remediation technologies which enable a controlled dissolution and desorption
process, eliminating the need for contaminated soil excavation. VeruTEK implements site specific remedies with
surfactant/oxidant combinations reportedly environmentally safe and non‐intrusive to adjoining communities.
VeruTEK has a co‐operative agreement with Carnegie Mellon University to include the University’s Fe‐TAML
catalysts into VeruTEK’s green technology platforms.
Carnegie Mellon University first developed tetra‐amido macrocyclic ligand (TAML) activators, which are made from
elements found in nature and work in combination with hydrogen peroxide to convert harmful pollutants into less
toxic or harmless substances. These TAML’s were first identified in 1995 and have been the subject of substantial
research. It was discovered that Fe‐TAML’s destroy a multitude of pollutants in water and soil by reactions with
hydrogen peroxide. Initial studies focused on the ability of Fe‐TAML’s to rapidly and successfully destroy
oestrogens in water which were incapable of being removed from domestic sewage treatment systems. Since then
a substantial body of research has identified the environmental benefits of Fe‐TAML in destroying a range of
contaminants generated by a variety of industries.
Published literature indicates that VeruTEK’s collaboration with Carnegie Mellon University has provided a product
of green designer molecules which are allegedly safe and extremely versatile in remediating in situ contamination.
Fe‐TAML has been widely researched since approximately 2000 and its benefits printed in a large number of
research and other papers from countries including USA, Denmark and New Zealand. In 2007 the New York State
Department of Environmental Conservation (NYSDEC) had accepted S‐ISCO test report and approved the use of
this remedial technology at a former manufactured gas plant site in Bay Shore New York. The technology was used
to safely clean up coal and tar related contaminants in soils and groundwater beneath buildings without having to
move residents. A third party report evaluating the effectiveness of S‐ISCO states “…complete or near complete
remediation…” can be achieved. S‐ISCO is the first of a line of coelution technologies developed by VeruTEK that
uses biodegradable, food‐grade plant extracts such as coconut oils, castor oils and soybean oils, and oxidants to
safely destroy contaminants in soil and groundwater.
In September 2008 VeruTEK was awarded 1st prize as the Energy, Environment and Green Tech Company of the
Year for 2008 presented by the Connecticut Technology Council and the Connecticut Centre for Advanced
Technologies.
Several case studies are presented by VeruTEK on its website to show its practicable application to the S‐ISCO
remedial technology process. These are:
Bloomfield, Connecticut November 2008; successful completion of in situ remediation of soil and groundwater at a former gas manufacturing plant using its proprietary technologies. A total of 1,200 cubic yards of soil was treated within 3 days and the total petroleum hydrocarbons in the soils were reduced from an average 4,500ppm to 235ppm, and all VOC’s and naphthalene were below required criteria. New York City, February to May 2010. Creosote contamination at a tidally –influenced site on the shores of the East River. Contamination included BTEX, naphthalene, and PAH’s. Contamination was
Review of Technical Risk ‐ Barangaroo 7 11001RP01_v01
present as residual NAPL at between 17 – 21ft bgs. More than 80% of the contaminant mass was located below the water table at between 8 – 24ft bgs. VeruTEK have so far completed a pilot trial which indicated that the S‐ISCO treatment decreased the maximum soil gas CoC concentrations by up to 96.5%. New York. Former gas plant in residential and commercial neighbour, contaminated by PAH’s and TPH present in the soil, groundwater and an estuarine surface water body. Contamination estimated at 900kg of PAH and BTEX located beneath the former 8100sq ft former generator house. The majority of contamination was between 30 – 35ft bgs. A third party consultant oversaw the remediation process and confirmed that the S‐ISCO process destroyed gas plant contamination at the site in a safe and controlled manner, and that S‐ISCO can achieve complete or near‐complete treatment of gas plant contaminated materials. Niras, Denmark. This case study refers to a site contaminated by free phase DNAPL including TCE, PCE, DCE, and other chlorinated organic compounds. Remediation is incomplete but sampling indicates that remediation is proceeding in the same manner as it had in laboratory‐scale investigation and the site is on schedule to achieve the remedial objective of eliminating the presence of chlorinated DNAPL. It is noted that the laboratory‐scale investigation succeeded in destruction of more than 99% of contaminants. Holley, Georgia. This site was contaminated with diesel. Implementation of the VeruTEK resulted in the NAPL having been successfully treated with confirmation that the presence of diesel had been reduced to less than 1000ppm, the threshold required by the State of Georgia. The case studies also make reference to additional projects, one involving chlorinated hydrocarbons, another referring to removal of TPH from a construction site, and a third referring to the cleanup of a heating oil spill which migrated under a residential property. (b) US EPA
The US EPA has produced a number of papers on in situ chemical oxidation (ISCO), both under its own banner, or
through collaboration with researchers in the field of in situ chemical oxidation. Reports include such papers as DNAPL’s ‐ a Review of Emerging Characterisation and Remediation Technologies;
Engineering Issue Paper ‐ In Situ Chemical Oxidation;
In Situ Chemical Oxidation ‐ Performance, Practice and Pitfalls; and In Situ Chemical Oxidation ‐ State of the Art.
All of these Papers and reports deal with the science of in situ chemical oxidation (ISCO), which has been used by
the environmental industry for years. In one extensive EPA paper titled “Engineering Issue ‐ In Situ Chemical
Oxidation”, the authors address the several types of chemical oxidation (permanganate, hydrogen peroxide and
iron, Fenton‐driven or H2O2‐ derived oxidation, and ozone) and note that ISCO can be deployed under a variety of
applications, both in unsaturated and saturated zones, and under a variety of hydrogeological environments. They
further note that potential advantages and disadvantages of ISCO should be assessed when considering the
deployment of this technology. Some are listed below:‐
Advantages
Applicable to a wide range of contaminants;
Contaminants are destroyed in situ;
In Situ treatment may reduce costs relative to other treatment methods;
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Enhanced mass transfer (enhanced desorption and NAPL dissolution); Heat from H2O2 reactions enhances mass transfer, reaction rates and microbiological activity; Potentially enhances post‐oxidation microbiological activity and natural attenuation; Relatively fast treatment. Disadvantages Oxidant delivery problems due to reactive transport and aquifer heterogeneities; Natural oxygen demand may be high in some soil/aquifers; Short persistence of some oxidants due to fast reaction rates in the subsurface; Health and safety issues regarding the handling of strong oxidants; Potential contaminant mobilisation; Potential permeability reduction; Limitations for application at heavily contaminated sites; Contaminant mixtures may require treatment trains; May have less oxidant/hydraulic control relative to other remedial technologies.
The report addresses the importance of recognising the physical differences between bench‐scale testing, pilot
studies and field scale systems, and recommends the scaling up from bench to field‐scale systems must be heavily
scrutinised. It further addresses related issues such as groundwater monitoring, rebound in the post‐oxidation
period, safety issues, the potential for generation of toxic reaction by‐products, process residuals, and other
related issues. It concludes that over the last 10 years, significant development of ISCO has dramatically advanced
the state of the science, practice and effectiveness of this technology. It has been used on thousands of hazardous
waste site in the US, and is the fastest‐growing subsurface technology used there today. The authors reference
over 150 research and technical papers and reports used in the development of this particular report.
Numerous other US EPA reports have also been reviewed in relation to the science and application of ISCO. The
reviewers of these documents provides feedback, commentary and reviews, all of which appear to have been
captured in the main EPA document on ISCO reviewed above.
At this time, no papers, research or other commentary has been found from Regulators in relation to the S‐ISCO
process developed by VeruTEK and Carnegie Mellon University, other than a report indicating that VeruTEK had
won the Energy, Environment, Green Tech Company of the Year for 2008, awarded by the Connecticut Technology
Council and the Connecticut Center for Advanced Technologies. The New York State Department of Environmental
Conservation awarded the remediation of a gas plant/coal tar site to VeruTEK and the site is reported to have been
successfully remediated in 70 days using 12 injection wells and 27 monitoring wells.
(c) Other Sources
ES has reviewed reports and papers on ISCO prepared by environmental consultants researchers and Universities.
Each offers a different perspective on the science, the process or the application of ISCO, but generally all confirm
that ISCO is a viable and cost‐effective remediation method , but one which requires attention and care to expand
from bench test to pilot trial to full site remediation. All are generally positive on the process as reflected by the
fact that it is the fastest‐growing remedial technology in the US, and considerable research is being undertaken in
the field of in situ chemical oxidation to further understand the process and improve the science.
No research or other commentary is available on the S‐ISCO process other than that provided by VeruTEK and
Carnegie Mellon University, as they are at the forefront of developing a green, and allegedly more efficient ISCO
process into the market ( named S‐ISCO).
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(d) Suppliers
A number of research and other papers and reports are available from Carnegie Mellon University. The earlier
reports, dating back to 2003 discuss the benefits of Fe‐TAML in destroying oestrogen in waterways where local
sewage treatment systems were incapable of sufficiently reducing concentrations to levels where they would be
harmless to aquatic biota. Concurrent studies showed that Fe‐TAML would successfully destroy OCP’s and other
pesticides, dioxins, and hydrocarbons. Toxicity testing of materials contaminated with phenols, pesticides, organic
dyes and pharmaceuticals at the University of Auckland NZ, in collaboration with Carnegie Mellon University,
indicated that the toxicity of treated samples was “lower to non‐existent”. Other papers refer to success in
destroying polyols, pulp paper processing by‐products, textile dye manufacturing, and anthrax.
In later studies Fe‐TAML was combined with hydrogen peroxide and added to sewage effluent. The compound was
found to successfully destroy several oestrogenic compounds, with no toxic products resulting from the process.
Research is currently underway to demonstrate that Fe‐TAML’s can work with oxygen in addition to hydrogen
peroxide, thereby extending the range of applications made possible through the use of Fe‐TAML.
Hydrogen Peroxide is an oxidising agent for organic and inorganic chemical processing as well as semi‐conductor
applications, bleach for textiles and pulp, and treatment of municipal and industrial waste. The versatility of
hydrogen peroxide is shown by the variety of oxidation potentials and pH ranges. Hydrogen peroxide can act as an
oxidiser. In the acid pH range un‐catalysed hydrogen peroxide is a moderate oxidiser, while catalysed with iron it
becomes a powerful oxidiser. In the alkaline pH range hydrogen peroxide can compete with hypochlorite as an
oxidiser. Because of hydrogen peroxide’s properties, numerous applications such as bleaching, odour control, and
waste water treatment have been developed. It is also used in refinery , oil, gas and petrochemical applications. In
site remediation, hydrogen peroxide is often an oxidant of choice for soil and groundwater remediation. It has
numerous applications both in the industrial and medical industries, and is readily available in most countries.
Solvay Interox is one of Australia’s larger suppliers of hydrogen peroxide.
Sodium Persulphate is a strong oxidant widely used in many industries for initiating emulsion polymerisation
reactions, clarifying swimming pools, hair bleaching, and micro‐etching of copper printed circuit boards. In the last
few years there has been increasing interest in sodium persulphate as an oxidant for destruction of a broad range
of soil and groundwater contaminants. It is readily available for industrial applications in most countries.
Sodium Hydroxide, also known as lye or caustic soda is a caustic metallic base. It is used in many industries , mostly
as a strong chemical base in the manufacture of pulp and paper, textiles, drinking water , soaps and detergents,
and as a drain cleaner. It is now also finding uses in the environmental remediation industry. Current manufacture
is in excess of 75 million tonnes worldwide, and is readily available.
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4
Summary
of
Environmental
Issues
The reports listed in Appendix A were reviewed in order to determine the proposed nature and extent of the Pilot
Trial to be carried out at Barangaroo. That review identified questions which were not addressed or not fully
addressed in these documents. Primary issues identified in the review are identified below.
4.1 Waste
Aecom have provided a Waste Management Plan and procedures intended to manage and minimise the
generation of waste during the Pilot Trial. While estimated volumes of waste to be collected and stored prior to
disposal have been provided, it appears no assessment of estimated volumes for liquid streams have been
provided either as a volume per unit of time, or an estimated total volume.
This review assumes that the Pilot Trial design has been determined on an estimated input/output calculation
which would determine the likely rates and volumes of liquid recovered, and therefore requiring treatment or
disposal. An estimate of volumes and resulting disposal mechanisms (particularly by road) would be beneficial.
4.2 Impact to Water
It is noted that water injection tests before the Pilot Trial are proposed in order to assess interconnectivity, but it is
not clear why these tests cannot be activated now, rather than waiting for the start of the Pilot Trial. It is assumed
that results of these tests would be beneficial in determining details of the actual Pilot Trial.
The ISCO process is exothermic and from review of printed media this process has the potential to generate heat.
Such a process has the potential to generate offgases/vapours including among them benzene and naphthalene
and other unidentified potentially hazardous vapours. The surfactant part of the process is designed to make
contaminants more miscible and therefore more mobile in water It is not certain if the ISCO process will destroy
any and all contaminants released into groundwater and whether all of these will be identified as part of the
groundwater monitoring process.
DECCW have expressed concern regarding the potential for the ISCO process to mobilise metals in groundwater,
which in turn have the potential to migrate in to Darling Harbour. The potential for the process to mobilise metals
in groundwater appears not to have been addressed anywhere in current documentation.
The review notes that VeruTEK refer to negative effects in groundwater beyond the treatment zones, therefore
migration of treatment effects is a likely outcome. Details of these effects are not specified and the potential for
these effects to bypass the proposed monitoring system have not been specifically addressed in the
documentation reviewed..
It is recommended that groundwater flow diagrams be provided to show the relative positions of in situ treatment
wells, and monitoring wells, as well as flow direction of groundwater in the vicinity of the treatment areas,
including the expected zone of influence of contaminant treatment, to ensure that a sufficient number and spacing
of monitoring wells is positioned relative to the potentially impacted area.
The proposed excavation of a basement carpark within Blocks 2 and 3 at Barangaroo, adjacent to the Pilot Trial
areas has the potential to impact groundwater flow conditions in the Pilot Trial areas. It is recommended that
assessments be undertaken to determine the likely zone of influence of basement carpark excavations and
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4.3 Chemicals
The Aecom report identifies dangerous goods to be stored at the Pilot Trial site, namely hydrogen peroxide,
sodium persulphate and sodium hydroxide. It is intended that the maximum quantity of these chemicals to be
stored at the site will be below the threshold limit required to activate the conditions of SEPP33, and therefore a
preliminary hazard analysis is not required. This review recommends that a site‐specific Health and Safety Plan is
prepared which specifically includes hydrogen peroxide.
4.4 Impacts to the Unsaturated Zone and Potentially to Air
The likely changes in temperature in the Pilot Trial subgrade generated by the exothermic reaction has the
potential to release contaminant vapours into the subsurface, and to atmosphere. Benzene and naphthalene are
cited as potential products of the destruction process but it appears no investigation has been undertaken into
additional hazardous vapours which could be released by the destruction processes.
Reports indicate significant generation of VOC’s with naphthalene during the ISCO process. It is further noted that
the VeruTEK bench test reports large amounts of gas formation at the base of the column, causing clogging. From
this it must be surmised that the Pilot Trial has the potential to generate large volumes of VOC’s into the subgrade.
The proposed vapour recovery system provides insufficient detail to support an assessment of the volume of VOC’s
requiring recovery into an air treatment system, or the area which will require vapour recovery, to ensure that
public health is not put at risk.
Aecom’s Air Quality Impact Assessment report refers to the destruction of in situ contaminants and uses air
dispersion modelling to determine potential impacts beyond the generation zone. This ES review is concerned that
the generation zone has not been well defined. Also the proposed SVE filtration system requires more detail to
determine its applicability and effectiveness with the chemical of concern and the anticipated concentrations.
This review expresses concern regarding the use of deodorants to mask odours but ignores the health risk of
contaminants potentially contained within these masked odours and the impact on public health. The Pilot Trial
reports make no mention of the potential for VOC accumulation in adjoining buildings or basements and no air
sampling appears to be proposed in these buildings.
Risk assessment does not appear to address all contingencies including the potential of equipment breakdowns or
power outages at a time when vapour recovery is essential to protecting human health.
4.5 Potential Health Impacts
The primary potential health impact is identified by vapour release from either the vapour extraction and
collection system, or fugitive vapour releases from either within and beyond the installed vapour collection system.
These have the potential to generate adverse impacts to air quality with resultant risk to human health.
As noted previously, this review recommends a site‐specific Health and Safety Plan be prepared and include all
chemicals stored or used at the site. This review stresses that without appropriate design of capture, fugitive
emissions may be possible and those emissions are potentially toxic.
4.6 Residual Contamination
The VeruTEK bench test results indicate a significant destruction of CoPC’s in a short time. These bench tests have
necessarily been completed using homogenised soil samples. While these tests indicate excellent treatment
potential, the Pilot Trial will be carried out in a far more heterogeneous subgrade. The purpose of the Pilot Trial is
to demonstrate the effectiveness of the S‐ISCO system within such a heterogeneous medium, including potentially
the sandstone bedrock. The purpose of the Pilot Trial is necessarily to demonstrate the effectiveness of this
system in actual in situ conditions, and a detailed monitoring program will be required to demonstrate the success
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4.7 Possible Geotechnical Issues
Excavation of blocks 1,2 and 3 for a basement car parking area within Blocks 2 and 3, adjacent to the Pilot Trial
area has the potential to impact the sandstone bedrock in the Pilot Trial area, and the bedrock between the Trial
area and the excavation.
Impacts created by vibration through the bedrock foundation from excavation works to more than 27m below
existing surface could potentially affect fractures already existing in the sandstone foundation, and provide new or
expanded migration pathways for contaminants.
Current geotechnical assessment within the existing tar tank beneath Hickson Road extended only to the base of
the tank and not into sandstone bedrock beneath the tank. While Aecom indicate review of existing data shows
little contaminant impact into the sandstone bedrock, this review considers that such a view has not been
adequately demonstrated. This review considers it unlikely that the pilot study will effect migration pathways in
the sandstone but more technical justification of this is required by reference to known geotechnical and structural
properties of the Hawkesbury Sandstone.
This review concludes that the proposed pilot trial technology may be suitable but may be hampered by the
heterogeneity of the subsurface profile. Further, important aspects of the design process to ensure protection of
human health and the environment, have not been addressed to the satisfaction of this Audit. Our literature
search also indicates no current large scale (beyond pilot scale) application of the chosen technology.
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Appendices
Review of Technical Risk ‐ Barangaroo 16 11001RP01_v01
Appendix
A
Summary
Report
of
all
Documents
Reviewed
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Summary
of
Documents
Reviewed
(1) JBA Urban Planning (17 June 2010) Part 3A Request for Minister’s Declaration. Surfactant
Enhance In Situ Chemical Oxidation (SISCO) Pilot Trial.
A letter directed to Department of Planning (DoP) referring to a meeting between DoP and Lend Lease to discuss
the proposed remediation methodology for the Barangaroo site. Lend Lease explain its proposal to undertake
future in situ remediation works comprising a chemical treatment technique as an option to treat and remove
contaminants known to be present in the soil and groundwater on part of the Barangaroo site and Hickson Road.
A pilot trial is proposed in an area that has been declared a Remediation Site under the CLM Act.
The purpose of the communication is to request the Minister’s opinion that the Pilot Trial is a development of the
type described in the Major Development SEPP, and requests that the Minister issue the requirements for the
preparation of an Environmental Assessment to accompany a Project application. The letter further describes the
pilot trial and the Statutory framework relevant to the application. Key issues are identified. Audit Review Comments
The Auditor has no additional comments to make regarding this document.
(2) JBA Urban Planning (November 2010) Environmental Assessment Report, Project
Application.
The project application seeks approval to pilot trial two in situ technologies to facilitate remediation of soil and
groundwater contamination on block 5 and part of Hickson Road. The technologies are being assessed for their
potential to remediate contamination previously identified on the site and Hickson Road.
The pilot trial is to assess the methodology as suitable for remediation at the Barangaroo site with a view to using
this technology for future full scale remediation works at the site. The project application addresses a range of
issues including traffic management and accessibility; soil and water impacts; air, noise and odour issues;
construction management; waste management; archaeological issues; and visual impacts.
The report identifies the Director General’s Environmental Assessment Requirements and provides a detailed
description of the Statutory framework, including a description of the environmental issues which are addressed in
detail in separate reports prepared by Aecom.
Lend Lease makes a series of commitments in relation to each of the identified environmental issues as a means of
warranting that all pilot trial environmental works will be undertaken in accordance with the respective
environmental plans, and to Regulatory criteria. Audit Review Comments
The Auditor notes that the Pilot Trial has been classified as Category 1 Remediation Works under SEPP55. The
storage of dangerous goods has been identified as being exempt from the requirements of SEPP33. The Auditor
has no additional comments.
(3) NSW Dept of Planning (14 July 2010) Director General’s Requirements for the SISCO Pilot
Trial.
Following a request from JBA Urban Planning Consultants the Director General has responded by providing a list of
