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Regulatory Approach

For information on the regulatory history of the Botany Groundwater Cleanup Project see Project Background. 

Voluntary Management Proposal (VMP)

In May 2020  the NSW EPA approved an updated Voluntary Management Proposal (VMP) , which states how and when Orica is to continue to clean up the contaminated groundwater. Orica must meet the requirements of the VMP in accordance with environmental legislation. 

The objectives of the VMP are:

  • To protect human health and the environment via hydraulic containment of the chlorinated hydrocarbon contaminant plumes and source areas (as outlined in the GRAMP, [link provided below]). In the case of Penrhyn Estuary and Botany Bay, the hydraulic containment works will prevent contaminant migration to these receptors via groundwater or surface water in order to achieve protection for slightly to moderately disturbed ecosystems using the Australian and New Zealand Guidelines for Marine and Fresh Water (ANZG, 2018);
  • To monitor the nature and extent of the contamination to identify any potential exposures to the contamination that require management; and
  • To investigate potential technologies to remediate contaminant source zones and plumes.

To achieve these objectives Part 3 of the VMP establishes a clear set of undertakings relating to each of the following components of the project:

  • Maintenance of hydraulic containment;
  • Source area management;
  • Contingency measures for the Groundwater Treatment Plant (GTP);
  • Community consultation;
  • Chemical monitoring programs for groundwater and surface water; (These data are used in assessment of risk to human health and the environment)
  • Assessment of risk to human health and the environment.  (This includes additional monitoring programs for relevant environmental media); and
  • Reporting requirements.

The following documents referenced in the VMP provide details about Orica's management and monitoring activities for the Botany Groundwater Cleanup Project:

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Environment Protection Licence

Orica implements its Groundwater Cleanup Project in accordance with an Environment Protection Licence (No 2148) issued by the EPA under Section 55 of Protection of the Environment Operations Act (NSW) 1997.  This licence covers all of Orica’s operations and remediation activities at Botany Industrial Park, including the Groundwater Cleanup Project.  


Contaminated Land Record of Notices

A record of all notices under the Contaminated Land Management Act, 1997 is maintained by the EPA and available on its website.


Licence under Water Industry Competition Act

The Independent Pricing and Regulatory Tribunal (IPART) administers the licensing of private water utilities in NSW under the Water Industry Competition Act (WIC Act) 2006. Under the WIC Act, a corporation must obtain a licence to construct, maintain or operate any water industry infrastructure, to supply water (potable or non-potable) or provide sewerage service by means of any water industry infrastructure. In 2012 Orica GTP was issued Network Operator's and Retail Supplier's licences from the Minister for Finance and Services. IPART reviewed and reissued the licences in 2018. 

The WIC Act requires licensees to develop and implement a Retail Supply Management Plan, a Water Quality Plan and an Infrastructure Operating Plan for the licensed water recycling scheme. Orica's Water Quality Plan and the Infrastructure Operating Plan were audited for adequacy in 2012, with follow-up audits conducted in 2014, 2015 and 2016. Copies of the audit reports (or the executive summaries) are provided below. 


GTP Environmental Impact Statement 

An Environmental Impact Statement (EIS) was prepared for the GTP in 2004 to assess the environmental impacts of the Groundwater Cleanup Project. It described the proposed mitigation measures to manage identified impacts. 

A chart illustrating the different regulatory bodies and how they regulate the different phases of the Groundwater Treatment Plant operation is included below. This chart also provides contact details of the different regulatory authorities.

Flow Chart - Regulation of GTP (PDF 143.6KB)

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