Botany Remediation Projects General Questions & Answers
Chemicals Sale Questions & Answers
In November 2014 Orica Limited announced the sale of its Chemicals business to the Blackstone Group. This Q&A has been prepared in response to a request from community members of the Orica Botany Liaison Committee and relates to Orica at Botany, NSW, Australia.
Which part of Orica at the Botany Industrial Park is to be sold?
The Botany ChlorAlkali Plant (CAP) and associated assets will be sold to the Blackstone Group. Orica is not selling the land that CAP is on to the Blackstone Group. The Blackstone Group will lease the land those assets occupy from Orica.
What happens to the legacy contamination remediation projects?
Orica will retain responsibility for its Botany legacy environmental remediation obligations, including the remediation of the Former ChlorAlkali Plant site, the management of the Hexachlorobenzene waste and implementation of the Botany Groundwater Cleanup Project. Management of these projects will not be changed by the sale. Orica remains committed to meeting its environmental obligations and will continue to comply with all existing regulatory conditions for remediation projects at the site.
How will Orica’s Environment Protection Licence, issued by the NSW Environment Protection Authority (EPA), be affected by the sale?
Orica has applied to the EPA to have the CAP plant excised from EPL2148 and placed in a new Environment Protection Licence issued to Blackstone Group. There are no other changes to EPL 2148 as a result of the sale.
Will Orica’s other remediation agreements with the EPA at Botany be affected by the sale?
How will the sale change operation of the Groundwater Treatment Plant (GTP)?
The GTP is currently operated by the CAP team and this arrangement will continue under a service agreement. Orica will continue to set target groundwater levels for the extraction system for the protection of human health and the environment, and to ensure compliance with licence conditions.
Orica will continue to direct the plant operations and to own the GTP assets. Existing staff will become employees of the new operating company ensuring the GTP will continue to be operated by the same people as before. This arrangement will continue the benefits of stronger local manufacturing support resources and the integration of support teams between the CAP and GTP.
Can the new owner make decisions about upgrades to the GTP over time?
Orica will continue to make decisions about any upgrades to the GTP. Orica retains control over the GTP budget. Any upgrades will be done cooperatively under a service agreement.
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Groundwater Cleanup Questions & Answers
Following is a summary of the questions frequently asked of Orica and the NSW Environment Protection Authority (EPA) at community meetings over recent years, and the response to each.
If you have further questions please contact us.
Questions Asked of Orica
Questions Asked of the Environment Protection Authority NSW (EPA)
Questions Asked of Orica
Is the groundwater moving northward?
Groundwater naturally flows in a south-westerly direction towards Botany Bay, but historical high-volume groundwater extraction in the 1960s to early 1980s by Davis Gelatine and others to the north and north-west of Botany Industrial Park (BIP) had shifted the groundwater flow in that direction during that time. The 'natural' flow direction towards the south-west was restored by the late 1980s when groundwater extraction was significantly reduced.
Why is Orica allowed to sell treated groundwater?
Orica is licensed by IPART under the Water Industry Competition Act to sell treated water. This reduces the demand on towns water. Approximately 4-5 ML/day is being supplied to neighbouring industrial users. The amount varies depending on how much groundwater needs to be extracted to achieve hydraulic containment, reuse of treated water within the GTP and customer requirements.
Orica's ChlorAlkali Plant and Qenos at BIP and neighbouring Solvay Interox all currently use treated water for industrial applications. Treated water is sold at a discount relative to towns water from Sydney Water Corporation, and covers only a small proportion of the annual GTP operating cost.
What is the status of residential bore water testing?
Orica had concerns that residential bore monitoring was been inadvertently encouraging residential bore water use (which is not permitted within the Groundwater Extraction Exclusion Area declared by the NSW Government). Additionally, community interest – as indicated by the number of residents asking for their bores to be sampled – has declined significantly.
As a result Orica discontinued residential bore monitoring in 2011.
How did mercury get to the Southlands site?
Mercury has been detected in some soil samples at Southlands. The main source of mercury on Southlands is likely to be ash from the former Bunnerong Power Station (which naturally contains mercury) that was used widely in the area as fill.
Historical discharges of waste water into Springvale Drain prior to the operating site being connected to the sewer in 1958 likely resulted in contaminated sediments in Springvale Drain on Southlands. These contaminated sediments were excavated from the drain during remediation works in 2000, and stored pending analysis and disposal next to Nant Street (which is adjacent to Springvale Drain on Southlands). Some mercury contamination of surface soils was subsequently identified when the sediments were removed from the site.
The concentrations of mercury detected in soil at Southlands are all less than 400 mg/kg, which is lower than the National Environment Protection Measure (NEPM) value of 730 mg/kg for commercial/industrial sites.
Is there contamination at the BIP near Anderson Street?
The BIP area known as the Anderson Street car park (although no longer used as a car park) was formerly used as a short-term drum storage area. Anecdotal information suggests that some of the drummed waste might have contaminated the ground. Groundwater monitoring in the vicinity of this area indicates that the ground is affected by chlorinated hydrocarbons (CHCs), although the origin of the CHCs has not been verified. The BIP containment line captures groundwater from this area.
Where is the off-site mercury groundwater contamination?
Orica has been monitoring specific groundwater monitoring locations since 2006. Mercury contaminated groundwater has been identified in off-site monitoring locations hydraulically downgradient (i.e., to the south west) of the former ChlorAlkali Plant (FCAP) (where mercury was used in the manufacture of chlorine, caustic soda and hydrogen). Mercury concentrations slightly higher than the value in the ANZECC (2000) Australian and New Zealand Guidelines for Fresh and Marine Water Quality have been detected in locations south of McPherson Street and also south of Beauchamp Road, but all north of Botany Road.
No mercury contaminated groundwater has been detected reaching any surface water bodies, including Springvale Drain, Floodvale Drain and Penrhyn Estuary.
All of the off-site wells included in the Orica investigations are situated in industrial/commercial areas on Beauchamp Road and McPherson Street, Banksmeadow, within the Groundwater Extraction Exclusion Area where the domestic use of groundwater is prohibited.
The aim of the FCAP remediation work is to reduce long-term groundwater impacts. The remediation works will be managed so that groundwater quality is not adversely affected.
Why does Orica need permanent Foreshore Road safety barriers along the Secondary Containment Line?
Ongoing maintenance of the extraction well infrastructure at the Secondary Containment Area (SCA) is required to ensure continued reliable operation of this essential component of the hydraulic containment system. The safety barriers are needed to ensure protection of people working on the Secondary Containment Line (e.g., undertaking maintenance works or collecting groundwater samples). Roads and Maritime Services (formerly the Roads and Traffic Authority) have specific design requirements for road barriers that must be met.
Questions Asked of the Environment Protection Authority NSW (EPA)
Questions around local drinking water concerns in late 2012
This matter had been resolved and Sydney Water had confirmed there was no contamination of drinking water (June 2013 CLC meeting minutes (PDF 2.6MB))
Mutch Park contamination - scope and responsibilities
The Mutch Park area had historically been an uncontrolled landfill and a substance associated with Orica’s historical operations had been found there in low concentrations, but how it got there was unknown. Orica conducted a Human Health and Environmental Risk Assessment (HHERA) some years ago for Mutch Park and it was provided to the EPA, the landowner and Council. (June 2012 CLC meeting minutes (PDF 84.7KB)).
The EPA advised that sand had historically been extracted at Mutch Park and then the area had been used as a landfill. Groundwater monitoring and human health risk assessments had been conducted some years ago and it was concluded that there was no unacceptable risk for adjacent residents or users of the Park. The risk management focussed on Council workers using groundwater for irrigation purposes. Orica had arranged for the risk assessment to be conducted in good faith as very low concentrations of chlorinated hydrocarbons had been identified at Mutch Park.
There is no record of Orica waste being taken to the landfill at Mutch Park and the contamination there is separate to the chlorinated hydrocarbon groundwater plumes that Orica is addressing under the Botany Groundwater Cleanup Project. Botany Council ceased using bore water from Mutch Park as a precaution. (Sept 2012 CLC meeting minutes (PDF 112.5KB))
The City of Botany Bay (CoBB) had tested bore water and contamination had been identified. CoBB advised that it does not use bore water from Mutch Park. CoBB advised there is further testing at Mutch Park being conducted. (Sept 2013 CLC meeting minutes (PDF 83.9KB)).
Claims that there are massive amounts of contamination (barrels) in the area and the government has been told about this many times
Any claims of contamination should be submitted to the EPA in writing, with appropriate evidence, so that they can be investigated. (Sept 2013 CLC meeting (PDF 83.9KB)).
Action #5 Sept 2013 CLC Meeting - Community members of the CLC to pull together information with concerns about claims of contamination for submission to the EPA.
No responses received as at June 2014.
How can we be assured that the testing is truly independent? And that sufficient data are gathered to assess contaminated sites properly
There are national guidelines for the accreditation of independent contaminated site auditors, and applicants have to sit an exam and be assessed by an independent panel. There is a $150k fine or imprisonment for providing fraudulent data. The independent auditor can also seek further data. Sampling and analyses are done by independent consultants and laboratories, which both care about their reputation. If there is concern about the quality of the data or the conclusions derived on the basis of the data, independent reviews can be carried out (e.g., by the regulator if sites are being regulated, by EPA accredited site auditors, or by other independent consultants).
Origin of groundwater contamination in Collins Street, Pagewood?
The groundwater in that area has been contaminated with chlorinated solvents as a result of third party operations upgradient of Collins Street, not from Orica’s legacy operations.
Chlorinated solvents were widely used historically in manufacturing and engineering businesses. (Sept 2013 CLC meeting minutes (PDF 83.9KB)).
Communication around residential bore water restrictions
NSW Health presented a report on Groundwater Usage in Botany and expressed concern that new residents, renters, non-English speaking groups and people who miss their mail don’t know about the four different groundwater extraction exclusion zones. Information about the exclusion zones is available on the Office of Water website. Government is aware of the need to periodically raise the issue of community awareness around groundwater usage and the EPA is working with NSW Health and the Office of Water to identify ways to improve communications. (March 2012 CLC meeting minutes (PDF 74.6KB))
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