Construction Monitoring Plan

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    Bell Bay Pulp Mill Project

    ConstructionMonitoring Plan

    BBA-PLN-1000-1400-001H-B-00

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    1. Purpose and Scope

    The purpose of the Construction Monitoring Plan is to describe how BBA intends to monitor airquality, noise and vibration, ground water quality, surface water quality, marine water quality,

    marine sediments, dinoflagellate cyst and marine ecological quality for the construction phase ofthe Bell Bay Pulp Mill and associated infrastructure. Specifically it aims to aid effectivemanagement of the risk associated with impacts potentially generated during the constructionactivities undertaken as part of the project. The implementation of an effective constructionmonitoring program (CMP) is necessary for several reasons including:

    Awareness of possible pollution issues and the appropriate and timely mitigation of suchissues.

    To enable quantification of possible impacts and tracking of performance of mitigationmeasures.

    The following table details the construction monitoring components associated with construction

    of each section of the Pulp Mill and associated infrastructure and the relevant schedules of thePulp Mill Permit. Marine mammal and turtle monitoring is included as it relates to noise impacts,but is separate to, and does not include, noise monitoring.

    PULP MILL PERMITLU 1 2MN3.1 TO 2MN3.7 Page 63 of 201

    LU3 CN3.1 to 3.7 Page 19 of 50LU4 CN3.1 to 3.7 Page 20 of 52

    EM1 MN2.1 to 2.7 Page 10 to 11 of 25Mill SiteLU1

    WharfLU1

    SolidWasteLU1

    LocalReservoirLU1

    WaterSupplyPipelineLU1

    LU3LU4

    WasteWaterPipelineLU1

    EffluentOutfallEM1

    WorkersAccomm-odationLU2

    QuarryLU1

    Construction StartDate

    05/02/08 28/04/08 03/08/08 03/08/08 12/05/08 17/10/08 30/06/08 15/04/08 TBA

    Air Monitoring

    Noise Monitoring GroundwaterMonitoring

    Surface WaterMonitoring

    Marine WaterMonitoring

    NA NA NA

    Dinoflagellate CystMonitoring

    NA NA NA NA NA NA NA NA

    Marine SedimentMonitoring

    NA NA NA TamarCrossing/Donovans

    Bay

    NA NA NA

    Marine EcologicalMonitoring

    NA NA NA Tamar

    Crossing/Donovans

    Bay

    NA NA NA

    Marine Mammals andTurtle Monitoring

    NA NA NA Donovans

    Bay

    NA NA NA

    NA : Not applicableNote: Dates are in accordance with the Construction Timetable submitted to the Director of

    Environmental Management on 31st January 2008. Dates reported are subject to change pendingactual construction start.

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    2. Applicable Permit Conditions

    Schedule Part Section Number Sequential page

    LU1 3 2 2MN3.163 of 201

    (Seq. 76)

    LU3 3 - CN3.119 of 50

    (Seq. 258)

    LU4 3 - CN3.120 of 52

    (Seq. 309)

    Permit condition

    EM1 MN2.110 of 25

    (Seq. 351)

    Permit wordingPrior to the commencement of construction activities, or by a date specified in writing bythe Director, a Construction Monitoring Plan must be submitted to the Director forapproval.

    Schedule Part Section Number Sequential page

    LU1 3 2 2MN3.263 of 201

    (Seq. 76)

    LU3 3 - CN3.219 of 50

    (Seq. 258)

    LU4 3 - CN3.220 of 52

    (Seq. 309)

    Permit condition

    EM1 MN2.210 of 25

    (Seq. 351)

    Permit wording The plan must be prepared in accordance with any guidelines provided by the Director,and must be prepared in consultation with relevant Government agencies.

    Schedule Part Section Number Sequential page

    Permit conditionLU1 3 2 2MN3.3

    63 of 201

    (Seq. 76)

    Permit wording

    The plan must be consistent with the requirements of these conditionsand include the following programs:

    (a) an Air Monitoring Program;(b) a Noise Monitoring Program;(c) a Groundwater Monitoring Program;

    (d) a Surface Water Monitoring Program;(e) a Marine Water Quality Monitoring Program;(f) a Marine Sediment Monitoring Program;(g) a Dinoflagellate Cyst Monitoring Program; and(h) a Marine Ecological Monitoring Program, which must be consistent with, but notlimited to, the monitoring design described in Section 3 (Donovans Bay Crossing)and Section 4 (Long Reach Wharf) of the Aquenal Pty Ltd report to Gunns Limitedtitled Ecological Monitoring Program for Marine andEstuarine Habitats during theConstruction and OperationPhases of Gunns Limiteds Proposed Pulp Milldated 21December 2006.

    Schedule Part Section Number Sequential pagePermit condition

    LU3 3 - CN3.3

    19 of 50

    (Seq. 258)

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    LU4 3 - CN3.320 of 52

    (Seq. 309)

    Permit wording

    The plan must be consistent with the requirements of these conditionsand include the following programs:

    (a) an Air Monitoring Program;

    (b) a Noise Monitoring Program;(c) a Surface Water Monitoring Program;(d) a Marine Water Quality Monitoring Program;(e) a Marine Sediment Monitoring Program; and(f) a Marine Ecological Monitoring Program, which must be consistent with, but notlimited to, the monitoring design described in Section 3 (Donovans Bay Crossing)and Section 2 (Tamar River Crossing) of the Aquenal Pty Ltd report to Gunns Limitedtitled Ecological Monitoring Program for Marine andEstuarine Habitats during theConstruction and OperationPhases of Gunns Limiteds Proposed Pulp Milldated 21December 2006.

    Schedule Part Section Number Sequential page

    Permit condition

    EM1 MN2.3

    10-11 of 25

    (Seq. 351-352)

    Permit wording

    The plan must be consistent with the requirements of these conditionsand include the following programs:

    (a) a Marine Water Quality Monitoring Program;(b) a Marine Sediment Monitoring Program; and(c) a Marine Ecological Monitoring Program, which must be consistent with, but notlimited to, the monitoring design described in Section 3 (Donovans Bay Crossing)and Section 5 (Effluent Pipeline Sub Sea Interval) of the Aquenal Pty Ltd report titledEcological Monitoring Program for Marine andEstuarine Habitats during theConstruction and OperationPhases of Gunns Limiteds Proposed Pulp Milldated 21December 2006.

    Schedule Part Section Number Sequential page

    LU1 3 2 2MN3.463 of 201

    (Seq. 76)

    LU3 3 - CN3.419 of 50

    (Seq. 258)

    LU4 3 - CN3.420 of 52

    (Seq. 309)

    Permit condition

    EM1 MN2.410-11 of 25

    (Seq. 351-352)

    Permit wording

    The plan must include, but is not limited to, details of the following:(a) a table containing all of the major commitments made in the plan;

    (b) an implementation timetable for key aspects of the plan; and(c) a reporting program to regularly advise the Director of the results of the plan.

    In addition to the above conditions, there a numerous conditions that relate to constructionenvironmental monitoring. These conditions are identified and summarised in the relevantsections of this plan, with the relevant permit page number for ease of linking the monitoring tothe permit condition.

    The requirements of the permit conditions are summarised for convenience (they are notverbatim due to a desire to reduce space).

    Responsibilities and reporting requirements are at the end of each section.

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    3. Monitoring Programs

    Air Monitoring

    Applicable permit conditions

    Schedule Part Section Number Page Requirement

    LU1 3 2 2MN3.363 of 201(Seq. 71)

    CMP to include air monitoring

    LU3 3 - 3.319 of 50

    (Seq. 258)CMP to include air monitoring

    LU4 3 - 3.320 of 52

    (Seq. 309)CMP to include air monitoring

    LU1 3 3 3AM11.2 107 of 201(Seq. 120)

    Dust Management Plan to include a description of how

    web cameras and direct visual monitoring of dustemissions will be utilised for dust mitigation purposesduring construction activities

    LU1 3 3 3AM13.1108 of 201(Seq. 121)

    Requires a web cam visual monitoring system to beestablished

    Objectives

    The primary objectives of the monitoring plan are to quantify airborne dust resulting from BBAconstruction activities and enable BBA

    1to take corrective action in real time to minimise the potential for

    and mitigate the effects of airborne dust on the sensitive receptors in the areas surrounding the pulp milland associated infrastructure.

    Background

    The pulp mill site and associated infrastructure have the potential, if the protocols detailed in theConstruction Environmental Management Plans are not followed, to generate unacceptable fugitivenuisance dust emissions. This report concentrates on monitoring protocols only - mitigation measuresare addressed in the Construction Environmental Management Plans and Dust Management Plan.

    Potential risk areas are nearby residences to the mill/wharf and pipeline easements and the section ofthe East Tamar Highway adjacent to the mill site,

    Mill and Wharf

    A risk assessment of the construction activity on the closest residents located at Rowella, afterconsideration of management measures (road watering etc), shows a moderate/low probability ofsignificant plumes being vectored towards Rowella. The prevailing wind pattern and the short period of

    significant ground disturbance, which may or may not occur during dry and dusty conditions (latesummer) were all considered in the assessment and work in favour of minimising potential impact.

    Under normal construction conditions, dust will be minimised through various measures including carefulplanning of works, siting and covering of stockpiles, and watering of work areas and haul roads. Realtime monitoring equipment will be used to measure wind direction and speed at the construction site,and dust total suspended particles (TSP) and PM10 at Rowella, and will automatically send messagesto key personnel to inform them of potential dust impact when TSP > 90 g/m

    3or PM10 >50 g/m

    3. On

    receipt of a public complaint or alert message, or when a wind alert status is experienced (winddirection is between 330 and 100 degrees and wind speed is >5 m/s, or wind speed is >7.5m/s in anydirection), or if an unacceptable dust emission is observed by personnel on site, then the web cam dustsurveillance system will be used to confirm that a dust plume is emanating from the mill construction siteand to determine the source of the dust generation. Additional dust mitigation measures, includingwatering of affected areas, will then be used to target dust sources. If dust concentrations measured at

    1Bell Bay Alliance consortium John Holland. Mc Mahon and Gunns.

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    the dust monitoring stations do not drop below trigger levels or if significant visible dust plumescontinue to leave the site and potentially impact on sensitive receptors, after 30 minutes fromcommencement of the additional mitigation measures, the activity generating the dust will be stopped.

    Landfill, Reservoir, Workers Accommodation, Water Pipeline and Effluent Pipeline.

    The remoteness of the solid waste disposal and local reservoir sites suggests that likelihood of dustevents from these areas is low.

    The waste water and water supply pipelines at a number of locations pass very close to residents. It isimportant to manage dust at these sites to prevent potential fugitive dust from creating a nuisance. Thiswill be achieved through regular visual inspection of the site to identify dust status and use of portableanemometers to assess wind status. If complaints are received or if the construction supervisor or siteenvironmental officer deems that there is the potential for excessive dust emission from any of theseconstruction activities, a portable continuous dust monitor capable of measuring TSP or PM10 shall beused to assess the extent of the problem. Under normal construction conditions, dust will be minimised

    through various measures including careful planning of works, siting and covering of stockpiles, andwatering of work areas and haul roads. If visual inspection of the site or measurements of TSP >90 g/m

    3or PM10 >50 g/m

    3are taken with the portable dust monitors, then additional dust mitigation

    measures, including watering of affected areas, will be used to target dust sources. If dustconcentrations measured at the sensitive receptors with the portable dust monitors do not drop belowtrigger levels or if significant visible dust plumes continue to leave the site and potentially impact onsensitive receptors, after 30 minutes from commencement of the additional mitigation measures, theactivity generating the dust will be stopped.

    Monitoring methodology mill and wharf sites

    A combination of live monitoring of wind speed and direction, live particle monitoring and regular visual

    monitoring and inspection, is required to provide immediate feedback and implementation of mitigationmeasures, if required. The following methodologies will be implemented:

    Wind Monitoring Locations:

    Sources of wind direction/speed information for this project are:

    Daily weather forecast this will be a topic at the morning tool box meeting for the earthmovingcrews with special cognisance of air humidity and wind speed.

    Wind direction sensor and anemometer at the construction supervisors office located at the millsite the supervisor will be responsible for monitoring this and reporting to his crew when thewind is in the critical arc and/or speed.

    Continuous data from the Rowella Air Quality Monitoring Station mobile messaging tonominated mobile phones will alert the Construction Supervisor, Site Environmental Officer andGunns environmental team when the wind is in the critical sector and speed.

    The location of the Rowella AQMS is shown on the attached map Figure 1.

    Alert Status Levels:

    The alert status is a wind speed and/or direction that trigger interrogation of dust monitoring stations atRowella, observation of the dust web cam, visual inspection on site and, potentially, implementation ofadditional targeted mitigation measures at the construction site.

    The alert critical conditions are:

    Wind direction sector 330 to 100 degrees and wind speed >5 m/s, or

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    Wind speed >7.5 m/s regardless of wind direction

    If it is raining the above critical conditions will not apply.

    Identification of Alert Status:

    Continuous data from the Rowella Air Quality Monitoring Station via mobile messaging of windspeed/direction to nominated mobile phones will alert the construction supervisor, site environmentalofficer and Gunns environmental team when the wind is in the critical sector and speed for potentialnuisance dust impact on Rowella.In addition the Construction Supervisor will be responsible for monitoring the wind direction sensor andanemometer at the construction site office, to determine if the wind is in the critical arc and/or speed forpotential nuisance dust impacts on sensitive receptors.

    Particle Monitoring:

    Dust Monitoring Stations

    Two dust monitoring stations will be located at nearby Rowella residences. These stations will compriseTurnkey Osiris Air Quality Monitors, capable of real time continuous measurement of total suspendedparticles (TSP) and PM10. When the 15 min average PM10 exceeds 50 ug/m

    3or the 15 min average

    TSP exceeds 90 ug/m3

    a message will be automatically sent to a nominated mobile phone held by thesite environmental manager. The locations are shown on the attached map.

    Rowella Air Quality Monitoring StationThe continuous PM10 monitor at the Rowella AQMS will be interrogated when the wind is in the criticalarc and speed.

    Observations

    An observed increase in PM10 or TSP levels will trigger viewing of video camera surveillance informationand visual inspection of the site to confirm whether a dust plume is emanating from the mill site. Thesource of the dust plume will be identified and appropriate control measures will be implemented.

    Web Cam Visual Monitoring System:

    A web cam visual monitoring system will be installed to facilitate real time visual monitoring of dustemissions during construction activities:

    The system comprises one camera, located on the roof of an existing building at the fish farm (ReferFigure 1) on the western side of the Tamar River where it has clear uninterrupted views of the mill andwharf sites. Although additional cameras could be added to the system if required and justifiable; thesingle camera is considered to provide adequate coverage and at this stage there is no reason to

    conclude that more are required.

    The camera will be mains powered with wireless link from the camera location.

    The system will provide real-time, streamed, date/time stamped images. Snapshot images will bearchived every 10 minutes. It also stores continuous images to allow investigation of complaints.

    The camera has software to allow pan, zoom capability and is controllable over the internet by DTAEusing a supplied web based application.

    The recording system includes a web based software package to access and control live and recordedimages from the camera. This application also allows remote access to archived images stored on theserver.

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    Air Monitoring

    For security, only authorised users will have access to the system.

    The provider of the system will provide training to Gunns, its contractors and DTAE to enable

    configuration of the VPN on any PC with internet access.

    Gunns will provide DTAE with the appropriate software to allow secure, remote accessibility at any time.

    Gunns, the Site Construction Supervisor and DTAE will have secure access at all times to the system.

    Visual Monitoring:

    Under normal conditions and ongoing dust mitigation, effectiveness of those measures will be assessedthrough daily inspection of the site by the Site Environmental Officer or Construction Supervisor withextra vigilance shown during periods of hot and dry weather.

    During a wind alert status, after a public complaint, after an alert from the dust monitoring stations or

    when a dust emission is reported by any personnel on site, the Construction Supervisor or SiteEnvironmental Officer will interrogate the surveillance camera and visually inspect the site directly. Directvisual inspection on site will include checking if significant dust plumes have the potential to impact onsensitive receptors including Rowella and the East Tamar Highway. Significant visible dust plumesleaving the site will trigger additional mitigation measures.

    The same monitoring methods (particle monitors and visual monitoring) will be used to determine ifadditional dust mitigation measures have been successful in preventing fugitive nuisance dust, andassist in the decision of whether to cease activities causing dust and when those activities can resume.

    Monitoring methodology landfill, reservoir, workers accommodation, water pipelineand effluent pipeline.

    Due to the transient nature of the construction of the water and effluent pipelines and workers

    accommodation facility and the remoteness of the landfill and reservoir it is not appropriate for the use offixed particle monitors. Dust monitoring and management on these sites will rely more on portableinstruments and regular visual monitoring.

    Wind Monitoring Locations:

    Sources of wind direction/speed information for this project are:Daily weather forecast this will be a topic at the morning tool box meeting for the earthmoving crewswith special cognisance of air humidity and wind speed.Portable anemometer the supervisor will be responsible for monitoring this and reporting to his crewwhen the wind is in a critical arc and/or speed.

    Alert Status Levels:

    The alert status is a wind speed and/or direction that trigger regular visual inspection on site and,potentially, implementation of additional targeted mitigation measures at the construction site.

    The alert critical conditions are:Wind direction towards sensitive receptors, and wind speed > 5 m/s, orWind speed >7.5 m/s regardless of wind direction

    If it has been raining for longer than 15 minutes then the above critical conditions will not apply.

    Particle Monitoring:Where necessary, during hot dry conditions, wind alert status, or in response to a public complaint, thesite environmental officer will use a portable dust monitor to measure TSP and PM10 at or close to the

    relevant sensitive receptor. This is to ensure that dust in the health affecting particle size range is alsomeasured, in conjunction with visual monitoring of visible (nuisance) dust, to prevent potential adverse

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    health effects from dust.

    When the 15 min average PM10 exceeds 50 ug/m3

    or the 15 min average TSP exceeds 90 ug/m3

    thiswill trigger visual inspection of the site to confirm whether a dust plume is emitted from the construction

    site, identify the source and implementation of appropriate controls.

    Visual Monitoring:

    Under normal conditions and ongoing dust mitigation, effectiveness of those measures will be assessedthrough daily inspection of the site by the Site Environmental Officer or Construction Supervisor withextra vigilance shown during periods of hot and dry weather.During a wind alert status, after a public complaint, after a measurement of excessive TSP or PM 10 witha portable dust monitor, or when a significant dust emission is reported by any personnel on site, theConstruction Supervisor or Site Environmental Officer will visually inspect the site directly. Direct visualinspection on site will include checking if significant dust plumes have the potential to impact on sensitivereceptors. Significant visible dust plumes leaving the site will trigger additional mitigation measures.

    The same monitoring methods (particle monitors and visual monitoring) will be used to determine ifadditional dust mitigation measures have been successful in preventing fugitive nuisance dust, andassist in the decision of whether to cease activities causing dust and when those activities can resume.

    Responsibilities and reporting

    Activity Responsibility Timing To

    Monitoring BBA Env Manager As required BBA Management Team

    Complaints Report BBA Env Manager Within 24 hrsBBA Management Team

    Director - Env Division

    Summary Report BBA Env Manager MonthlyBBA Management Team

    Director - Env Division

    Noise and Vibration Monitoring

    Applicable permit conditions

    Schedule Part Section NumberSequential

    pageRequirement

    LU1 3 2 2MN3.363 of 201(Seq. 71)

    CMP to include noise monitoring

    LU1 3 22NC 1.1-

    1.11

    79 to 81 of201 (Seq.

    92-94)

    Specifies allowable noise levels from the pulp mill,landfill and quarry that vary depending on time of dayand location in Rowella, and how measurements must

    be made and interpreted.

    LU1 3 2 2NC2.182 of 201(Seq. 95)

    Requires prior to the commencement of each keyconstruction activity the submission of a reportdemonstrating that the limits imposed above will not beexceeded.

    LU1 3 2 2NC3.1-3.783-84 of

    201 (Seq.96-97)

    Requires that a survey of the spatial distributionpattern of sound pressure levels in the Rowella Arearesulting from construction activities be undertaken assoon as practicable following the commencement ofsustained major construction activity.

    LU1 3 2 2NC5.185 of 201(Seq.98)

    Specifies acceptable vibration levels associated withblasting at the pulp mill and quarry.

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    LU1 3 2 2NC6.185 of 201(Seq.98)

    Requires blasting measurements to be carried out inaccordance with the methods set down in thedocument Technical basis for guidelines to minimiseannoyance due to blasting overpressure and groundvibration, Australian and New Zealand Environment

    Council, September 1990.

    LU1 3 5 5NC2.1-2.3

    155-156 of201

    (Seq. 168-169)

    Specifies allowable noise levels for effluent pipelineconstruction that vary depending on time of day.

    LU1 3 5 5NC 7.1157 of 201(Seq. 170)

    Requires blasting events along the effluent pipeline tobe monitored for both ground vibration and air blastover-pressure.

    LU1 3 5 5NC 8.1157 of 201(Seq. 170)

    Requires blasting results to be forwarded to theDirector within 24 hours.

    LU1 3 6 6NC2.1-2.3

    164-165 of

    201(Seq. 177-

    178)

    Specifies allowable noise levels for water supplypipeline construction that vary depending on time ofday.

    LU1 3 6 6NC7.1165 of 201

    (Seq. 178)

    All blasting events along the water supply pipelineroute must be monitored for both ground vibration andair blast over-pressure.

    LU1 3 6 6NC8.1165 of 201

    (Seq. 178)

    Requires blasting results to be forwarded to theDirector within 24 hours.

    LU2 3 - NC1.220 of 25

    (Seq. 234)

    Specifies allowable noise levels for accommodationcamp construction that vary depending on time of day.

    LU3 3 - 3.319 of 50

    (Seq. 258) CMP to include noise monitoring

    LU3 3 - NC2.1-2.338 of 50

    (Seq. 277)

    Specifies allowable noise levels for water supplypipeline construction that vary depending on time ofday.

    LU3 3 - NC7.139 of 50

    (Seq. 278)

    Requires blasting events along the water supplypipeline to be monitored for both ground vibration andair blast over-pressure.

    LU3 3 - NC8.139 of 50

    (Seq. 278)

    Requires blasting measurements to be carried out inaccordance with the methods set down in thedocument Technical basis for guidelines to minimiseannoyance due to blasting overpressure and groundvibration, Australian and New Zealand EnvironmentCouncil, September 1990.

    LU3 3 - NC9.1 39 of 50(Seq. 278)

    Requires blasting results to be forwarded to theDirector within 24 hours.

    LU4 3 - 3.320 of 52

    (Seq. 309)CMP to include noise monitoring

    LU4 3 - NC2.1-2.339 of 52

    (Seq. 328)

    Specifies allowable noise levels for water supplypipeline construction that vary depending on time ofday.

    LU4 3 - NC7.140 of 52

    (Seq. 329)

    Requires blasting events along the water supplypipeline to be monitored for both ground vibration andair blast over-pressure.

    LU4 3 - NC8.1

    40 of 52

    (Seq. 329)

    Requires blasting measurements to be carried out inaccordance with the methods set down in thedocument Technical basis for guidelines to minimise

    annoyance due to blasting overpressure and groundvibration, Australian and New Zealand EnvironmentCouncil, September 1990.

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    Noise and Vibration Monitoring

    LU4 3 - NC9.140 of 52

    (Seq. 329)

    Requires blasting results to be forwarded to theDirector within 24 hours.

    Objectives

    The primary objectives of the monitoring program is to quantify noise and vibration resulting from BBAconstruction activities and enable BBA to take corrective action in real time to minimise the potential forand mitigate the effects of noise and vibration on the sensitive receptors in the areas surrounding thepulp mill and associated infrastructure.

    Background

    One of the major concerns of local stakeholders relates to the propagation of noise from the constructionand operational phases of the mill affecting the amenity of nearby residential areas; and to a lesserextent vibration from blasting. Gunns has engaged a suitably qualified and experienced specialistconsultant

    2whose primary role is to implement, co-ordinate and manage noise and vibration monitoring

    programs during construction. The specialist and/or suitably trained BBA persons will conduct targetedmonitoring in the event of public complaints.

    Under normal operating conditions, noise will be managed through measures such as careful planningand timing of works, silencing of equipment, use of well maintained equipment and the use of noisebarriers where appropriate. Compliance with permitted noise limits will be achieved through a variety ofmeans described below.

    This includes an instrument which continuously monitors noise levels at the proposed pulp mill site, andanother continuous monitoring unit that is installed at a residence in Rowella that is close to the mill site.A second Rowella site is available for continuous monitoring (Refer Figure 2). The intent is that onemonitoring instrument will roam between the two Rowella sites on an as required basis. If the SiteSupervisor receives an alert message from the continuous noise monitoring system, for exceedance ofpermitted noise limits (LU 1 Part 3 Section 2, 2NC1.1 1.11), or a warning message that noise levelsare approaching the permitted noise limits, the following action hierarchy will be implemented:-

    Immediate review of continuous monitoring data, which will assist in identifying the source andconfirming if the noise is from the activities on the mill site.

    Implement mitigation measures to prevent recurrence, including cessation of the noisiest activities

    Check continuous monitoring data to ensure that noise levels drop to, and remain below permittednoise levels

    If noise levels do not drop to and remain below permitted noise levels, cease all noise generatingactivities on site and confirm with continuous monitoring data if permitted noise limits are stillexceeded.

    Only if noise levels drop below and remain below permitted noise levels, continue work with theappropriate plant and equipment.

    Log and report noise event or exceedance to BBA Environmental Manager.

    At all sites, community complaints relating to noise/vibration or measurement of exceedance of permitlimits during attended surveys will trigger the following actions:-

    Review of available monitoring data which will assist in identifying the source

    Additional attended noise and vibration monitoring if required

    Implement mitigation measures to minimise likelihood of recurrence

    Meet with the complainant, where applicable.

    Prepare an incident report and send to Gunns Environmental Manager and Director ofEnvironmental Management, DTAE..

    A ground vibration monitoring system will be installed at the closest residence to the mill site3

    during theconstruction phase of the project. The unit can be programmed to record an event exceedance and

    2Vipac Engineers & Scientists Ltd have been engaged for this task.

    3Conditional upon agreement of the landowner.

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    Noise and Vibration Monitoring

    provide all blasting parameters for reporting to the Director, Environmental Management, DTAE. Theblasting contractor will also be required to monitor all blasting events. The ground vibration monitoringsystem is portable and can be used for monitoring of blasts along the water supply and effluentpipelines, as required.

    Monitoring methodology mill, wharf, landfill, reservoir and quarry

    Pre-construction

    Noise measurement equipment used to date:-

    Sound Level Meter Larson Davis 831 s/n

    Sound Level Meter Larson Davis 831 /n

    Environmental Noise Analyser Larson Davis 870B s/n 1364

    Environmental Noise Analyser Larson Davis 870B s/n 1189

    Acoustic Calibrator Larson Davis CA250 s/n 2760

    Sound Level Meter Larson Davis 700-20 s/n 1116

    Spectrum Analyser Larson Davis 2900 s/n A0343

    Noise measurement equipment has been chosen to comply with the measurement requirements of thepulp mill operating permit.Continuous noise logging instruments have been installed and commissioned at the following locations(Refer Figure 2):-

    Pulp mill site

    Rowella

    A Secure web site hosted by Vipac has been developed for reporting of logged data. Authorised accesshas been made available to DTAE and BBA. The web site is to be updated with all preconstructionlogged data at the end of January 2008. Following start of construction the data will be updated at 2week intervals.

    Observed measurements have been carried out intermittently throughout 2007 at several sites inRowella (Refer Figure 2). Extended unmanned logging has also been under taken at most sites.Measurements obtained at nominated manned measurement positions during the preconstruction periodare to be analysed and reported by Vipac in early February 2008.

    During Construction

    A full acoustic model of the project will be provided to Gunns prior to the commencement of eachphase of construction. Project phases have been defined as follows:-

    Vegetation clearance Environmental noise monitoring requirements for this phase have been

    completed and noise management strategies determined. This includes the use of temporaryacoustic barriers around significant stationary noise sources and the use of noise modellingpredictions to plan equipment use on site.

    Bulk earthworks Noise modelling work has commenced.

    Infrastructure construction not started

    Commissioning not started

    Operations not started

    A full environmental noise survey is to be carried out at the commencement of each construction phaseas per permit requirements (LU1 Part 3 Section 2 2NC 3.1-3.7) starting with the vegetation clearance.This work is planned for February 2008. The approved noise survey methodology (Appendix 1.) will beused for this survey.

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    Noise and Vibration Monitoring

    A full environmental noise survey is also to be carried out for each season as follows:-

    Summer December to February

    Autumn March to May

    Winter June to August

    Spring September to NovemberThe approved noise survey methodology (Appendix 1.) will be used for these surveys.

    Live noise monitoring

    The noise monitoring system(s) installed provide live noise feedback to the site environmental manager.This system provides SMS warnings and alarms based on permit noise limits. This data is loggedcontinuously and is designed to assist with the management and control of site noise, and investigationof noise events.

    Attended samplers:

    Attended samplers will record:

    the average equivalent (Leq) and L1, L10, L50, L90, L99 A-weighted sound pressure levels measuredover periods of 10-20 minutes; and

    One third octave and narrow band spectra over suitably representative periods of not less than oneminute; and

    A subjective description of the sound at each location, including meteorological details relevant tothe propagation of noise.

    If required, a logging noise monitor would be deployed for investigation of any noise complaints or shortterm monitoring at supplementary locations as appropriate.

    Noise monitoring and analysis of the noise monitoring data will be in accordance with the NoiseMeasurement Procedures Manual(July 2004)

    4

    Vibration Monitoring

    A fully automated blast monitoring system has been obtained and is to be installed at one of the closestnoise sensitive locations in Rowella (Refer Figure 2). This equipment will continuously record groundvibration as Peak Particle Velocity and airborne Blast Overpressure.

    The instrumentation is also suitable for monitoring any ground borne vibration generated by piling activityassociated with the construction of the wharf.

    The system is capable of recording all blasting details (such as charge levels, blast patternsand location, charge delays, etc.) carried out on the Pulp Mill site and providing a full reportof the resultant ground vibration and blast overpressure on a daily basis.

    Exceedance of ground vibration limits (LU1 Part 3 Section 2 2N5.1) would trigger an SMS exceedancewarning and all such events will be investigated and reported by the site environmental manager.

    The blast contractor is also responsible for monitoring of all blasts.

    Blasting measurements will be carried out in accordance with the methods set down in the documentTechnical basis for guidelines to minimise annoyance due to blasting overpressure and ground vibration,(Australian and New Zealand Environment Council, September 1990).

    Blast reports will be submitted to the Director, Environmental Management DTAE within 24 hours ofeach blast.

    4NOISE MEASUREMENT PROCEDURES MANUAL Environment Division Department of Primary Industries, Water andEnvironment First edition July 2004

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    Noise and Vibration Monitoring

    All vibration data will be reviewed on a monthly basis and a summary report provided to theDirector.

    Monitoring methodology water supply and effluent pipelines, and workersaccommodation

    Water Supply & Effluent Pipelines

    Noise sensitive locations, for example private residences, will be identified along the length of bothpipeline corridors, before the construction of each section of the water supply and effluent pipelines, by aqualified specialist or the Site Environmental Officer.

    Construction noise will be modelled at these locations to determine the potential noise impact.

    Noise control measures will be determined where required, to ensure that allowable noise limits (LU1Part 3 Section 5 5NC2.1-2.3; LU1 Part 3 Section 6 6NC 2.1-2.3; LU3 Part 3 NC2.1-2.3; LU4 Part 3NC2.1 -2.3) are not exceeded.

    Construction noise activity will be logged for a minimum of 48-hours in each noise sensitive locationidentified. Where appropriate noise logging may be carried out at more than one position.

    Observed measurements will be undertaken for a minimum of 1-hour representative periodduring the day and evening at each site.

    Noise monitoring and analysis of the noise monitoring data will be in accordance with the NoiseMeasurement Procedures Manual(July 2004)

    Written reports will be provided to the BBA Environmental Manager at the completion of each phase ofthis work.

    A ground vibration monitoring system, similar to the one used to monitor the Pulp Mill site, would beused on an as needs basis to monitor, record, and report on all blasting activity associated with theconstruction of both pipelines. The vibration monitoring instrument that is located at Rowella adjacent tothe mill is portable and can be moved as required to monitor blasting at other locations. The blastingcontractor will also be required to monitor all blasting events.

    Alarming, investigations and reporting procedures will be the same as those described for the Pulp Millsite.

    Blasting measurements will be carried out in accordance with the methods set down in the documentTechnical basis for guidelines to minimise annoyance due to blasting overpressure and ground vibration,(Australian and New Zealand Environment Council, September 1990).

    Blast reports will be submitted to the Director, Environmental Management DTAE within 24 hours ofeach blast.

    All vibration data will be reviewed on a monthly basis and a summary report provided to theDirector, Environmental Management DTAE.

    Workers Accommodation

    Environmental noise levels are to be measured at the proposed site for the workers accommodationfacility to establish the typical ambient background level prior to commencement of activity on the site.

    These measurements would be recorded over two minute intervals over a 14 day period as per therequirements of the Noise Measurement Procedures Manual (July 2004).

    Representative noise monitoring of the site would be conducted during construction and occupation for a

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    Noise and Vibration Monitoring

    minimum period of 48-hours.

    Noise monitoring and analysis of the noise monitoring data will be in accordance with the TasmanianNoise Measurement Procedures Manual(July 2004)

    No vibration or blast monitoring is proposed for the workers accommodation, as no blasting will beundertaken at that site.

    Responsibilities and reporting

    Activity Responsibility Timing To

    Monitoring generalBBA Env Officer andSpecialist Consultant

    As requiredBBA Management Team

    Monitoring vibration/over

    pressure

    BBA Env Officer andBlasting Contractor

    Report required 24hrsafter event

    BBA Management TeamDirector Environmental

    Management

    Complaints/IncidentReport

    BBA Env Manager Within 24 hrs

    BBA Management TeamGunns Environmental

    Manager.Director Environmental

    Management

    Summary report atend of construction.

    BBA Env Manager Within 90 days

    Gunns EnvironmentalManager.

    Director EnvironmentalManagement

    Groundwater Monitoring

    Applicable permit conditions

    Schedule Part Section NumberSequential

    pageRequirement

    LU1 3 22MN2.1 to

    2.7

    61/62 of 201

    (Seq. 74,75)Calls for Baseline and Operational Monitoring Plan.Baseline component applicable to construction iscovered in the CMP

    LU1 3 22MN3.1 to

    3.7

    63/64 of 201

    (Seq. 76,77)CMP calls for groundwater monitoring , it mustprovide commitments, reporting protocol, it must beapproved by Director, and be available to the public.

    LU1 3 22GW2.1 t0

    2.7

    67 to 69 of201

    (Seq. 80 to82)

    Requires the preparation and submission of an initialhydro-geological assessment prior to thecommencement of plant construction5.

    LU1 3 22GW3.1 to

    3.3

    69 of 201

    (Seq. 82)Requires the development of a conceptual hydro-geological model prior to the commencement ofplant construction.

    5 Plant construction means construction of the plant, major buildings and facilities on the pulp mill site, but excluded site preparation,land clearing, grading and excludes construction activities associated with the wharf. (LU1-Part 1- Page 2 of 201).

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    Groundwater Monitoring

    LU1 3 22GW4.1 to

    4.6

    69/70 of 201

    (Seq. 82)Requires the preparation and submission of agroundwater monitoring program prior to thecommencement of plant commissioning.

    LU1 3 22GW5.1 to

    5.2

    70 of 201

    (Seq. 83) Requires the installation of sentinel monitoring wells.

    Objectives

    The primary objectives of the monitoring program are to assess potential impacts on ground waterresulting from BBA construction activities and enable BBA to take corrective action to minimise thepotential for and mitigate the effects of any hydrocarbon spills on the ground water.

    Background

    Baseline Monitoring

    During 3rd quarter of 2006 baseline monitoring of thirteen bores for an extensive range of chemicalparameters commenced, an additional 10 bores have been installed during the 4

    thquarter of 2007. The

    bores are located down gradient of the mill and landfill footprints and there are some bores located wellaway from the impact zones which will be control bores for construction and life of the project.

    The Initial Hydrogeological Assessment Report prepared by Environmental, Engineering andGroundwater Geologists William C. Cromer Pty Ltd in association with Pitt and Sherry has beensubmitted and approved by the Director of Environmental Management.

    During Construction Monitoring

    The program associated with the construction is firstly a risk based assessment of areas where the watertable may intercept the construction activity. A qualified and experienced groundwater hydrologist will

    inspect the entire construction foot print assess groundwater levels in problem areas and report to theBBA who will implement appropriate management measures. Secondly implementation of monthlymonitoring of existing 13 groundwater bores immediately off the mill footprint and 10 bores associatedwith the landfill during the construction phase involving establishment of major foundations. Refer toFigure 3 for location of bores.Thirdly a significant hydrocarbon spill at any construction site may trigger the installation of additionalbores to assess impact on the groundwater in the immediate area and/or more frequent hydrocarbonmonitoring of adjacent bores.

    Monitoring methodology

    Baseline Monitoring:

    The baseline monitoring covers parameters applicable to construction activites which are:-- standing water level- pH- conductivity- turbidity- redox potential- total petroleum hydrocarbons as well as oil and grease;

    as well as parameters associated with potential emissions from the operating mill. The monitoringfrequency varies pending location of the bore and risk.

    During Construction Monitoring:

    Monthly monitoring of all bores within the active construction footprint as well as downgradient of it willbe monitored/sampled for:-

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    - standing water level- pH- conductivity- turbidity

    - redox potential- total petroleum hydrocarbons as well as oil and grease

    Quality Control:

    Low flow pumping technique is used for sampling with each bore having dedicated sample tubing whicheliminates the risk of cross contamination. The flow is discharged via a flow cell with a field water qualityinstrument monitoring all parameters listed except standing water level and petroleum hydrocarbons.Once stabilised the instrument readings are recorded. The field water quality instrument is calibrated atthe beginning and end of each day.Samples for hydrocarbon analyses are taken in laboratory supplied containers, packed in eskys withchiller blocks and shipped with appropriate chain of custody documentation to a NATA accreditedlaboratory.

    Interpretation of Results:

    Interpretation of the groundwater test results will be undertaken using various reference materialsdetailed in the Permit (LU1/3/2/Page 68 of 201).The highest risk to groundwater quality is hydrocarbon contamination from oil spills. A commonly usedintervention level for this parameter is the Dutch 1994 guideline which is 325ppb of total petroleumhydrocarbons.

    Exceedance of this intervention level will trigger the following actions:-- detailed inspection of construction site- soil sampling and testing for total petroleum hydrocarbons from likely sources eg

    fuel storages

    - clean up of identified contaminated areas- weekly testing of bores until levels return to background.

    Responsibilities and reporting

    Activity Responsibility Timing To

    Initial HydrologicalAssessment andConceptual Model

    Gunns EnvironmentalManager

    Before plantconstruction. It hasbeen submitted andapproved

    Director EnvironmentalManagement

    Groundwater

    Monitoring asrequired.

    BBA Environmental

    Manager As required.

    Gunns EnvironmentalManager

    Director EnvironmentalManagement

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    Surface and Marine Water Quality Monitoring

    Applicable permit conditions

    Schedule Part Section Number

    GunnsPage

    PermitReference

    Requirement

    LU1 3 2 2MN1.160 of 201

    (Seq. 74)

    Samples must be analysed by a NATA accreditedlaboratory. Collection and analysis details must bemaintained for at least 3 years. The sample must becollected and transported by a person with appropriatetraining.

    LU1 3 22MN2.1 to

    2.7

    62 of 201

    (Seq. 75)

    Calls for Baseline and Operational Monitoring Plan.Baseline component applicable to construction iscovered in the CMP.

    LU1 3 22MN3.1 to

    3.7

    62/64 of201

    (Seq.76,77)

    CMP calls for water quality monitoring (surface andmarine), it must provide commitments, reportingprotocol, it must be approved by Director, and be

    available to the public.

    LU1 3 2 2SL(d)66 of 201

    (Seq. 79)

    The Acid Sulphate Soil Management Report calls forongoing monitoring program. As this is a very specificprogram and is dependent on field investigations whichare pending it will not be included in the CMP it willremain in the Report.

    LU1 3 2 2ER1.1(e)66 of 201

    (Seq. 79)

    Calls for erosion and sediment control monitoring andmaintenance program, the monitoring is covered in theCMP.

    LU1 3 2 3SW4.3( c )122 of 201

    (Seq. 135)

    Calls for a stormwater construction monitoring plancovered in the CMP.

    LU1 3 2 3SW11.1125 of 201

    (Seq. 138)

    Specifies stormwater emission limits for total suspended

    solids, biological oxygen demand, total petroleumhydrocarbons, oil and grease.

    LU1 3 33WW20.1and 20.2

    132 of 201

    (Seq. 145)

    During construction on the mill site, monitoring of pH,turbidity, conductivity, dissolved oxygen and TPH mustbe undertaken at surface water monitoring sitesidentified in Summary Table 2.2 of the Pulp MillEnvironmental Monitoring Program and from allsediment detention pond discharge points.

    If turbidity exceeds 130NTU a water sample must becollected for overnight analysis.

    LU1 3 3 3MR16.1136 of 201

    (Seq. 149)

    Insitu pH, turbidity, temperature and dissolved oxygenmust be undertaken daily up and down current of wharfconstruction activity.

    LU1 3 3 3MR17.1 to17.3

    136 of 201(Seq. 149)

    Calls for water quality monitoring at least every secondday whenever substantial suspended soild plumes areevident. Analysed for a comprehensive suite ofparameters.

    LU1 3 5 5SW9.1150 of 201

    (Seq. 163)

    Requires in situ meter monitoring of pH, turbidity,conductivity and dissolved oxygen to be undertakendaily where effluent pipeline construction disturbance isoccurring within a permanent watercourse.

    LU1 3 5 5DB11.1153 of 201

    (Seq. 166)

    Requires in situ meter monitoring of pH, turbidity,conductivity and dissolved oxygen to be undertakendaily up and dwn current of the construction activitywhen it is occurring below the high water mark.

    LU1 3 55DB12.1 to

    12.3

    153 of 201

    (Seq. 166)

    Calls for water quality monitoring at least every secondday whenever substantial suspended soild plumes areevident. Analysed for a comprehensive suite of

    parameters.

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    LU1 3 5 5SC1.2154 of 201

    (Seq. 166)

    Requires monitoring to form part of the Shore CrossingManagement Plan which is under development hence itis not covered in the CMP.

    LU1 3 6 6SW9.1162 of 201

    (Seq. 175)

    Requires in situ meter monitoring of pH, turbidity,

    conductivity and dissolved oxygen to be undertakendaily , up and down where construction disturbance isoccurring within a permanent watercourse.

    LU1 3 33MR15.1-

    15.2

    136 of 201

    (Seq. 149)

    Requires sediment cores to be taken prior tocommencement of wharf construction

    LU1 3 3 3MR16.1136 of 201

    (Seq. 149)

    Requires daily in situ profile monitoring of pH, turbidity,temperature and dissolved oxygen during wharfconstruction

    LU1 3 8 Annex M1201 of 210

    (Seq. 214)

    Provides a comprehensive list of analytes for sedimentand water quality

    LU3 3 -CN3.1 to

    3.7

    19 of 50

    (Seq. 258)

    CMP must be approved by Director, it calls for waterquality monitoring (surface and marine), it must providecommitments, reporting protocol, it must be approved by

    Director, and be available to the public.

    LU3 3 -MN1.1 toMN4.1

    22 of 50

    (Seq. 161)

    Samples must be analysed by a NATA acreditedlaboratory. Collection and analysis details must bemaintained for at least 3 years. The sample must becollected and transported by a person with appropriatetraining.

    LU3 3 - SW9.1265 of 544

    (Seq. 265)

    Requires in situ meter monitoring of pH, turbidity,conductivity and dissolved oxygen to be undertakendaily where water supply pipeline constructiondisturbance is occurring within a permanentwatercourse.

    LU3 3 - TM 2.2(f)28 of 50

    (Seq. 267)

    Tamar River Management Plan calls for a monitoringprogram which is also addressed in CMP.

    LU3 3 - TM 4.129 0f 50

    (Seq. 268)

    Requires in situ meter monitoring of pH, turbidity,conductivity and dissolved oxygen to be undertakendaily at one location up and down current whereconstruction activities are occurring

    LU3 3 -TM

    5.1,5.2,5.3

    29 0f 50

    (Seq. 268)

    Calls for water quality monitoring at least every secondday whenever substantial suspended soild plumes areevident. Analysed for a comprehensive suite ofparameters.

    LU3 3 - TM7.130 of 50

    (Seq. 269)

    Within 90 days of completion of construction activitiesassociated with Tamar River Crossing a report must besubmitted to the Director of all the monitoring results etc.

    LU3 3 - Annex M150 of 50

    (Seq. 289)

    Provides a comprehensive list of analytes for sedimentand water quality

    LU4 3 - 3.1 to 3.7 20 of 52(Seq. 309)

    CMP must be approved by Director, it calls for water

    quality monitoring (surface and marine), it must providecommitments, reporting protocol, it must be approved byDirector, and be available to the public.

    LU4 3 -MN1.1 and

    2.1

    22 of 52

    (Seq.311,312)

    Samples must be analysed by a NATA acreditedlaboratory. Collection and analysis details must bemaintained for at least 3 years. The sample must becollected and transported by a person with appropriatetraining.

    LU4 3 - AS1.2(d)26 of 52

    (Seq. 315)

    The Acid Sulphate Soil Management Report calls forongoing monitoring program. As this is a very specificprogram and is dependent on field investigations whichare pending it will not be included in the CMP.

    LU4 3 - SW9.1

    27 of 52

    (Seq. 316)

    Requires daily up and down current in situ metermonitoring of pH, turbidity, conductivity and dissolved

    oxygen where water supply pipeline constructiondisturbance is occurring within a permanentwatercourse.

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    Surface and Marine Water Quality Monitoring

    LU4 3 - TM2.2(f)30 of 52

    (Seq. 319)

    Calls for a monitoring plan which is covered by thisdocument

    LU4 3 - TM4.1 30 of 52(Seq. 319)

    Requires in situ meter monitoring of pH, turbidity,

    conductivity and dissolved oxygen to be undertakendaily up and down current of the construction activitywhen it is occurring below the high water mark.

    LU4 3 - TM5.1-5.330 of 52

    (Seq. 319)

    Calls for water quality monitoring at least every secondday whenever substantial suspended soild plumes areevident. Analysed for a comprehensive suite ofparameters.

    LU4 3 - TM7.131 of 52

    (Seq. 320)

    Within 90 days of completion of construction activitiesassociated with Tamar River Crossing a report must besubmitted to the Director of all the monitoring resultsetc.

    LU4 3 - Annex M152 of 52

    (Seq. 341)

    Provides a comprehensive list of analytes for sedimentand water quality

    EM1 - -MN2.1 to

    2.7

    10/11 of 25

    (Seq.351/352)

    CMP calls for water quality monitoring, it must providecommitments, reporting protocol, it must be approved byDirector, and be available to the public.

    EM1 - - MN4.111 of 25

    (Seq. 352)

    Requires in situ meter monitoring of pH, turbidity,conductivity and dissolved oxygen to be undertakendaily up and down current of the construction activitywhen it is occurring below the high water mark.

    EM1 - -MN5.1 to

    5.3

    11 of 25

    (Seq. 352)

    Calls for water quality monitoring at least every secondday whenever substantial suspended soild plumes areevident. Analysed for a comprehensive suite ofparameters.

    EM1 - -MN7.1(a) to

    (d)

    12/13 of 25

    (Seq.353/354)

    Samples must be analysed by a NATA acreditedlaboratory. Collection and analysis details must be

    maintained for at least 3 years. The sample must becollected and transported by a person with appropriatetraining.

    EM1 - - Annex M120 of 25

    (Seq. 361)

    Provides a comprehensive list of analytes for sedimentand water quality

    Objectives

    The primary objectives of this component of the monitoring program are to measure any changes in waterquality in surface and marine waters in the areas surrounding the pulp mill and associated infrastructureas a result of BBA construction activities, and enable BBA to take corrective action to minimise andmitigate those impacts.

    Background

    This project involves land based construction activities associated with the mill, landfill, reservoir, andpipelines as well as marine based construction activities associated with the wharf, the water supplycrossing the Tamar Estuary, the effluent pipeline crossing Donovans Bay, and the effluent outfall in BassStrait.

    In principal the ANZECC approach will be used, where applicable and as a guide, to assess typicalbackground levels (reference levels) of various parameters that may be released by the disturbance ofsoil/sediments during construction. Control and impact sites must be monitored prior and duringconstruction activities. During construction, exceedances beyond the 80

    thpercentile, as calculated from

    baseline data, will trigger the implementation of additional mitigation controls.A review of construction activities and their locations has identified construction activities at the mill site,the landfill, Donovans Bay, Tamar Crossing and the Wharf to be higher risk because surface water runoff,if not properly managed, and disturbance of estuarine sediments have the potential to impact on the

    nearby aquaculture facility. Gunns monitoring data associated with the Tamar Estuary and surface waterstreams on the mill and landfill sites as well as extensive data provided by Tasmanian Department of

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    Surface and Marine Water Quality Monitoring

    Tourism, Arts and Environment will provide a robust data set enabling the determination of trigger valuesfor the receiving environments.The receiving environments and current water monitoring locations are :-

    - Tamar Estuary in vicinity of mill site sample location Longreach chip mill wharf

    - Stream discharging into Dirty Bay (SW9,10,11)- Confluence of Williams Creek and the Tamar Estuary (SW1,2,3,4,5,6,7,8)- Up-current of Tamar Crossing water supply pipeline

    Refer Figures 4-6 for current water quality monitoring locations.

    Land Based Activities.Stormwater Management Strategy:-Erosion and sediment controls must be implemented as soon as possible after the start of vegetationclearing and before earthworks associated with the mill, wharf, landfill, water reservoir, water supplypipeline and effluent pipeline. These include but are not limited to diversion drains, sediment fences andsedimentation ponds. During construction activities associated with the mill, the wharf, the landfill, and thewater reservoir, the stormwater strategy will entail total containment of runoff from construction areas in

    sedimentation basins, which will be designed to hold either a 1 in 20 year design storm, in the case of longterm temporary sediment basins (expected life of sediment pond exceeding 1 year), or a 1 in 2 yeardesign storm, in the case of short term temporary sedimentation ponds (expected life of sediment pondless than 1 year). The water trapped in these ponds will as a priority, be reused for dust suppression,compaction or watering of rehabilitation areas or mulched areas with water trucks and sprinkler systems.Once all diversion drains and sedimentation ponds are in place, from that point on no surface waters willoutfall into the existing streams on the mill, landfill and reservoir sites except under two potentialcircumstances:

    1. A storm event exceeding the design storm for the sediment ponds on site. Sediment ponds aredesigned and built with stable outlets that gradually decant the uppermost (and therefore clearest)water from the sediment pond.

    2. During periods of regular rain when sediment ponds are full or filling, and there is no need for re-use of the water for dust suppression, it will be necessary to flocculate the water in the sediment

    ponds to facilitate settling out of suspended colloids, and then, once it meets the relevant waterquality requirements, pump the water either to the nearest receiving water course, or to a wellvegetated area within the boundary of the construction site. This reduces the risk of a subsequentrain event causing the sediment ponds to overflow with dirty water into the adjacent creeks. Thiswill be a last resort, with re-use of water being the preferred option under normal conditions. Nointentional discharge will be allowed without a Site Environmental Officer first testing the water tocheck if it meets the water quality requirements and issuing an internal Permit to Discharge Form(BBA-FRM-1000-1400-0001)

    In both circumstances the water quality of the discharged water will need to be monitored as describedbelow.Along the water supply and effluent pipelines, it may not always be practical to completely contain run-offfrom site, and it will be necessary to rely more on filtration in the form of, but not exclusive to, filter socks,sediment fences and vegetation. In this case it will be important to monitor water quality in any watercourses crossing or adjacent to the pipeline routes, as described below, to assess the effectiveness ofthese control measures.

    Monitoring:-The first baseline pre construction monitoring event of major streams on the pulp mill and landfill sitesoccurred September 2006 and monthly monitoring commenced February 2007 with a sampling strategydesigned to assess water quality soon after rain events and at low flows. If there are no rain events thensamples are taken during the last week of the month giving every opportunity to catch a rain event. Theyear 2007 was drier than usual. This monthly monitoring strategy must continue throughout the plantconstruction phase (subject to annual reviews and changes by regulatory authorities) beforecommencement of operations.

    There are six surface water sampling locations associated with the landfill site and another six with thepulp mill site Refer Figure 4. Comprising upstream control sites (SW1,7,9,10,12) and downstreamimpact sites (SW2,3,4,5,6,8,11). At each sampling event stream flows are noted, the more significant

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    Surface and Marine Water Quality Monitoring

    streams have minimalistic flow monitoring structures, such as weirs, allowing the estimation of volumetricsurface flows.At a location on a water course downstream of the landfill (SW4) and at another on a stream interceptedby the mill footprint (SW11) an automatic water sampler and water depth monitoring instrument, installed

    January 2008, will trigger sampling to assess mass pollutant loads from these areas. The pollutant loadsfrom the mill and landfill sites will be associated with washed insoluble and soluble fugitive emissions fromfirstly construction then mill/landfill activities. These streams will not receive any runoff waters from themill/landfill sites except during infrequent significant rain events during the construction phase only.Essentially these devices will assess first flush mass emission data (fugitive dust deposition) during majorearthworks associated with construction then baseline pre-operational data over approximately 2 yearsbefore commencement of operations.

    The pipeline easements cross natural water courses and it is essential that these are monitored upstreamand downstream of the pipeline crossing during construction. Initial baseline monitoring of in situ meterparameters, refer Methodology Section, has occurred on four occasions over 2007. Beforecommencement of construction activities associated with creek crossings weekly inspections and in situwater quality meter monitoring shall occur commencing January 2008. At the major crossings weekly

    water samples for chemical analyses shall also be collected of non stagnant flowing waters.

    The construction water quality monitoring is designed to assess quality of stormwater runoff fromconstruction areas associated with the entire project.

    Marine Based Actvities

    Tamar Estuary Water Supply Crossing

    Preliminary background monitoring associated with this activity occurred October 2006, April, May andJune 2007 with baseline monthly monitoring commencing July 2007. The latter monitoring involves in situwater quality meter readings and collection of monthly water samples for chemical analyses at high, midand low tides. Refer Figure 5 for location of monitoring site which provides safe access at various tides. It

    is up-current of the Tamar Crossing location.

    Wharf

    Preliminary background monitoring associated with this activity occurred May and June 2007 with baselinemonthly monitoring commencing July 2007. The latter monitoring involves insitu water quality meterreadings and collection of monthly water samples at high, mid and low tides. Refer Figure 6 for location ofmonitoring site which is up-current of the new wharf, it is off the existing Gunns chip mill wharf allowingwater quality profiling to the bottom at high tide associated with the monthly program.

    Donovans Bay Effluent Pipeline Crossing.

    Preliminary background monitoring associated with this activity occurred May and June 2007 with baselinemonthly monitoring commencing February 2008. This involves insitu monitoring and water sampling athigh, mid and low tides.

    Effluent outfall to Bass Strait.

    Preliminary monthly baseline monitoring associated with the effluent outfall commenced January 2007with regular insitu water quality monitoring along the proposed pipeline installation route. This monitoringwill continue on a monthly basis.

    Monitoring methodology

    Pre Construction Baseline Monitoring

    Land Based Activities

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    Surface and Marine Water Quality Monitoring

    The Baseline and Operational Monitoring (LU1/3/2/3MN2.1 to 2.7) which is under preparation referencessummary table 2.2.1 of the Pulp Mill Environmental Monitoring Program which provides an extensiveanalyte list as well as sampling frequency.

    Those analytes, from the extensive list, considered appropriate to baseline pre construction monitoring ofsurface flowing streams associated with the mill, landfill and reservoir are:-

    - pH- conductivity- turbidity- dissolved oxygen- total alkalinity- oil and grease- total petroleum hydrocarbons- total dissolved solids- total suspended solids

    Water samples are collected monthly (commenced February 20076) from up to 12 sites over the mill and

    landfill areas (refer Figure 4) and have been analysed for all the above parameters with the exception of

    total petroleum hydrocarbons which was analysed September 2006, February and August 2007. As ofJanuary 2008 total petroleum hydrocarbons are included in the monthly analytical suite.

    Commencing January 2008 the following weekly in situ meter monitoring7

    of all flowing creek crossingsshall be initiated prior to pipeline construction over these creeks:-

    - pH- conductivity- turbidity- dissolved oxygen- temperature

    In addition the major creek crossings shall be sampled weekly when flowing and analysed for- total alkalinity- oil and grease

    - total petroleum hydrocarbons- total dissolved solids- total suspended solids

    Marine Based Activities Tamar Crossing, Wharf and Donovans Bay

    Past monitoring by government agencies and others indicates that the Tamar Estuary has elevated metaland nutrient levels from past activities, existing sewage outfalls and stormwater runoff. Hence the baselinemonitoring program involves ascertaining the existing levels of these contaminants by carrying out thefollowing monthly sampling and analyses for:-

    - suspended solids- total Nitrogen- NO3 and NO2- ammonia- total nitrogen- total phosphorus- reactive phosphorus- arsenic- barium- beryllium- cadmium- cobalt- nickel- chromium- copper

    6One extensive sampling event (insitu and chemical testing) occurred September 2006.

    7Four such surveys were carried out during 2007

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    Surface and Marine Water Quality Monitoring

    - lead- zinc- manganese- vanadium

    - mercury- (Metals total and dissolved.)

    As well as in situ meter monitoring of:-- pH- salinity- turbidity- dissolved oxygen- redox potential- temperature

    Marine Based Activities Effluent Outfall

    The frequency of monitoring and analytes are the same as those detailed above. Water samples are taken

    at top and bottom of water column in the region of what will be the diffuser location as well as more remotecontrol sites.

    During Construction Monitoring.

    The pre-construction baseline monitoring detailed for land and marine based activities continues, at thesame frequency and for the same parameters, during construction monitoring.

    Land Based Activities

    During construction, outfalls from sedimentation ponds/traps, and waters upstream and downstream ofpipeline creek crossings shall be monitored daily when the ponds are outfalling, or when there is a flow inthe creek. Waters will be analysed for:-

    - pH- salinity- turbidity- dissolved oxygen- temperature- TPH

    8

    If turbidity when correlated to 50 mg/L suspended solids equals or exceeds 50 mg/L a water sample shallbe collected and analysed over night to validate or otherwise the results in accordance with the Permit(LU1/3/3/3WW20.1 and 20.2).

    Also during construction, in accordance with stormwater emission limits (LU1/3/2/3SW11.1), daily watersamples shall be collected from sedimentation ponds at the mill site and analysed for:-

    - total suspended solids- BOD- TPH- oil and grease

    The rules for unintentional decanting or intentional pumping from these ponds (for significant rain eventsas described above) to the offsite environment are:

    - Suspended solid levels < 50 mg/L9

    or ;- Turbidity of outfall is less than the turbidity of surface water flows in the receiving

    water course upstream of the construction zone, where this is not the result ofpoor stormwater management practices upstream.

    8 Where there is evidence or possibility of a hydrocarbon spill.9Testing of various soil types fom the construction sites will allow the establishment of an approximate correlation between turbidity

    and suspended solids.

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    Surface and Marine Water Quality Monitoring

    In direct accordance with LU1/3WW20.1 daily water samples during construction shall be collected at thesample locations depicted in Figure 4 Surface Water Sample Sites and analysed for:

    - pH- salinity/conductivity

    - turbidity- dissolved oxygen- temperature- Total petroleum hydrocarbons.

    Marine Based Activities

    Tamar Crossing, Donovans Bay, Wharf, Effluent Outfall

    When construction commences at the above locations, in situ profile water quality monitoring shall occurdaily. More frequent monitoring associated with the Donovans Bay and Wharf construction activities maybe required as they are in the vicinity of an Aquaculture Facility and Shark refuge.The tamar Crossing is up-current and greater than 500m away from the Tamar Wetlands and an

    assessment by Envirogulf (DIIS Supplementary Information Book D) indicates that any turbidity associatedwith this activity will not impact these wetlands.

    Monitoring will occur directly up-current and directly down-current of the construction activity and at theconstruction site and involve the following measurements:-

    - pH- salinity- turbidity- redox potential- dissolved oxygen- temperature

    Should construction activities at Tamar Crossing, Wharf, Donovans Bay and Effluent Outfall generate

    substantial turbid plumes (exceeding the trigger values determined below), then a sub surface watersample shall be collected from within the plume, and as near as is practicable to the source of the plume,and outside of the plume. If the plume extends for more than 100m from the area of disturbance towardsthe nearest aquaculture facility then water samples will be taken at the end of the plume and the facilitywill be notified immediately. The extent and source of the plume must then be determined and theinformation must immediately be reported to the Director of Environmental Management.

    The Department of Tourism, Arts and Environment carried out an extensive turbidity monitoring programat locations within the Tamar Estuary which effectively are in the vicinity of the mill, Tamar and DonovansBay Crossing construction sites. The site Big Bay is in the vicinity of the mill, wharf and Donovans BayCrossing while Tamar Island site is in the vicinity of the Tamar Crossing. Statistical analysis of theseresults, in accordance with the ANZECC protocols, provides trigger turbidity readings that if exceeded willrequire collection of daily sub surface water samples within and outside of the plume at least every secondday.The 80

    thpercentile trigger turbidity levels are:-

    - 6 NTU Donovans Bay, Mill and Wharf Sites- 100 NTU Tamar Crossing

    Trigger turbidity for the effluent outfall will be determined nearer to the construction time and will becalculated from an extensive data set collected by Gunns.

    The samples taken from the turbid plume shall be analysed for the following:-- dissolved oxygen- turbidity- redox- suspended solids- total nitrogen- NO3 and NO2- ammonia

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    Surface and Marine Water Quality Monitoring

    - kjeldahl nitrogen- total phosphorus- reactive phosphorus- total organic carbon

    - dissolved organic carbon- arsenic- barium- beryllium- cadmium- cobalt- nickel- chromium- copper- lead- zinc- manganese- nickel

    - vanadium- mercury (Metals are dissolved and total)

    Quality Control

    Water samples during the construction phase will be sampled, monitored and managed with reference tothe AS/NZS 5667.1:1998Water quality Sampling Part 1: Guidance on the design of sampling programs,sampling techniques and the preservation and handling of samples.

    In situ monitoring instruments shall be calibrated before and immediately after the monitoring run andcalibration records maintained

    Samples for laboratory analyses shall be shipped with appropriate chain of custody documentation.

    All analyses shall be performed by a NATA accredited laboratory.

    Details relating to the collection and analysis of the sample must be retained for at least 3 years and madeavailable on request by an authorised officer. The sample must be taken and transported by a person withappropriate training and experience.

    A Consultant Environmental Chemist shall audit the laboratory and field monitoring protocols to ensurecompliance with best practice environmental monitoring methods.

    The water quality monitoring will be recorded on a works program log sheet. Photographic records willalso be taken which show easily recognisable monitoring points and provide indication of turbidity levels.

    Before any controlled discharge, that is intentional pumping or draining of water from site, an InternalPermit to Discharge Form (BBA-FRM-1000-1400-0001) must be completed and signed by a SiteEnvironmental Officer, who must ensure that the quality of the water to be discharged meets the aboverequirements and that there is no other possible use for the water.

    Responsibilities and reporting

    Activity Responsibility Timing To

    Monitoring pre andduring construction

    activities

    Gunns EnvironmentalManager

    Monthly BBA Environmental ManagerDirector of Environmental

    Management.Monitoring the water

    quality of stormwaterflows from variousconstruction sites.

    BBA Environmental

    Manager

    At commencement of

    construction.

    Appropriate BBA Construction

    Supervisors.

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    Surface and Marine Water Quality Monitoring

    Controlled discharge. BBA SiteEnvironmental Officer

    Before any controlledrelease

    BBA Contractor and BBAEnvironmental Manager.

    Confirmedhydrocarbon

    contamination and/orturbidity/suspendedsolids exceedance.

    BBA EnvironmentalManager

    Immediate to BBAConstruction

    Supervisors.Within 24 hrs to

    DTAE.

    Appropriate BBA ConstructionSupervisors.

    Director Env. Management

    Monitoring ofSediment Plume

    BBA EnvironmentalManager

    In the event of asignificant turbidity

    plume during works onDonovans bay and

    Wharf

    Notify Aquaculture Facility andReport to Director of Env.

    Management.

    A summary report ofall monitoring and nonconformances, if any.

    BBA EnvironmentalManager

    90 days aftercompletion ofconstruction.

    Gunns EnvironmentalManager.

    Director Env. Management.

    Dinoflagellate Cyst Monitoring

    Applicable permit conditions

    Schedule Part Section NumberSequential

    pageRequirement

    LU1 3 2 2MN3.363 of 201(Seq. 71)

    CMP to include dinoflagellate cyst monitoring

    LU1 3 33MR5.1 -

    5.4

    134-135 of201

    (Seq. 147 -

    148

    Dinoflagellate cyst survey report must be submitted forthe Wharf

    Objectives

    The primary objective of the dinoflagellate cyst monitoring program is to assess the presence ofdinoflagellate cysts at the wharf.

    Background

    Introduced marine pests are a major problem in Tasmania, dinoflagellate cysts are one of these pestspecies. A survey shall be carried out before construction to ascertain presence and the need forimplementation of mitigation measures.

    Monitoring methodology

    Sediment samplingSediment cores are taken from locations where the deposition and undisturbed accumulation of sediment

    and cysts is likely to occur. As a general guide, sites where there is an accumulation of uncompacted finesediment to a depth of 20 30 cm are most suitable.Coring is carried out by divers using 200 mm long 25 mm ID plastic tubes. These cores are forced into theundisturbed sediment to a depth that leaves the top 25 50 mm of the tube unfilled. The top of the tube iscapped with a bung, the tube is withdrawn from the sediment and the lower end is capped with anotherbung to provide an airtight seal. Cores are placed upright in an insulated box and stored in the dark at

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    Dinoflagellate Cyst Monitoring

    counted and identified by a suitably qualified expert. Where possible, at least 100 cysts are counted andidentified per sample. Cysts of suspected toxic species may be photographed with a light microscope.

    Cyst germination

    Cysts of suspected toxic species are located and isolated by micro pipette and washed twice in filteredseawater. Individual cysts are then placed into tissue culture wells containing 2 ml of 75% filteredseawater with nutrients added according to medium GPM of Loeblich (1975). Additional sedimentincubations using sub-samples from the 20-90 m size fraction are carried out in Parafilm sealed, sterilepolystyrene petri-dishes containing 20 ml of growth medium. Actively swimming dinoflagellate cells fromincubations are isolated by micro-pipette and washed in sterile growth medium prior to identification by asuitably qualified expert.

    Responsibilities and reporting

    Activity Responsibility Timing To

    Pre constructionsurvey

    BBA EnvironmentalManager

    Before construction Report to Gunns Env ManagerDirector of EnvironmentalManagement.

    Marine Sediment Monitoring

    Applicable permit conditions

    Schedule Part Section Number Page Requirement

    LU1 3 2 2MN3.3(f) 63 of 201

    (Seq. 76)

    CMP calls for a marine sediment monitoring program, itmust provide commitments, reporting potocol, it must beapproved by the Director, and be available to the public.

    LU1 3 2 2ER1.166 of 201

    (Seq. 79)

    Calls for erosion and sediment control monitoring andmaintenance program the monitoring relates to waterquality rather than sediment.

    LU1 3 23MR1.2 ( c)

    and (d)

    133 of 201

    (Seq. 146)

    Calls for results of the sediment survey andcharacterisation of sediment impacts to be included inthe Wharf Construction Plan.

    LU1 3 33MR15.1-

    15.2

    136 of 201

    (Seq. 149)

    Requires sediment cores (10 cores to 30cm) to be takenand chemically analysed prior to commencement ofwharf construction

    LU1 3 55DB10.1-

    10.2

    152 of 201

    (Seq. 165)

    Requires sediment cores (10cores to 30cm) to beundertaken and chemically analysed prior to thecommencement of the Donovans Bay crossingconstruction

    LU1 3 8 Annex M1201 of 201

    (Seq. 214)

    Parameters and Analyses for Construction Monitoring inState Waters

    LU3 3 -CN3.1 to

    3.7

    19 of 50

    (Seq. 258)

    CMP calls for a marine sediment monitoring program, itmust provide commitments, reporting potocol, it must beapproved by the Director, and be available to the public.

    LU3 3 -MN 1.1 (a)

    to (c)

    21/22 of 50

    (Seq.260/261)

    Samples must be analysed by a NATA accreditedlaboratory. Collection and analysis details maintained forat least 3 years. The sample must be collected andtransported by a person with appropriate training.

    LU3 3 -TM2.2(a),(b) and (f).

    28 of 50

    (Seq. 267)

    Calls for results of the sediment survey andcharacterisation of sediment impacts and a monitoringprogram to be included in the Tamar River CrossingPlan. The montoring program is part of the CMP.

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    Marine Sediment Monitoring

    LU3 3 - TM3.1-3.329 of 50

    (Seq. 268)

    Requires sediment cores to be undertaken prior to thecommencement of the Tamar River crossingconstruction

    LU3 3 - TM 7.1

    30 of 50

    (Seq. 269)

    Results of all monitoring associated with the Tamar

    Crossing must be submitted to the Director within 90days.

    LU3 3 - Annex M150 of 50

    (Seq. 289)

    Provides a comprehensive list of analytes for sedimentand water quality

    LU4 3 -CN3.1 to

    3.7

    20 of 52

    (Seq. 309)

    CMP calls for a marine sediment monitoring program, itmust provide commitments, reporting potocol, it must beapproved by the Director, and be available to the public.

    LU4 3 -MN1.1 (a)

    to (d)

    22/23 of 52

    (Seq.311/312)

    Samples must be analysed by a NATA accreditedlaboratory. Collection and analysis details maintained forat least 3 years. The sample must be collected andtransported by a person with appropriate training.

    LU4 3 - TM2.2(a),(b),(f)

    29 of 52(Seq. 318)

    Calls for results of the sediment survey andcharacterisation of sediment impacts and a monitoringprogram to be included in the Tamar River CrossingManagement Plan. The montoring program is part of theCMP.

    LU4 3 - TM3.1-3.3

    30 of 52

    (Seq. 319)

    Requires 3 equi spaced sediment cores to 5m becollected prior to the commencement of the TamarRiver crossing construction. Visual inspection withrepresentative samples taken from each sediment typefor detailed chemical testing.

    LU4 3 - TM7.131 of 52

    (Seq. 320)Within 90 days of completion of construction a detailedmonitoring report must be submitted to the Director.

    LU4 3 -AnnexM1??

    52 of 52

    (Seq. 341)

    Provides a comprehensive list of analytes for sedimentand water quality

    EM1 - - MN2.1-2.7

    10/11 of 25

    (Seq.351/352)

    CMP calls for a marine sediment monitoring program, itmust provide commitments, reporting potocol, it must beapproved by the Director, and be available to the public.

    Specifically calls for 5 equally spaced grab sedimentsamples along effluent outfall for comprehensive testing.

    EM1 - -MN 3.1 -

    3.2

    11 of 25

    (Seq. 352)

    5 Equally spaced sediment grab samples to be takenfrom the sub tidal section of the offshore constructioncorridor

    EM1 - -MN7.1 (a)

    to (d)

    13/13 of 25

    (Seq.353/354)

    Samples must be analysed by a NATA accreditedlaboratory. Collection and analysis details maintained forat least 3 years. The sample must be collected andtransported by a person with appropriate training.

    EM1 - - Annex M1

    20 of 25

    (Seq. 361)

    Parameters and analyses for Construction Monitoring in

    State Waters.

    Objectives

    The primary objectives of this component of the monitoring program are to measure any physico-chemicalimpacts due to sediment disturbance during construction at:-- the wharf adjacent to the mill site;- the effluent pipeline across Donovans Bay;- the water supply pipeline across the Tamar Estuary; and- the effluent outfall in Bass Strait.It will also ensure timely implementation of mitigation measures as required.

    Background

    Construction activities in the marine environment have the potential to disturb the sediment which if not

    appropriately managed could have adverse effects on flora, fauna and water quality in the immediate areaof disturbance.

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    Marine Sediment Monitoring

    The decision tree approach promulgated by ANZECC and ARMCANZ (2000) will be used to assess thepresent sediment quality in the marine footprint associated with the infrastructure listed above.Applicable requirements associated with this project are:-

    - Assess sediment contamination (total and d