PP 246
HOUSE OF ASSEMBLY
LAID ON THE TABLE
08 Mar 2016
FINAL REPORT
VICTOR HARBOR
WASTEWATER NETWORK
UPGRADE PROJECT
542ND REPORT
OF THE
PUBLIC WORKS COMMITTEE
Tabled in the House of Assembly and ordered to be published, 8 March 2016
Second Session, Fifty-Third Parliament
CONTENTS
THE PUBLIC WORKS COMMITTEE ........................................................................................................................... 2
THE FUNCTIONS OF THE COMMITTEE ................................................................................................................... 2
PART ONE: PREAMBLE AND PROJECT BACKGROUND ................................................................................... 3
1.1
1.2
1.3
1.4
TERM OF REFERENCE ........................................................................................................................................... 3
FURTHER REPORTING TO THE COMMITTEE .......................................................................................................... 3
SCOPE OF THIS REPORT ....................................................................................................................................... 3
PROJECT BACKGROUND ....................................................................................................................................... 4
PART TWO: EXECUTIVE SUMMARY ........................................................................................................................ 5
PART THREE: PROJECT PROPOSAL AND PRE-CONSTRUCTION ACTIVIITES ........................................... 6
3.1
3.2
3.3
3.4
3.5
THE CURRENT PROPOSAL .................................................................................................................................... 6
CONSULTATION...................................................................................................................................................... 7
ABORIGINAL HERITAGE ......................................................................................................................................... 7
HERITAGE BUILDINGS............................................................................................................................................ 7
ECOLOGICAL SUSTAINABILITY ............................................................................................................................... 7
PART FOUR: JUSTIFICATION AND IMPACT OF THE PROJECT ....................................................................... 9
4.1
PROJECT JUSTIFICATION ....................................................................................................................................... 9
4.2
PUBLIC VALUE OF THE PROPOSED PROJECT ..................................................................................................... 10
4.3
REVENUE EARNING CAPACITY OF PROPOSED PROJECT ................................................................................... 10
4.4
W HOLE LIFE COSTS OF THE PROJECT ............................................................................................................... 10
4.5
ESTIMATED NET EFFECT OF THE W ORK, AND ITS USE, ON PUBLIC FUNDS ...................................................... 10
4.6
PROJECT DELIVERY ............................................................................................................................................ 11
4.7
THE EFFICIENCY AND PROGRESS OF THE PROJECT AND JUSTIFICATION OF ANY EXPENDITURE BEYOND
ESTIMATED COSTS ........................................................................................................................................................... 12
PART FIVE: CONCLUSION & RECOMMENDATION ............................................................................................ 13
PART SIX: ATTACHMENTS ....................................................................................................................................... 14
6.1
6.2
6.3
LIST OF W ITNESSES AND SUBMISSIONS ............................................................................................................. 14
LIST OF SUBMISSIONS ......................................................................................................................................... 14
ATTACHMENTS..................................................................................................................................................... 14
Public Works Committee
1
Victor Harbor Wastewater Network Upgrade Project
THE PUBLIC WORKS COMMITTEE
The Public Works Committee is established pursuant to sections 12A, B and C of the Parliamentary
Committees Act 1991, proclaimed February 1992.
The following members constitute the nineteenth Public Works Committee as reconstituted on
6 May 2014:
Mrs Annabel Digance MP (Presiding Member)
Hon Paul Caica MP
Ms Dana Wortley MP
Mr Michael Pengilly MP
Mr Tim Whetstone MP
Staff assisting the Committee:
Executive Officer:
Ms Alison Meeks
Administrative Officer:
Mr Ryan-Lee Piekarski
THE FUNCTIONS OF THE COMMITTEE
Section 12C of the Parliamentary Committees Act 1991 defines the functions of the Public Works
Committee as:
(a)
(b)
to inquire into and report on any public work referred to it by or under this Act, including(i)
the stated purpose of the work;
(ii)
the necessity or advisability of constructing it;
(iii)
where the work purports to be of a revenue-producing character, the revenue that it
might reasonably be expected to produce;
(iv)
the present and prospective public value of the work;
(v)
the recurrent or whole-of-life costs associated with the work, including costs arising
out of financial arrangements;
(vi)
the estimated net effect on the Consolidated Account or the funds of a statutory
authority of the construction and proposed use of the work;
(vii)
the efficiency and progress of construction of the work and the reasons for any
expenditure beyond the estimated costs of its construction;
to perform such other functions as are imposed on the Committee under this or any other Act
or by resolution of both Houses.
Public Works Committee
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Victor Harbor Wastewater Network Upgrade Project
PART ONE: PREAMBLE AND PROJECT BACKGROUND
1.1
Term of Reference
Parliamentary Committees
Parliamentary Committees have the specific task of examining individual initiatives, projects or
policies of the government of the day, or issues of importance to society as a whole. Standing
Committees are created by an Act of Parliament and charged with the ongoing examination of subject
categories such as public works.
Parliamentary Committees are made up of both government and opposition members, with numbers
of each calculated according to rules which reflect the numbers of seats each group holds in the
Parliament. Much of the Committee process is open to the public and completed reports are public
documents.
This Project
SA Water has referred the Victor Harbor Wastewater Network Upgrade Project to the Public Works
Committee pursuant to the requirements of the Parliamentary Committees Act 1991. Please refer to
the "Functions of the Committee" on the previous page for a full description of the Committee's tasks.
1.2
Further Reporting to the Committee
SA Water must notify the Committee immediately in writing should there be substantial changes to the
nature of the project or the evidence provided to the Committee. To enable appropriate monitoring of
the project, SA Water must also provide quarterly reports to the Committee on the progress of
construction. Pursuant to section 12C (vii) of the Act, these reports must outline the efficiency and
progress of construction and provide an explanation of any expenditure beyond the estimated costs
quoted in this report. Evidence of any substantial changes to, or the withdrawal of, any approval
(provisional or otherwise) must also be relayed to the Committee immediately with an appropriate
explanation, and an assessment of the probability of a suitable resolution.
In addition, the Committee requires that it be notified of the proposed date for the commissioning of
the works.
The Committee has the authority under Section 16 (1)(c) of the Parliamentary Committees Act 1991
to re-open investigations into any project for the purpose of further examination and monitoring.
1.3
Scope of This Report
This report examines the history of the proposal and the efficacy of the application of South
Australian taxpayer funds to the Victor Harbor Wastewater Network Upgrade Project. The report
structure is guided by, and largely limited to, the terms of the Parliamentary Committees Act 1991.
It describes, in summary, the evidence presented to the Committee and concludes with a brief
summary incorporating findings and recommendations.
Detailed evidence upon which the Committee’s decision is based is held in Parliament and, in most
cases, can be examined by making an application to the Committee Administrative Officer.
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Victor Harbor Wastewater Network Upgrade Project
1.4
Project Background
The Victor Harbor wastewater scheme serves a population in excess of 14,000 permanent
residents (Australian Bureau of Statistics, 2014). This can increase fifty to one hundred percent
during holiday periods.
Sections of the Victor Harbor Wastewater Network are currently operating near or at capacity, and
with the proposed residential expansions and new Fleurieu Regional Aquatic and Health Centre
(FRAC) there is a need to expand the networks capacity.
There is a risk of wastewater overflows with the current network. Modelling of the network shows
that overflows would likely occur at the low point in the network immediately adjacent to the
Hindmarsh River mouth.
In addition, new development is occurring throughout the Victor Harbour Wastewater Network
catchment area, including residential development and the FRAC which is due for completion in
December 2016. Several other large areas in the north of the Victor Harbor area have been
rezoned for urban development.
Augmentation changes have been collected since 2007 and there are agreements in place for the
wastewater from the FRAC to be treated at the wastewater treatment plant. Hence there is a need
to upgrade the wastewater treatment network capacity to manage the additional wastewater. There
is also an expectation from the community that, given the collection of augmentation charges over
the years, the wastewater network and treatment plant will be upgraded and expanded as and
when required.
Public Works Committee
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Victor Harbor Wastewater Network Upgrade Project
PART TWO: EXECUTIVE SUMMARY
The Victor Harbor Wastewater Network is at capacity. In order to address this and the expansion in
the region, SA Water is proposing to upgrade the wastewater treatment network to accommodate
the additional wastewater flows at a cost of $7.289 million (GST exclusive).
The works will include the installation of approximately 6.2 kilometres of gravity and rising
wastewater mains pipeline and the construction of three new wastewater pump stations. The
project also includes the decommissioning of any superfluous wastewater pump stations.
This new network will provide services to the new FRAC and the proposed residential
developments. Augmentation charges have been collected since 2007 in anticipation of the need
to upgrade and/or expand the wastewater network to accommodate the growth in the region.
The project will ensure an adequate capacity for wastewater flows to 2030, and allow SA Water to
continue to meet its licensing obligations and other regulatory requirements.
The construction works for the project are due to commence in April 2016 with completion later in
the year.
Public Works Committee
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Victor Harbor Wastewater Network Upgrade Project
PART THREE: PROJECT PROPOSAL AND PRE-CONSTRUCTION ASSESSMENTS
3.1
The Current Proposal
The aim of the project is to provide the necessary infrastructure for SA Water to meet its current
needs, as the network is at capacity, and to accept future wastewater from the FRAC and new
developments in the Victor Harbor area. This will ensure SA Water continues to meet its licence
obligations and other regulatory requirements as specified in the Code of Practice for Wastewater
Overflow Management.
The proposed upgrade works will provide sufficient capacity to transfer the increasing quantity of
wastewater from new developments to the existing Victor Harbor Wastewater Treatment Plant,
providing adequate capacity for the area to 2030. The works to be undertaken are:

the installation of approximately 6.2 kilometres of gravity and rising wastewater mains
pipeline,

the construction of three associated wastewater pump stations, and

the decommissioning of superfluous wastewater pump stations.
The proposed works are in line with SA Water’s 2006 Master Plan for the area. Attachment 1
shows the proposed alignment for the project.
SA Water confirmed that the current treatment plant has the capacity to manage the additional
wastewater to be transported by the expanded wastewater network. The Committee sought
clarification regarding the reuse and quality of treated wastewater from the treatment plant, and
would like to see as much as possible of the treated wastewater being reused on ovals, parks, etc
and not discharged to the Inman River or the ocean.
The Committee raised concerns regarding the treated wastewater entering the Inman River from
time to time, and in particular the odour that is associated with this. They requested that this issue
be considered as part of the project.
Risk Management
SA Water reviewed the project using the Business Risk Management Policy and Framework, which
requires the identification of risks, their likely impact and severity, and proposed risk mitigation
strategies1. The extreme and high ranked identified risks are all form part of the “Base Case”
option which is not being pursued. They were:

adverse impact on SA Water reputation because SA Water would be seen as not
supportive of local development downstream, and

network exceeding its capacity with the potential to cause wastewater overflow incidents.
These risks will be mitigated as part of the upgrade.
Land Acquisition
There are a number of land acquisitions required for the project, from Alexandrina Council,
Hickinbotham and a private landholder. Discussions are still underway with the private landholder
and an alternative alignment could be implemented should the discussion not be successful.
1
The policy and framework is consistent with the Australia/New Zealand Risk Management Standard AS/NZS
ISO 4360.
Public Works Committee
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Victor Harbor Wastewater Network Upgrade Project
3.2
Consultation
SA Water informed the Committee that it is committed to ensuring high levels of stakeholder
engagement in order to manage expectation, concerns and any other stakeholder issues
associated with the project. It has developed a community and stakeholder engagement plan to
address the various project related matters raised through the stakeholder engagement process
during both the development and design, and that may be raised during the construction phases of
this project.
Consultation has already commenced with key state government departments, as well as the City
of Victor Harbor and Alexandrina Council. Local residents along the proposed route, including the
Encounter Lutheran College, have already been consulted. This identified one neighbour with a
new baby – a strategy is being prepared to best address the noise and possible dust impacts,
including the possibility of relocation for a short period during the drilling.
Letters are due to be sent to the local Members of Parliament from the Minister for Water and the
River Murray.
3.3
Aboriginal Heritage
SA Water engaged EBS Heritage to undertake a cultural heritage desktop assessment for the
project. It included a search of the Central Archive managed by Aboriginal Affairs and
Reconciliation in the Department of State Development, as well as a review of other relevant
historical and archival information. No registered or recorded heritage sites were identified within a
10 kilometre radius of the current project area
In considering the alignment options, Option 1 provides the least risk of encountering Aboriginal
heritage as the proposed works are primarily to be undertaken on already disturbed or excavated
land. However, the section of works through the Hickinbotham land, parallel to the Hindmarsh
River, presents the greatest potential of finding Aboriginal heritage. SA Water is seeking to engage
with the Ngarrindjeri people on the project.
The Design and Construct contractor will be required to comply with SA Water’s Standard
Operating Procedure for the Discovery of Aboriginal Sites during the construction work in the
unlikely event heritage is uncovered. Site construction employees will be inducted into the
requirements of this procedure.
3.4
Heritage Buildings
A heritage assessment was undertaken for the project site. No heritage sites were identified within
the project site and works area.
3.5
Ecological Sustainability
SA Water’s environmental policy embraces the following principles:

everything is connected,

the environment has physical limits,

water is a limited resource,

climate change effects,

pollution should be prevented wherever possible, and

environmental management requires a systematic approach.
As part of the contract requirements, the Design and Construct contractor is to develop processes
that include sustainability aspects such as the conservation and efficient use of resources and raw
materials, energy efficiency, generation and/or use of renewable energy, development of flexible
Public Works Committee
7
Victor Harbor Wastewater Network Upgrade Project
processes and products, design of closed loop processes where possible and where not, the
implementation of recycling and reuse to reduce waste, operating within the carrying capacity of
natural systems, providing a safe and healthy work environment, enhancing or not detracting from
the amenity of the area, and cost effective delivery. The contractor will also need to quantify and
report greenhouse emissions associated with the project.
A preliminary environmental impact and cultural heritage assessment has been undertaken (see
attachment 2). The Design and Construct contractor will be required to prepare an environmental
management plan that addresses the site specific environmental issues such as noise, dust,
erosion and stormwater management as well as any environmental conditions associated with
approvals.
Public Works Committee
8
Victor Harbor Wastewater Network Upgrade Project
PART FOUR: JUSTIFICATION AND IMPACT OF THE PROJECT
4.1
Project Justification
This project will address the key issues of potential environmental incidents caused by overflows. It
will also remove significant risks such as the ability of the system to cope with the additional
connection of new developments to the wastewater network as they arise.
In determining the project works, three options were considered in addition to the Base Case (do
nothing).
Base Case: business as usual (do nothing)
The Base Case consists of not upgrading the wastewater network. This will prevent immediate
and future local development in Victor Harbor, specifically preventing the FRAC from opening.
This is not considered viable. In collecting connection and augmentation charges, SA Water has
been preparing financially for the changes to the proposed wastewater network. SA Water has
also already collected augmentation charges from other developers for the proposed
wastewater network upgrade.
The associated reputation and wastewater overflow risks are extreme and high respectively.
This would lead to a loss of confidence in SA Water, both by the state government and the
general public.
Three Options
Three options, based on three pipeline alignments, were identified for the upgrade. The first
3.47 kilometre and the last 0.8 kilometre of the pipeline (referred to as the “common pipeline
alignments”) and the pump station adjacent to the proposed FRAC are common for all the three
options. (refer to Appendix A- Location plan).
The difference between the proposed options are the location of the wastewater mains and two
additional pump stations. The three options have been identified based on the following key
criteria:

Option 1 (preferred option) - the route that follows the road reserves as much as possible
and therefore requires the least amount of new easements,

Option 3 - the shortest route with the majority of the pipeline located on private land, and

Option 2 - an alignment that is a compromise of the first two criteria.
Option 1 consists of laying the majority of the gravity and rising mains along road reserves as
compared to the other two options. Approximately 1.4 kilometres will be laid on private land
resulting in a large amount of easements being required for Options 2 and 3, including in some
previously undisturbed ground resulting in a higher risk of poor ground conditions and rock, and
Aboriginal heritage impacts. Option 1 is the most economical and beneficial solution amongst
the three options, addressing the current risks and achieving the project outcome for the
customers.
The Base Case does not meet the aims of the project and hence a “do nothing’ option is not
considered feasible. The preferred option, Option 1 is the most viable considering cost, alignment,
and impact on landholders, and is therefore recommended
Public Works Committee
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Victor Harbor Wastewater Network Upgrade Project
4.2
Public Value of the Proposed Project
Benefits that will be achieved by this project include:

supporting the development in the Victor Harbour area, thus allowing continued growth
and prosperity of the region, and
 supporting the liveability in the region by continuing to provide essential services that
change rapidly with events such as Schoolies and the holiday seasons.
The proposed works align with the state government’s strategic priority “Safe Communities,
Healthy Neighbourhoods” and the following South Australia’s Strategic Plan (SASP) Targets:
Target 32. Customer and Client satisfaction with government services: Increase the
satisfaction of South Australians with government services by 10% by 2014, maintaining or
exceeding that level of satisfaction thereafter.
Target 56. Strategic infrastructure: Ensure that the provision of key economic and social
infrastructure accommodates population growth.
The project supports these SASP targets by providing a critical wastewater network infrastructure
as required by the current and growing population of the region, and reduces the environmental
risk of overflow into the Hindmarsh River community area near the river mouth.
4.3
Revenue Earning Capacity of Proposed Project
Revenue will be collected from new customers, both residents and businesses, who choose to
connect to the new wastewater network. Charges will be in-line with those charged to other customers
in the region.
4.4
Whole Life Costs of the Project
The project requires capital expenditure of up to $7.289 million in nominal dollars (excluding GST).
It is provided for within SA Water’s forward estimates from the Networks Extension annual
program. The project will therefore have no impact on SA Water’s overall capital plan, borrowings,
contribution to government or customer prices, nor will it adversely impact the outcomes of this
program.
To support the future expansion and upgrade of infrastructure in the region, there has been an
augmentation charge set for the Victor Harbor wastewater catchment since 2007. As such, there is an
expectation that the infrastructure will be upgraded and expanded as required. Also, SA Water has
committed to accepting the flows from the FRAC development and other growth areas in Victor
Harbour and hence committed to providing this infrastructure.
There is approximately up to $100,000 operating funding associated with additional maintenance
(75% of operating expenditure) and power consumption (25% of operating expenditure) required
as a result of this project. The increase in operating costs will be managed within SA Water’s
current operating budget.
4.5
Estimated Net Effect of the Work, and Its Use, on Public Funds
A financial analysis of the project has been undertaken by SA Water, in accordance with Treasury
Instructions and corporation guidelines. The analysis is based on a 30-year study period and uses
a cost of capital (discount rate) of 5.06% (real, pre-tax), which is SA Water’s regulatory weighted
average cost of capital as determined by the Essential Services Commission of South Australia
(ESCOSA) for the current regulatory period.
Options 1, 2 and 3 were compared against the Base Case to determine the best net present value
(NPV). The analysis is shown below.
Public Works Committee
10
Victor Harbor Wastewater Network Upgrade Project
Base Case
Option 1
Option 2
Option 3
30 years
30 years
30 years
30 years
Total capital
expenditure ($k)
0
6,761
7,030
6,984
Total residual
value ($k)
0
1,143
1,188
1,181
Total revenue ($k)
0
12,369
12,369
12,369
799
1,476
1,476
1,476
(799)
5,274
5,051
5,089
n/a
6,073
5,850
5,888
4
1
3
2
Review period
(years)
Total operating
expenditure ($k)
Total NPV ($k)
NPV incremental
to Base Case ($k)
NPV ranking
Notes:
1. Operating expenditure for Base Case includes projected clean-up costs, should an overflow occur.
2. Capital expenditure excludes sunk costs of $130 000 for project development work.
3. All numbers are in discounted real dollars.
Option 1 (preferred selected option) has the lowest capital cost and the highest NPV and overall
ranking compared to the other options. It has a substantially lower risks for pre-construction
(easement acquisitions and Aboriginal heritage approvals) and construction activities (adverse
environmental damage and impact on Aboriginal heritage) compared to Options 2 and 3.
Therefore Option 1 is preferred taking into account the identified risks and the marginal difference
in the financial NPV results.
Sensitivity testing was applied to the discount rate (plus-minus 2%). This did not change the
ranking.
4.6
Project Delivery
The project is due to commence construction in April 2016, with completion by the end of the year.
The timeframes are outlined below.
Full Financial Approval
February 2016
Major Order Placed
March 2016
Start Major Work
April 2016
Practical Completion
November 2016
Final Completion/End Defects Period
November 2017
Project Operational Handover/ Closeout
December 2017
The project received endorsement from the SA Water Board in December 2015 and from the
Minister for Water and the River Murray in January 2016.
This project is being managed in accordance with the SA Waters’ Corporate Project Management
Methodology by a senior project manager from SA Water’s Infrastructure Management Group. The
senior project manager is responsible for the development and delivery of the overall project
including seeking the necessary approvals and management of the selected contractor/works.
Public Works Committee
11
Victor Harbor Wastewater Network Upgrade Project
To ensure greater certainty around the timing and cost, the project will be delivered via a two-stage
procurement process with an initial Early Contractor Involvement (ECI) contract (Stage 1) followed
by a Design and Construct contract (Stage 2).
The ECI contractor will be selected for the Stage 1 contract phase based on their proven capability
and demonstrated relevant experience to deliver this project, develop the project scope and
undertake 90 percent of the design and specification enabling a robust target outturn cost to be
prepared to inform the full financial approval process. The successful ECI contractor will be
required to submit the following construction management plans prior to starting construction:

project management plan,

traffic management plan,

environmental management plan,

work, health and safety (WHS) management plan,

quality management plan, and

communication and stakeholder management plans.
SA Water is aware of the Industry Participation Policy administered by the Industry Capability
Network SA, a division of the Department of State Development. They have committed to comply
with the policy. It is anticipated that fourteen to twenty jobs will be created for the duration of the
project.
4.7
The Efficiency and Progress of the Project and Justification of Any
Expenditure Beyond Estimated Costs
The Committee will monitor the progress of the Victor Harbor Wastewater Network Upgrade Project
as required by the Parliamentary Committees Act 1991 through the regular reports SA Water is
required to provide prior to the completion of construction (refer to "Further Reporting to the
Committee"). The Committee will provide a further statement to Parliament in the event that
subsequent information provided renders this report inaccurate or misleading.
Public Works Committee
12
Victor Harbor Wastewater Network Upgrade Project
PART FIVE: CONCLUSION & RECOMMENDATION
The Public Works Committee has examined written and oral evidence in relation to the Victor
Harbor Wastewater Network Upgrade Project. It has also been assured by SA Water officials that
acquittals have been received from the Department of Treasury and Finance, Premier and Cabinet
and the Crown Solicitor that the works and procedures are lawful. The Committee is satisfied that the
proposal has been subject to the appropriate agency consultation and meets the criteria for
examination of projects as set out in the Parliamentary Committees Act 1991.
Based upon the evidence considered, and pursuant to Section 12C of the Parliamentary Committees
Act 1991, the Public Works Committee reports to Parliament that it recommends the proposed public
work.
Mrs Annabel Digance MP
PRESIDING MEMBER
Public Works Committee
Public Works Committee
March 2016
13
Victor Harbor Wastewater Network Upgrade Project
PART SIX: ATTACHMENTS
6.1
List of Witnesses and Submissions
The following people appeared before the Committee on 25 February 2016 at Parliament House,
North Terrace, Adelaide:

Mr Jim McGuire – General Manager Commercial and Business Development, SA Water

Mr Randall Bonner –Senior Manager Infrastructure Delivery, SA Water
6.2
List of Submissions
SA Water, Victor Harbor Wastewater Network Upgrade Project, February 2016
6.3
Attachments
Attachment 1: Alignment for New Wastewater Network
Attachment 2: Environment and Heritage Assessment Report and Project Environmental
Management Plan
Public Works Committee
14
Victor Harbor Wastewater Network Upgrade Project
ATTACHMENT 1: Alignment for New Wastewater Network
ATTACHMENT 2:
Environment and Heritage Assessment Report and Project
Environmental Management Plan
IS Method
Environment and Heritage Services
Environment and Heritage
Assessment ReportIS Method
and
Project Environmental
Management Plan (PEMP)
Project:
Version:1.0
Date: 14/12/15
Status:Issued – for ECI
Document ID: EMS 01 Template EHA Response
Capital Project Number: C3714
© 2015 SA Water Corporation. All rights reserved.
This document may contain confidential information of SA Water Corporation.
Disclosure or dissemination to unauthorised individuals is strictly prohibited.
Uncontrolled when printed or downloaded.
Environment and Heritage Services – Environment and Heritage Assessment Report and Project Environmental Management Plan
(PEMP) Project:
SA Water
Document Controls
Version History
Version
Date
Author
Comments
0.01
11/09/15
Tara Hage
First draft.
1.0
14/12/15
Tara Hage
Issued to inform ECI
Template: Document - Long Version 2.03 13/05/15
Reviewers
Note: Review of this document is required prior to issue to PMs in the following instances:

By AHEO - where outcome of the heritage assessment identifies: a ‘elevated risk of encountering
heritage’ and where specific heritage controls have been identified.

By Mgr, EHS – where a complex or potentially ‘sensitive’ potential environmental issue(s) is identified
Role
Name
AHEO
Ben Denison/Sara Smith (AH
section)
Version 0.01 dd/mm/yy Draft
For Official Use Only
Document ID: TBD
Version
0.1
Review Date
Sept 2015
Page 2 of 46
Uncontrolled when printed or downloaded
Environment and Heritage Services – Environment and Heritage Assessment Report and Project Environmental Management Plan
(PEMP) Project:
SA Water
Contents
1
Introduction ............................................................................................................... 5
1.1
Project understanding and description of works .......................................................... 5
1.1.1
Background ............................................................................................................... 5
1.1.2
Project Objective ...................................................................................................... 6
1.1.3
Proposed Scope of works ......................................................................................... 6
1.1.4
Alternatives considered ............................................................................................ 6
1.2
Key Construction Activities ............................................................................................ 7
PART A: Project Environment and Heritage Assessment ........................................................ 9
1
Description of existing site ......................................................................................... 9
1.1
Description of project scope and alignments .............................................................. 10
1.2
Biological Environment ................................................................................................ 12
1.2.1
Vegetation .............................................................................................................. 12
1.2.2
Fauna ...................................................................................................................... 15
1.2.3
Pest Plants and animals .......................................................................................... 17
1.3
Physical Environment................................................................................................... 18
1.3.1
Water and water quality ......................................................................................... 18
1.3.2
Air Quality ............................................................................................................... 19
1.3.3
Site Contamination ................................................................................................. 20
1.3.4
Waste and Resource Use ........................................................................................ 20
1.4
Social Environment ...................................................................................................... 21
1.4.1
Noise and Vibration ................................................................................................ 21
1.4.2
Night Works ............................................................................................................ 22
1.4.3
Community and Land use ....................................................................................... 23
1.4.4
Access ..................................................................................................................... 23
1.4.5
Amenity................................................................................................................... 24
1.4.6
Heritage (European) ............................................................................................... 24
1.4.7
Aboriginal Heritage ................................................................................................. 25
1.4.8
Native Title.............................................................................................................. 26
1.4.9
EPA Licenced site .................................................................................................... 26
Part B: Project Environment Management Plan .................................................................. 27
1
Objectives of the Environmental Management Plan .................................................. 27
2
Key Assessment Outcomes ....................................................................................... 27
3
Legal and other requirements ................................................................................... 29
4
Environmental Management System and Structure ................................................... 31
4.1
Environmental system requirements .......................................................................... 31
4.2
Inductions and Training ............................................................................................... 31
4.3
Records and record keeping ........................................................................................ 31
4.4
Roles and Responsibilities............................................................................................ 31
4.4.1
Project Manager ..................................................................................................... 31
Version 0.01 dd/mm/yy Draft
For Official Use Only
Document ID: TBD
Page 3 of 46
Uncontrolled when printed or downloaded
Environment and Heritage Services – Environment and Heritage Assessment Report and Project Environmental Management Plan
(PEMP) Project:
SA Water
4.4.2
4.4.3
4.5
4.5.1
4.5.2
Site Supervisor/ Site Manager ................................................................................ 31
Employees, sub-contractors and Labour hire personnel........................................ 32
Inspections and Monitoring of Environmental Performance ...................................... 32
Audits and Inspections............................................................................................ 33
Non -conformance and corrective actions ............................................................. 33
5
5.1
5.2
Emergency Response and Environmental Incidents ................................................... 33
Emergency Planning, Preparedness and Response ..................................................... 33
Environmental Incident Management ......................................................................... 34
6
Environmental Management Controls ...................................................................... 35
Appendix A
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1
Introduction
This document outlines the primary environmental and heritage issues and potential impacts related to the
proposed augmentation of the wastewater network at Victor Harbor.
The report is broken into three key parts:
 Introduction - Summarises the project, construction activities and alternative options that may be
been considered.
 Part A - documents the outcomes of the environmental and heritage assessment, including the
matters considered as part of the assessment, the outcomes of any investigations or further
investigation requirements.
 Part B - includes the Project Environment (and Heritage) Management Plan (PEMP, it identifies any
regulatory approval requirements for the project (and their status where relevant) and further
details environmental management measures and controls to be implemented to manage or
mitigate identified impacts, particularly during construction.
The Victor Harbor wastewater network upgrade (Stage 3) is being delivered via an Early Contractor
Involvement (ECI) process. This assessment report is based on a high level design developed to inform
pipeline alignment options. It is anticipated that further development of the project will involve additional
environmental investigations and considerations.
The ECI contractor should ensure that the outcomes and recommendations including mitigation measures
identified and environmental controls in this report are considered during the design development for the
project. Following the outcomes of the first stage of the ECI, the environment management requirements
will be reviewed and updated.
1.1 Project understanding and description of works
Network flow modelling has been undertaken on the Victor Harbor wastewater network to assess the
current and long term flow projections against the current network capacity. The modelling indicates that
parts of the network are at peak capacity and require augmentation. This project proposes a wastewater
network upgrade to address current capacity issues within the wastewater network.
1.1.1 Background
The Victor Harbor region has experienced strong and continuing development over a number of years.
The current wastewater network is configured such that wastewater flows by gravity and pumping to the
site of the old Wastewater Treatment Plant (WWTP) and then is pumped up to the new Trillity operated
Victor Harbor WWTP on Greenhill Road (Refer to Figure 1).
As a result of the development in the area the wastewater network is running at capacity. Modelling also
shows that during peak periods the network runs over its capacity causing network surcharging and is at
risk of overflows to the environment. As a result the network has been identified as needing
augmentation, particularly to service new development areas.
In 2006, SA Water undertook a master planning process for the Victor Harbor area to define augmentation
requirements, appropriate staging of works and to develop an augmentation charge. The current project
comprises Stage 3 of the identified augmentation requirements.
The masterplan identified that the most cost effective solution to address the network issues was to pump
the wastewater flows from the Hayborough development area (adjacent to Ocean Road) directly to the
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new Victor Harbor WWTP with an alignment that would be able to pick up flows from some of the future
development areas.
This project proposes to upgrade the Victor Harbor wastewater network such that it has sufficient capacity
to transfer the increasing quantity of wastewater. This increase is being generated by the growing
population of Victor Harbor as well as several planned developments including a new Regional Aquatic and
a Health and wellbeing Centre at the intersection of Ocean Road and Waterport Road and adjacent new
housing (refer Figure 1).
1.1.2 Project Objective
The objective of this project is to upgrade the wastewater network to address current network capacity
issues, though the construction of a combination of new wastewater gravity mains, pump stations and
rising mains that will transfer wastewater from the new Aquatic and Health Centre, due to be completed in
December 2016, and surrounding development areas, to the Victor Harbor WWTP operated by Trility.
1.1.3 Proposed Scope of works
The proposed project scope is to design and build a combination of new sewer gravity mains (with pipe
sizes ranging between DN150 and DN200), four pump stations and rising mains (with pipe sizes ranging
between DN200 and DN225) that will transfer wastewater from the new Aquatic and Health Centre and
Hickenbotham Development to the new WWTP, located off Greenhills Road, for a total distance of
approximately 6.2km. The scope of work also includes minor connections and decommissioning of existing
wastewater pumping stations (WWPSs).
1.1.4 Alternatives considered
The master plan developed in 2006 considered a range of options for augmenting the Victor Harbor
wastewater system. The outcomes of this planning work identified that the most efficient cost effective
solution would be to pump wastewater flows from the Hayborough development area directly to the new
Victor Harbor WWTP with an alignment that is able to pick up flows from some of the new future
development areas.
Three pipeline alignments were considered as part of the option investigation phase for this project.
The first 1.6km pipeline and the pump station adjacent to the new Aquatic and Health Centre were
common for all three options. Early investigations determined that there were no other clear or feasible
alignments for this section which is referred to as the “Common Pipeline Alignment”.
For the remainder of the pipeline three possible alignments were investigated (Refer Figure 2). These
options were been identified based on key criteria as listed below:
1. Shortest route (Option 3);
2. Route that follows road reserves as much as possible and therefore requires the least
amount of new easements (Option 1); and
3. An alignment that is a compromise of the first two criteria (Option 2). This option is referred
to as “developer friendly” option because the pipeline along two property boundaries, with
a pump station at the lowest corner will enable developers to connect to the system by
gravity.
In addition a Base Case option was considered which involved not proceeding with the project at this time.
This option was discounted as not proceeding with the project would prevent the connection to the
Aquatic and Health Centre which effectively would prevent the opening of this centre. It was also
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considered that not proceeding did not address the current environmental risks of overflows due to the
system operating at capacity.
The recommended option, Option 1, consists of laying the majority of the gravity and rising mains along
road reserves as compared to the other two options (Options 2 and 3) where approximately 1.4km section
will be laid in private lands resulting in large amount of easements be required, and some in previously
undisturbed ground resulting highest risk of poor ground conditions/rock and greater potential to
encounter Aboriginal heritage.
Given these benefits, Option 1 was considered the most economic and preferred option.
1.2 Key Construction Activities
Table 1 below provides a summary of typical project construction activities and potential environmental
issues/impacts. It includes those activities which are likely to be undertaken as part of the works. Where
an issue is identified the management / environmental controls included in Part B should be implemented.
The following table identifies the documents and/or articles that are referenced in this document:
Table 1 Construction Activities and associated environmental impacts
Activity / Aspect
Potential Environmental Issues/Impact
Use of vehicles, equipment & plant
Noise creating nuisance
Property damage from vibration
Emissions to air from equipment
Introduction/spread of weed seeds or plant pathogens
Fire (hot works or use near dry vegetation)
Nuisance to neighbours – access, light spill etc
Storage of materials, maintenance
and refuelling of machinery and
equipment
Spills leading to pollution and contamination of soil, water
Damage to vegetation and fauna
Emissions of noxious / toxic gases
Washdown of equipment/plant
Pollution to water (watercourses or stormwater)
Introduction/spread of weed seeds or plant pathogens
Damage to vegetation and fauna
Excavation and earthworks
Damage to vegetation and fauna
Disturbance or damage to Aboriginal and non-Aboriginal Heritage
Discovery/management of soil or groundwater contamination
Dust
Erosion of exposed surfaces
Pollution to water (watercourses or stormwater)
Stockpiling / spoil management
Damage to vegetation and fauna
Pollution to water bodies from poor location / erosion /runoff
Water management and flooding
Dust
Inappropriate waste disposal/landfill
Contamination
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Activity / Aspect
Potential Environmental Issues/Impact
Amenity of the estuarine/beach environment for water/beach users
Waste Management and Disposal
Aesthetics – litter/ debris
Inappropriate waste disposal/landfill
Resource use
Dredging
Inappropriate waste disposal
Pollution to water (watercourses)
Damage to vegetation and fauna
Impacts to recreational uses of area / nuisance
Import of fill material
Introduction of weeds and diseases (phytophthora)
Contamination (imported)
Site / compound establishment
Aesthetics – visually intrusive structures
Inappropriate waste management, litter
Access impacts and nuisance to neighbours
Noise creating nuisance
Dewatering or other discharges/
water released from site
Pollution
Water management and flooding
Contamination
Damage to vegetation
Night works
Noise
Light spill and nuisance to neighbours
Management of contaminated or
hazardous materials
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PART A: Project Environment and Heritage Assessment
1
Description of existing site
The proposed network augmentation works, will be located in the Victor Harbor region, extending from the
Hayborough development area (corner of Ocean Road/Waterport Road) to the Victor Harbor WWTP
located at Greenhills Road. This broad project area is characterised by a mixture of semi-rural/residential
land uses located between the townships of Victor Harbor, Hindmarsh Valley, McCracken and Hayborough.
The majority of the landscape within the vicinity of the proposed pipeline has been highly modified and
predominantly consists of cleared paddocks interspersed with rural living dwellings. Vegetation in the
project area is highly altered, with native vegetation predominantly restricted to roadsides, along
watercourses and swamp/depressions and scattered paddock trees.
The preferred pipeline alignment traverses a mixture of road reserve and paddocks with scattered trees. In
addition, the pipeline will need to cross a gully via a pipe bridge and the Hindmarsh River via
boring/directional drilling. The alignment includes land that whilst currently comprising paddocks has been
identified for future development into residential allotments by Hickinbotham.
Figure 1 Victor Harbor Project area and proposed pipeline alignment
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Figure 2 Proposed pipeline alignments – (Preferred alignment Option 1 shown in purple)
1.1 Description of project scope and alignments
The project involves the construction of approximately 6.2 km of pipeline comprising rising mains and
gravity mains as well waste water pumping stations (WWPSs). An overview of the alignment is provided in
Figure 2 and 3 and summarised below:
 Construction of a new wastewater pumping station (WWPS) on a new site to replace the existing
WWTP located at the Ocean Road / Waterport Road. The existing pump station at the intersection
of Ocean Road and Waterport Road will be abandoned and the flows will be diverted to the new
pump station (PS0).
 A new pipeline (rising main) along Waterport Road and Strawberry Hill Road which discharges to a
manhole at western end of Strawberry Road.
 From the Strawberry Road manhole the pipeline will exit the manhole going west along Adelaide
Road and gravitate along the southern boundary of Hickinbotham’s land toward the Hindmarsh
River.
 The gravity sewer will then turn north and runs along the western boundary of the Hickenbotham
land ending at a new WWPS (PS1 as per Figure 3) to be constructed at a site in the north western
corner of the Hickenbotham land. The pipe will be required to cross large gully in this section,
provisionally it is assumed that the gulley will be crossed using a pipe bridge..
 From here, the rising main will run along Welch Road to Waggon Road.
 In order to cross the Hindmarsh River, the pipe will either be bored under the river or could be
attached to the side of the Council Road Bridge.
 At the downstream of the Hindmarsh Bridge crossing, the pipe follows the road west to a point at
CH3470 (see Figure 3). Downstream of CH3470,.
 From CH3740 the alignment option follows Armstrong Road for approximately 850m towards Day
Road. It then cuts cross the corner of a paddock and joins Day Road after approximately 370m. The
pipe will then follow Day Road to Greenhills Road, approximately 1,000m. It then turns west along
the WWTP access road and enters the WWTP.
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Figure 3 Alignment Options and Development areas
Figure 4 looking toward Hindmarsh River at
nominal crossing location
Figure 5 Looking away from Hindmarsh River at
nominal crossing location
Figure 6 Approximately pipeline alignment through Hickenbotham land
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1.2 Biological Environment
1.2.1 Vegetation
Potential aspect/impact
Tick if relevant
No identified impacts and/or no risk of impacts to vegetation as part of project
☐
Potential impacts to vegetation. (If ticked, complete section below) –
☒
Ensure total construction footprint considered – including access requirements, laydown/stockpile areas,
turnaround, re-connections etc (may not all be within main project site)
Native Vegetation
New works (approval required):
Level 1 (minor) ☐
Level 2 (medium)
☒
Level 3 (major) ☐
Impacts covered by operational / maintenance regulations
☐
Vegetation with conservation value and/or rare/threatened/protected species/communities
present within or adjacent to works area (consider regional, state and national ratings)
☐
Vegetation with high habitat value, wetlands / riparian zones within works area
☒
Other (specify eg vegetation covered by heritage agreement)
☒
Other vegetation (inc Significant / Regulated trees)
Works will impact significant / regulated trees
☐
Works will impact non protected vegetation eg amenity plantings
☒
Vegetation description (include area/number of trees to be removed, pruned, condition of vegetation etc)
EBS ecology undertook a desktop flora and fauna assessment of the three potential pipeline alignments
(including the ‘common alignment’)
The aim of the desktop assessment was to identify any constraints or issues from an ecological
perspective and inform option selection and further project development requirements.
The assessment was undertaken on broad pipeline routes rather than on a detailed design as such the
exact location of the pipeline and extent of construction impacts (i.e. limited to the road or on the road
reserve) was not known at the time of the assessment. To be conservative it was assumed that the
construction footprint may extend into road reserves.
Native vegetation remnancy across the project area is low, with approximately 11% (4,117 ha) of the
Inman Valley environmental association mapped as remnant native vegetation, of which 28% (1,150 ha) is
formally conserved. As such vegetation that remains in the region is considered important of value and
should be retained wherever possible.
EBS identified two primary main areas along the proposed pipeline that contain stands of native
vegetation as per DEWNR vegetation mapping. A Eucalyptus fasciculosa (Pink Gum) Woodland was
mapped as occurring at the northern intersection of the preferred pipeline location and common
alignment and a Eucalyptus camaldulensis var. camaldulensis (Red Gum) Woodland is present along the
Hindmarsh River which is intersected by the Common Pipeline, south of the Victor Harbor Harness Racing
Club. Refer to the full EBS report for further details.
The common pipeline alignment mostly crosses cleared paddocks. It intersects Eucalyptus camaldulensis
var. camaldulensis (River Red Gum) Woodland along the Hindmarsh River. There is scattered native
Eucalyptus sp., native sedges and natural waterbodies along Strawberry Hill Road. EBS identified that
native sedges (presumably Gahnia and Juncus sp.) are scattered on either side of Strawberry Hill Road
(mostly outside the road reserve). The brackish marsh directly south of Strawberry Hill Road has been
revegetated and is likely to be utilised by waterbirds.
The Option 1 alignment largely follows road reserves and EBS identified that it has the potential to
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Potential aspect/impact
Tick if relevant
interact existing vegetation both remmant and planted within sections. The road reserve along Days Road
is lined with vegetation. The northern road reserve appears to consist of a row of planted tall, mature
exotic pines trees (Pinus sp.) with an exotic grass understorey, as well as patches of mixed shrub/tree
plantings (which appear to be predominantly Acacia sp. and Eucalyptus sp.). The southern road reserve
appears to predominantly comprise mixed native shrub and tree plantings (assumed approximately 10
years old). There is remnant native vegetation on a sandy substrate at and approaching the intersection
with Colebatch Road. Visible species are Xanthorrhoea semiplana ssp (Yacca) and Eucalyptus sp. The
understorey appears to be highly degraded.
Along Days Road from Colebatch Road intersection to Armstrong Road, there is remnant native vegetation
scattered along both sides of the road; visible species include Eucalyptus fasciculosa (Pink Gum),
Eucalyptus baxteri (Brown Stringybark) Xanthorrhoea semiplana ssp. (Yacca), Acacia longifolia ssp.
sophorae (Coastal Wattle) and Leptospermum sp. (Tea-tree). Inter-mixed planted vegetation is also
present. Based on nearby roadside vegetation mapping (Transport SA Roadside Survey 2005) Eucalyptus
cosmophylla (Cup Gum) and a range of native understorey species could potentially be present.
The road reserve on both sides of Armstrong Road (Day Road intersection to Waggon Road intersection)
has previously been cut-in to construct the road and consists mostly of native tree/shrub plantings and
potentially native regrowth. The road reserve along Waggon Road is lined with native Eucalyptus sp.
hence the pipeline may impact on some trees in this section.
Figure 6 Mapped Native Vegetation Communities in Project Area
Threatened communities in project area
A Protected Matters Report was generated on 7/7/2015 to identify matters of national environmental
significance under the Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act) that may
occur or may have suitable habitat occurring within the project area. A buffer of 1 km around the pipeline
route was applied for this search (DOE 2015). No nationally threatened ecological communities listed
under the EPBC Act were identified in the EPBC Protected Matters Search as being present within the
project area (DOE 2015).
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Potential aspect/impact
Tick if relevant
No nationally threatened ecological communities listed under the EPBC Act were identified in the EPBC
Protected Matters Search as being present within the project area (DOE 2015).
In their report EBS also advise that E. fasciculosa +/- E. leucoxylon Heathy Woodland on sandy loams of
flats and slopes is considered a state vulnerable ecosystem. The reserved examples are mostly small and
in poor condition (DEH in progress). The E. fasciculosa woodland within the project area may be
considered part of this community. Impacts to this area will need to be minimised as part of progressing
the project.
Gahnia filum Sedgeland in drainage lines and depressions is provisionally listed as a State threatened
community (DEH in progress). EBS identified that the sedgeland along Strawberry Hill Road could be
considered part of this community. However impacts to this area are not likely to be significant much of
vegetation occurred outside the road reserve.
Conclusion
The initial vegetation assessment undertaken by EBS was a desktop assessment which involved reviewing
existing spatial datasets including: vegetation cover, watercourses, DEWNR floristic mapping, biological
survey sites, protected areas, DPTI roadside vegetation survey, Heritage Agreements and SEB offset areas
under the Native Vegetation Act 1991. Relevant literature, aerial imagery (Google satellite and street
view), and previous survey information was also reviewed by EBS. Site visits have been undertaken to
review potential impacts, however no detailed ground assessments or field based survey work has been
undertaken at this stage.
Actual impacts to vegetation will need to be confirmed as part of further design development.
Summary of impacts
Area of native vegetation to be removed
TBC once detailed design developed
Condition of vegetation (describe & as ratio)
Number of trees to be removed
Sign/Reg:
Other:TBC
Number of trees to be pruned
Sign/Reg:
Other:TBC
Alternatives & Mitigation Measures to be employed to avoid or minimise impacts
Further assessments of vegetation type and condition should be undertaken as part of the design
development, including at the pump station locations to inform mitigation strategies for avoiding impacts
to vegetation.
Design
The following mitigation measures are to be addressed as part of further design development:

Impact to native vegetation will require assessment and approval under the Native Vegetation Act
1991 and in accordance with SA Water’s Native Vegetation Standard Operating Procedure (SOP)

A field vegetation survey is required to look more closely at the vegetation and confirm the
presence/absence of threatened species and potential impacts to vegetation.

The pipeline alignment should avoid or minimise requiring excavations that would encroach the
on the tree protection zone (TPZ) of established trees /scattered trees including :
o Scatted trees along the alignment through the Hickinbotham site, around Hindmarsh
River, section of pipeline from near Colebatch Road to Armstrong Road, near the
intersection of Armstrong Road and Waggon Road and along Days Road.
o An arborist assessment should be undertaken to inform requirements for tree retention.

Location of WWTPs infrastructure and pipeline alignments should be such to avoid impacts to
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Potential aspect/impact
Tick if relevant
native vegetation where it is present, particularly areas of higher SEB value (i.e. Hindmarsh River
area, Waggon Road/Armstrong Road intersection, Strawberry Hill Road)

Where pipelines alignments are located within road reserve impacts to native vegetation should
be avoided by locating the pipeline, where practical, away remnant roadside vegetation.

Construction footprint to be minimised were possible in areas where native vegetation is present.

Avoid impacts to the already established native vegetation offset area as identified in the EBS
report (Strawberry Hill Road)
Construction

Construction footprint to be minimised in areas where native vegetation is present

Ensure hygiene protocols are strictly followed to avoid spreading of Phytophthora and pest plant
species



Ensure only vegetation approved for removal is impacted
Development Contractor EMP to include vegetation protection measures.
Refer also to Section 6 for further construction controls.
1.2.2 Fauna
Aspects
Tick where
relevant
Low risk of impacts to fauna or fauna habitat identified for the works
☒
Impacts to fauna or fauna habitat (breeding areas, nests or hollows, barriers and corridors) *consider
terrestrial and/or aquatic (inc consider fish barriers or impacts to flows) and consider timing of works
☒
Rare and endangered species or migratory species potentially in/adjacent to works area (EPBC Act and
NPWS)
☐
Other (specify)
☐
Summary of assessment and potential impacts
EBS ecology undertook a desktop fauna assessment of the three potential pipeline alignments (including the
‘common alignment’). The desktop assessment did not identify any potential significant impacts to fauna
though it did identify that any potential impacts to vegetation associated with the works could impact the
habitat of some native species.
Native vegetation has high conservation value, particularly given the low level of remnancy within the
broader region. EBS identified that the habitat value for most of the pipeline alignment is low given the
modified nature of the landscape. The established vegetation along Days Road and Hindmarsh River has
high habitat value, particularly for birds and the Common Brush-tailed Possum. Scattered remnant paddock
trees may contain hollows and also have habitat value, particularly given the low level of remnancy.
The natural wetland areas along the Hindmarsh River, Strawberry Hill Road would be seasonally utilised by
a range of waterbirds, including potentially threatened waterbird species.
Threatened species in project area
The EPBC Protected Matters Search (1 km buffer) identified six threatened birds, one threatened fish, one
threatened mammal and 11 listed migratory bird species which may occur or may have habitat occurring
within the project area (DOE 2015).
EBS identified that some of the wetland birds species are considered as having potential to occur within the
project area. The other species are considered unlikely to be present. None of the species were considered
to be significantly impacted by the proposed works.
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Aspects
Tick where
relevant
In addition, the BSDBA search identified numerous threatened terrestrial fauna species with records within
5 km of the project area (EBS 2015). Thirteen bird species, 2 mammal species and 2 reptile species are
considered as potentially present within the project area, though impacts to these species are not
considered likely to be significant based on the temporary nature of the works and limited size of the
construction footprint.
BDBSA threatened fauna records within close proximity to the pipeline alignment are shown in the figure
below. In addition to the BDBSA records, there is a record from the Atlas of Living Australia (not mapped) of
the state rare Spotless Crake (Porzana tabuensis) within the marshy area along Strawberry Hill Road, on the
common pipeline route (ALA 2015).
Further details can be found in the EBS Report.
Figure 7 Records of Threatened Fauna Species in Project area and surrounds
Alternatives & Mitigation Measures
Design
The following mitigation measures are to be addressed as part of further design development:


Design to retaining and buffering native and planted vegetation
Retaining established trees, as fauna habitat
Construction

Construction footprint to be minimised in areas where native vegetation/habitat is present

Development Contractor EMP.

Refer also to Section 6 for further construction controls.
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1.2.3 Pest Plants and animals
Aspects
Tick where
relevant
Declared/environmental weed species within project area or surrounds
☒
Pest animal species that may require management
☐
Phytophthora, phylloxera risk ?
☒
Identify whether a ‘High/Medium/Low Potential Threat Area’ under the Phytophthora
☐
Other (specify)
Summary of assessment and potential impacts
A site inspection of the project area and pipeline alignments identified the presence of a number of weeds
(eg oxalis, salvation jane, onion weed) within the project area. Removal of topsoil and movements of plant
and machinery though the project area has the potential to encourage the spread of these species if
measures are not in place to control.
In addition, EBS identified that there are known infestation of Phytophthora at the eastern end of the
Common Pipeline alignment.
Figure 8 Records of Phytophthora
Alternatives & Mitigation Measures

Ensure hygiene protocols are strictly followed to avoid spreading of Phytophthora and pest plant
species.

Refer also to Section 6 for further construction controls.
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1.3 Physical Environment
1.3.1 Water and water quality
Aspects
Tick where
relevant
Waterbodies (watercourse, wetlands, coastal/marine) within or close to works area
☒
Stormwater infrastructure (drains/culverts) within or close to works area
☒
Water management and/or flooding risk (consider catchment above work site and below)
☐
Works within watercourse (inc on banks) or involve alteration/modification of drainage lines or
flow patterns (either during construction or operation)
☒
Discharges to land or water (or change to existing discharges) required during construction,
commissioning/testing and/or during operation)
☒
Groundwater impacts eg potential for dewatering or interaction with groundwater during works
☒
Construction of bore / well or other operation requiring drilling
☐
Soil, Erosion & Drainage Management site specific controls required during works eg erosion
control required, sedimentation risk, bank/batter stabilisation required
☒
Change in non-permeable surface area - change to flow/drainage requirements at site
☒
Risk of pollution to water from construction/operation, risk of spills, etc
☒
Acid sulphate soil risk
☐
Large volumes of water required during construction (dust suppression, construction water).
consider source and volume
☐
Other (specify)
☐
Summary of assessment and potential impacts
The project area falls within the Hindmarsh River Catchment and Brown Hill Catchment.
Construction works for both the pipeline and pump stations will involve excavation and associated ground
disturbance. This will create a potential risk of erosion. In addition the pipeline route will need to cross a
the Hindmarsh River (south of the Victor Harbor Harness Racing Club). It also intersects a large brackish
marsh near the eastern end of the common pipeline route. Works in the vicinity of the river have the
potential to impact water quality and release of sediment into the watercourse if not managed
appropriately. Initial design work has identified that the river crossing will utilise trenchless technology
which will assist with mitigating these risks.
A review the WaterConnect online database indicated that groundwater depths vary from 2 m to15 m BGL
along the proposed pipeline alignment. Standing groundwater has been recorded in wells at depths of
approximately 2 m near Hindmarsh River and approximately 3 m near Armstrong Road Creek. Records
away from the watercourses show standing water levels at depths ranging from approximately 3 m to 15
m below ground level. Groundwater levels are potentially subject to seasonal and climatic variation and
perched water could also be encountered in areas of the proposed alignment. Noting these depths,
particularly near the watercourses and deeper with if deeper sections of excavation are required in some
sections, groundwater dewatering may be required.
It is important that stormwater management be implemented during works to prevent sediment laden
runoff leaving the works site and where relevant entering the River. This management should focus not
only on the construction envelope but also laydown and stockpile areas.
In addition, any discharges associated with commissioning of pipes must be approved via the standard SA
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Aspects
Tick where
relevant
Water planned discharge approvals process.
Alternatives & Mitigation Measures

Use of trenchless technology/direction drilling for the crossing of the Hindmarsh River (consider
management of entry and entry pits and drilling waste)

Once detailed design developed, consider requirements for Water Affecting Permits / earthworks
drainage

Groundwater dewatering management plan will be required to be developed for the works by the
contractor to specify how groundwater will be managed if encountered during the works.

Ensure stockpiles are not placed within drainage lines

Control contaminated runoff from site works (during construction and for WWTPs operation)

Ensure roads are free from mud etc during works

Incorporation of Water Sensitive Urban Design (WSUD) opportunities in design of pump stations
including minimising amount of impervious material at sites.

Refer also to Section 6 for further construction controls.
1.3.2 Air Quality
Aspects
Tick where
relevant
Potential for construction emissions and associated impacts (dust, odours, other emissions or
particulates (vehicles, noxious/toxic gases)) - Consider proximity to sensitive receptors, working or
connecting to ‘live’ wastewater infrastructure?)
☒
Operational emissions (eg odour, other (eg chlorine?) - consider proximity to sensitive receptors)
☐
Monitoring required (pre/during/post)
☐
Other (specify)
☐
Summary of assessment and potential impacts
Potential for dust generation during excavation works associated with both the pump station sites and
pipeline as well as with stockpile sites.
The use of plant and machinery associated with the construction works also can generate nuisance
emissions if not managed appropriately.
The project will involve the construction of a number of wastewater pump stations, potential odour
emissions from these locations should be considered with respect to the proximity to sensitive land uses
(now and associated with planned future development).
Alternatives & Mitigation Measures
Design phase
Potential odour risks from the network / pump stations sites should be considered during design
development and mitigation strategies to minimise impact on surrounding sensitive receptors incorporated
where relevant. Pumping stations in particular should consider if odour control facilities are required and
requirements for mitigation measures (educts (and their location), filters or dosing).
Construction phase measures
 Refer to Section 6 ‘Air Quality’ for mitigation measures.
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1.3.3 Site Contamination
Aspects
Tick where
relevant
Current / past land use (or surrounding landuse) includes potentially contaminating activities or area
known to be contaminated site – soil or groundwater (specify below)
☒
Project involves land acquisition or disposal?
☒
Site history or environmental site assessment required / being undertaken (specify below)
☐
Existing onsite contaminated or hazardous materials to be managed (asbestos, contaminated
stockpiles)
☐
Disposal of waste and chemical substances required as part of project
☐
Risk of migration of contaminants from or to neighbouring land especially during works – or risk that
works could result in migration of contaminants (eg by altering groundwater movements)
☐
Acid sulphate soil risk
☐
Other (specify)
☐
Summary of assessment and potential impacts
A review of SA Water’s Aquamap layer did not identify any sites that are potentially contaminated based on
known records. No soil testing or has been undertaken along the alignment.
Given the agricultural history of the area there may be some pockets of contamination within the project
alignment. It is also noted that within the Hickenbotham land in the ‘gully’ there were areas that have from
the site inspection were identified as having previously been used for illegal dumping. A range of materials,
drums, car parts were noted in the gully. Potential contamination and waste management in these areas
will need to be considered if the works interact with the gully at this location.
The Contractor should include measures in their EMP should contamination be uncovered as part of the
works.
No significant PASS or ASS risks identified and a review of high level geotechnical work did not indicate any
soil material that would present PASS risk. However as the works will involve waterway crossing there is
some potential that PASS material could be uncovered.
Alternatives & Mitigation Measures


Refer to Section 6 for measures should unexpected or suspected contamination be uncovered.
Contractor to ensure any contamination managed in accordance with EPA requirements for testing,
handling and disposal.
1.3.4 Waste and Resource Use
Aspects
Tick where
relevant
Project will generate waste requiring management, transport and disposal (construction demolition
waste, rock/spoil etc).
☒
Increase or change to waste management (during construction and/or operation) eg generation of new
waste
☐
Significant use of materials or resource use (including new resource – groundwater extraction)
☐
Use or opportunity to use recycled materials or recycling of generated materials (cut & fill balances,
pavement recycling, concrete recycling)
☒
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Aspects
Tick where
relevant
☐
Other (specify)
Summary of assessment and potential impacts
Construction of the project will result in the generation of general construction wastes including cleared
vegetation, excess spoil from excavations and packaging and material offcuts. Other waste streams will
include demolition waste, waste hydrocarbons, garbage and concrete wash down waste.
Construction waste will need to be managed under the Environment Protection (Waste to Resources) Policy
2010, which aims to achieve sustainable waste management by applying the waste management hierarchy
consistently with the principles of ecologically sustainable development set out in section 10 of the
Environment Protection Act 1993.
All excess fill material and waste from excavations (that cannot be recycled) should be disposed of
appropriately at an appropriately licensed waste management facility with all receipts retained.
Any soil removed from site should be tested in accordance with EPA requirements before being disposed of.
Alternatives & Mitigation Measures

Waste management hierarchy to be followed.

Maximise the re-cycling and reuse of construction/demolition and waste materials – pavements,
concrete etc

Reusing excavated material from the project – balance cut to fill (where material is suitable to do
so)

Implement waste management practices during construction to reduce waste to landfill, eg reduce
cutoffs, waste segregation and collection etc.

Consider whole of life and life cycle costing of materials during design

Refer to Section 6 for further controls.
1.4 Social Environment
1.4.1 Noise and Vibration
Aspects
Tick where
relevant
Noise sensitive land uses/receptors potentially affected or close by
☒
Potential change in ongoing or operational noise levels (new or altered noise source eg new PRV,
pumps, change to traffic movements around an SA Water facility) (if tick undertake noise assessment
including pre monitoring and model anticipated changes)
☒
Construction noise impacts – from works themselves and/or from access to site (consider traffic routes
and traffic management relating to noise).
☒
Vibration – potential for impacts to heritage sites/objects/sensitive properties (dilapidation surveys)
☐
Other (specify)
☐
Summary of assessment and potential impacts
The project will involve a range of construction activities that will generate noise as part of the project.
Such noise sources include construction vehicle movements and activities (ie , light vehicles, dump trucks,
excavators), generators, pumps, delivery of materials and general traffic. These impacts will be temporary
associated with the construction phase of the works and are unlikely to be significant provided controls are
in place.
The project involves the construction of 4 new WWPS which will generate noise as part of the operation of
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Aspects
Tick where
relevant
the pumps, motors, generators and ventilation equipment installed in the new pump stations. As such,
these WWPS will potentially be introducing additional operational noise and have the potential to impact
on surrounding sensitive receptors. It should be noted that whilst some of the project area is currently
undeveloped (eg Hickenbotham land) there is still the requirement that noise complies with the EPA noise
requirements.
Acoustics treatment shall be provided, where it is necessary to mitigate any noise from the WWTP and
ensure achievement of EPA requirements.
Alternatives & Mitigation Measures
Design

The WWPS must be designed to meet compliance with the requirements of the Environment
Protection(Noise) Policy as a minimum

The selection of M&E equipment must consider noise for all supplied equipment and ability to
achieve noise requirements.
Acoustics treatment shall be provided, to mitigate the impacts during operation including of pumps,
motors, generators and ventilation equipment installed in the new pump station.
Design to also consideration will be given to the interaction of noise and vibration, and the best
installation methods to reduce impacts from these phenomena.
Noise monitoring should be undertaken to assess compliance with and achievement of noise
following development. Consideration of background noise levels through undertaking initial
survey.



Construction

Construction activities should be in accordance with the EPA Construction Noise Information Sheet
(EPA 425/10).

Refer to “Noise and Vibration” mitigation measures in Section 6 of this document.
1.4.2 Night Works
Aspects
Tick where
relevant
Night works required during project
☐
Works in close proximity to residents etc potential for impact
☐
Potential for light spill and associated nuisance
☐
Other (specify)
☐
Summary of assessment and potential impacts
Night works not identified at time of assessment.
Alternatives & Mitigation Measures
If night works are likely to be required a specific nightworks management plan to be developed that
includes aspects such as:

Limiting the duration range of activities during night works, limit noise generating especially
between hours of 10pm and 6am.

Consider placement of noise generating equipment, lights etc to minimise impacts on residences
etc
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1.4.3 Community and Land use
Aspects
Tick where
relevant
Change in land use following project (permanent)
☒
Temporary change in access or use of area during works (eg reduced access to recreational areas,
parklands, closure of park; consider timing of works – impact on community events?)
☐
Land acquisition required
☒
Opportunity for new / improved community spaces/facilities as part of project / post project
☐
Sensitive land use or use with critical needs potentially impacted (schools, child care centres, age care,
hospitals etc)
☐
Traffic disruption/delays
☒
Security/privacy – (eg security projects or upgrades - camera angles, new fences etc)
☐
Other community concerns (specify)
☐
Summary of assessment and potential impacts
Land acquisition will be required for the project associated with easements/new WWTPs sites. To minimise
impacts associated with this the preferred pipeline alignment has sought to minimise requirements for
easements by largely following road reserves were possible. The new pump station adjacent to the Aquatic
Centre is to be located on a site identified and provided by the Aquatic Centre developers. SA Water has
been negotiating with Hickenbotham to determine their preferred pipeline route and pump station location
within their development area to ensure that the locations are acceptable.
There will be some short terms impacts associated with construction and potential traffic delays. This will
be short terms and impacts minimised though having in place traffic management where required. In
addition the pipeline crossing of Adelaide Road is likely to be directional drillingto minimise impacts on road
users.
The overall outcomes of the project will facilitate the development and growth within the Victor Harbor
township, as well as facilitate the development of the new Aquatic Centre and well being centre though the
provision of critical wastewater services. As such it is considered that it will have overall benefits for the
local community.
Alternatives & Mitigation Measures
SA Water has been negotiating with Hickenbotham and the developers of the Aquatic Centre to determine
their preferred pipeline route and pump station location within their development area to ensure that the
locations are acceptable.
A Stakeholder Engagement plan has been developed by SA Water’s Stakeholder engagement team and this
will be implemented for the project to ensure local community is aware of the project and potential impacts
and mitigation measures.
Landscaping opportunities for the new WWTPs sites will be developed as part of detailed design.
1.4.4 Access
Aspects
Tick where
relevant
Access to project area already established – no change required
☐
New access required (track/road/access point etc)
☒
Severance of access (permanent or temporary during works) to properties (including residential,
community, business/commercial)
☐
Traffic interruption /delays (permanent or temporary)
☒
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Aspects
Tick where
relevant
Travel patterns altered, road closure/detours (pedestrian and vehicles)
☒
Parking impacts
☐
Other (specify)
☐
Summary of assessment and potential impacts
Some temporary impacts on traffic movements and short term access to properties may occur during the construction
phase of the project. This will be temporary and affected people will be consulted as part of the Stakeholder
engagement for the project.
Alternatives & Mitigation Measures

Traffic management plan for works

Discussion mitigation measures/alternatives with Stakeholder Group
1.4.5 Amenity
Aspects
Tick where
relevant
Impacts on view or view scapes
☐
Structures/built form visually intrusive or change to current
☒
Urban design considerations for new structures – including risk of graffiti/crime prevention etc
☒
Impacts on open space, reserves, parks, marine park (specific below)
☐
Improved amenity opportunities (landscaping, improved water quality, improved open space etc).
☒
Light spill (construction or operation)
☐
Other (specify)
☐
Summary of assessment and potential impacts
The project involves the construction of new wastewater pumping stations. The pipeline will be
underground and as such will not impact on visual amenity post some initial disturbance during
construction.
To minimise impacts associated with the WWPS and ensure they are acceptable SA Water has been in
negotiations on the location of this infrastructure with the Developers/current owners.
In addition the sites where appropriate landscaping at the sites will be undertaken.
Alternatives & Mitigation Measures
Design phase to consider

Built form and design principles (crime prevention / graffiti etc principles)

Landscaping and amenity screening as required, WSUD, contribution to liveability
1.4.6 Heritage (European)
Aspect
Tick where
relevant
National or State Heritage site(s) potential impacted by works
☐
Local heritage sites (on Local Government Development Plan) potential impacted by works
☐
Indirect/non-structural aspects of heritage items impacted (e.g. colour scheme, aesthetic impacts)
☐
Potential vibration impacts (risk of cracking or impacts to structural integrity) from works (esp rock
☐
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Aspect
Tick where
relevant
breaking etc)
Geological Heritage
☐
Other (specify – marine heritage etc)
☐
Summary of assessment and potential impacts
None identified, to be confirmed as part of final detailed design.
Alternatives & Mitigation Measures
1.4.7 Aboriginal Heritage
Aspects
Tick where
relevant
Works on or within existing structure/building (or no excavation) – low risk of encountering heritage
☐
Aboriginal heritage (AAR- DSD) Register search completed
☒
Aboriginal Heritage risk assessment completed
☒
Other (specify)
☐
Summary of assessment and potential impacts
An initial risk assessment/desktop analysis of the pipeline options was undertaken to inform initial planning
and further investigation requirements this included including a search of the Central Archive. The risk
assessment included a desktop analysis and initial site walkover (of accessible sections). The initial analysis
sought to identify areas of risk and provide initial suggested mitigation strategies associated with each
option/alignment.
From the outcomes of the desktop analysis of the proposed alignments, Option 1 was assessed as the
lowest risk alignment of the three and on this basis would be the preferred alignment .This is largely based
on the disturbance history of the surface and sub-surface. Options 2 and 3 were considered to pose a higher
risk as they impact relative undisturbed surfaces and both intersect drainage lines. No previously recorded
sites as per the Central Archive were identified for any of the options.
The common alignment, particularly the section that runs through relatively undisturbed areas within
Hickenbotham land and parallel with the Hindmarsh River was considered to present the greatest risk area.
SA Water is seeking to engage with Ngarrindjeri on the project to provide a better understanding of risks
and requirements associated with protection and management of Aboriginal Heritage as part of the project.
Alternatives & Mitigation Measures
Design
SA Water to engage with the Ngarrindjeri Heritage Committee to identify any project requirements for the protection
and management of Aboriginal Heritage that may
Construction

Construction to incorporate outcomes of engagement with Ngarrindjeri, this may include presence of
Heritage monitors during excavation works.

All construction /site personnel to be inducted into the SA Water’s Standard Operating Procedure for
Discovery of Aboriginal Heritage to be followed in event of heritage discovery. SOP to be on site at all times

SA Water’s Standard Operating Procedure for Discovery of Aboriginal Heritage to be followed in event of
heritage discovery.
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1.4.8 Native Title
Aspects
Tick where
relevant
Native Title to be considered - advice from the Crown Solicitors Office (through Corporate Council) to
determine whether Native Title exists over land within the project area
☐
ILUA process applicable in works area?
☐
Notification Process undertaken if native title not extinguished or ILUA triggered?
☐
Other (specify)
Summary of assessment and potential impacts
Native Title Requirements to be examined and confirmed as part of further project development and detailed design.
Alternatives & Mitigation Measures
1.4.9 EPA Licenced site
Aspects
Tick where
relevant
Project on an site covered by EPA licenced (wastewater treatment plants, desalination plant etc
☐
Project involves changes to emissions to water or air (eg odour) – changes could include an increase in
volume, change in quality, change in timing, different discharge point. Consider if temporary or
permanent. ( EPA notification required.)
☐
Other (specify)
☐
Summary of assessment and potential impacts
The works will end at the Victor Harbor WWTP operated by Trility. Trilly to advise of any specific requirements
Alternatives & Mitigation Measures
N/A
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Part B: Project Environment Management Plan
1
Objectives of the Environmental Management Plan
The general objectives of this Environmental Management Plan are to:
 Ensure that potential environmental or heritage risks associated with common construction
activities are being considered as part of the planning and delivery of SA Water’s works
 Ensure that control measures are in place to minimise potential risks and impacts
 Achieve the project objectives in relation environment and heritage management
 Ensure the works are undertaken in accordance with our customer’s expectations
 Continually improve project/site practices for the mitigation and management of impacts
 Establish clear responsibilities for environmental and heritage management as part of the works
 Ensure compliance with all statutory and regulatory requirements.
2
Key Assessment Outcomes
The project and associated works include a number of activities that have the potential to cause
impacts to the environment and/or heritage. As this project is being delivered through an ECI there are
a number of potential impacts that can be mitigated and should be considered during further design
development.
The ECI contractor should ensure that the outcomes and recommendations including mitigation
measures identified in this report are adhered to and considered during the design development for
the project. Key outcomes and requirements are highlighted below, further details are provided in Part
A and Section 6:
Flora and Fauna
 Design for pipeline alignments to minimise impacts to vegetation, particularly roadside
vegetation and identified sensitive areas. Impacts to native vegetation will require assessment
and approval in accordance with SA Water’s Native Vegetation Standard Operating Procedure.
This will require further field base vegetation assessments.
 Pipeline alignments should avoid or minimise requiring excavations that would encroach on the
tree protection zone of established trees (particularly scattered trees). An arborist assessment
should be undertaken to inform requirements where works are within the vicinity of trees.
Water and Water Quality
 Design development to consider potential requirements for dewatering during works
 Crossing of the Hindmarsh River to be via boring/direction drill, should this approach change
potential impacts and approval requirements will need to be re assessed
Air Quality
 Potential odour risks from the network/pump stations sites should be considered during design
and mitigation requirements identified and incorporated as necessary.
Noise
 Design for the wastewater pump stations must ensure compliance with EPA Noise Policy
requirements as a minimum.
Aboriginal Heritage
 Further consultation with the Ngarrindjeri Regional Authority to occur to inform project
development and requirements.
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Amenity
 Amenity aspects of new infrastructure (WWTPs) should be considered during design
development. This should include built form to minimise impacts, as well as landscaping
requirements and opportunities.
Environment / heritage controls for during construction phase are further outlined in Section 6, these will
be reviewed and refined following development of concept and detailed designs.
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3
Legal and other requirements
A key governing legal requirement for all projects is set out in the SA Environment Protection Act 1993,
Section 25:
A person must not undertake an activity that pollutes, or might pollute, the environment unless the
person takes all reasonable and practicable measures to prevent or minimise any resulting environmental
harm.
A summary of the environment and heritage approval / permits associated with the project is provided
below, with the status and where relevant, conditions, for each.
Act
Environment
Protection and
Biodiversity
Conservation Act
2000 (Cth)
Description
Approval from the Commonwealth
Environment Minister is required for
actions that have or are likely to have a
significant impact on matters of national
environmental significance (MNES).
Tick if
relevant to
project
☐
Status/Assessment
outcome/ comments
Summary of approval/
assessment conditions (if
relevant)
Based on desktop
assessments no MNES will be
impacted by the works and
therefore the project has
been assessed as not
requiring referral under the
EPBC Act.
If project triggers above, referral under
EPBC Act required.
Development Act
1993
Works that constitute Development
require approval. Development includes
(not limited to):




Heritage
Act/Development
Act
Environmental
Protection Act
1993
(Section 36 –
Requirement for
licence)
Environmental
Protection Act
1993
Licenced
facilities(eg
WWTP, desal
plants etc)
Native
Vegetation Act
1991
☒
Change of land use
Building works
Prescribed earthworks
Impacts to Significant/Regulated
Trees
Works that impact on State heritage
require development authorisation
Prescribed activities of Environmental
Significance require an EPA licence.
or
☐
☒
(eg dredging/earthworks
drainage/abrasive blasting, transport of
contaminated soil, sewage treatment,
desal, etc)
A condition of EPA licence is the
requirement that where there is a change
to process or emission, EPA should be
notified, may require formal process
change.
Approval for clearance of native
vegetation is required under the Act.
Native vegetation includes trees, shrubs,
groundcovers and grasses.
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Works for the pipeline are
exempt under Schedule 14 of
the Development
Regulations. The WWPS are
considered ‘local
infrastructure’ and also do
not require development
approval as per Schedule 14.
☐
☒
Document ID: TBD
Based on the concept
options it has been assumed
that directional drilling will
be used for the crossing of
the Hindmarsh River. On this
basis no dredging licence
would be required.
However earthworks
draining licence could be
required if earth works
drainage needs to occur.
Will not change any
processes at EPA licenced
facility.
Design development to
minimise impacts, approval
to be required once design
developed and extent of
impact known.
Approval will be required following
further design work and
confirmation of impacts. This will
include an offset / payment into the
NV Fund
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Act
Description
Aboriginal
Heritage Act
1988
Authorisation from the Minister for
Aboriginal Affairs is required to interfere,
damage or disturb Aboriginal heritage
sites, objects or remains.
Natural
Resources
Management Act
2004
Works in creek beds and floodplains
and/or discharges of water may require a
Water Affecting Activities Permit or
approval under SA Water’s BPOP
Tick if
relevant to
project
☒
☒
(Section 127—
Water affecting
activities)
Natural
Resources
Management Act
2004
Status/Assessment
outcome/ comments
Further engagement with
NRA to occur as part of
project development
Summary of approval/
assessment conditions (if
relevant)
All Aboriginal sites and objects
protected under the Aboriginal
Heritage Act 1988. In event of
discovery, stop work follow SA
Water’s Standard Operating
Procedure for Aboriginal Heritage
Discovery
Based on the concept
options it has been assumed
that directional drilling will
be used for the crossing of
the Hindmarsh River. On this
basis a WAAP is not required
Any discharges associated
with commissioning require
a discharge approval from
Environment and Heritage
Services.
None identified in project
area based on assessments
to date.
Consultation with NRM Board is required
if transporting plants declared under Part
175 of NRM Act
☐
Notice to be issued if works Native Title.
Note: ILUA notification process may be
applicable in some areas.
☒
Native title advice sought
from CSO
Permit required under if works within a
National Park, Marine Park
☒
There are no National Parks
and Wildlife Act Reserves
within the vicinity of the
project area.
(specify)
☐
(Section 175—
transporting
declared plants)
Native Title Act
1993
National Parks
and Wildlife Act
1972
Marine Parks Act
2007
Other
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4
Environmental Management System and Structure
4.1 Environmental system requirements
As a minimum, the contractor should have in place systems and methods for ensuring that the
environmental requirements identified in this document are implemented. Normally this would be through
the development a site specific or project specific Environmental Management Plan for the works.
4.2 Inductions and Training
All project staff, including subcontractors, must be inducted to the requirements of the project
Environment Management Plan and associated procedures. The induction should ensure that any site
specific environmental controls and/or requirements associated with Aboriginal Heritage are
communicated to staff prior to the commencement of on-site works.
A record of inductions must be maintained.
4.3 Records and record keeping
Relevant schedules and records should be retained on site during the construction phase of the project. As
a minimum this should include
 Environmental Management Plan
 Prestart inspection checklists
 Induction / Training registers
 Monitoring/inspection reports and audit reports
 Non conformance reports
 Environmental incident reports/register
 Waste tracking and disposal records
 Listed/controlled waste transport certificates and volumes
 Complaints registers
4.4 Roles and Responsibilities
4.4.1 Project Manager
The nominated SA Water Project Manager is responsible for:
 Ensuring that Contractors/SA Water works crew are provided with and made aware of the
contents and requirements of this EMP
 Monitoring the effectiveness of implementation of this plan
 Being a point of communication with SA Water’s Environment and Heritage Services Team
4.4.2 Site Supervisor/ Site Manager
The Contractor’s/SA Water site manager (or nominated onsite environmental representate) is responsible
for:
 Implementing the control measures in this document such as establishing site controls
 Inducting site personnel into the requirements of the EMP
 Undertake regular site inspections and monitoring the effectiveness of onsite controls, instigating
improvements where necessary
 Maintaining site records such as site inspections/monitoring reports, induction records, NCRs or
incident reports
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Liaising with the Project Manager where environmental issues or concerns are raised that require
further attention
Enforcing work practices that minimise adverse environmental impacts through due diligence
Ensuring all employees report any environmental risks or hazards
Implementing additional mitigation measures in the event of non-conformances or emergencies
4.4.3 Employees, sub-contractors and Labour hire personnel
All employees (including subcontractors) have an obligation to protect the environment when carrying out
their work this includes:
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Being aware of the contents of the EMP including general environmental statutory requirements to
carry out their work with due diligence.
Complying with instructions/directions given by the Site Supervisor
Report any incident that may result in environmental harm that arises in the course of or in
connection to their work.
4.5 Inspections and Monitoring of Environmental Performance
Inspections of the work area should be carried out by the Site Supervisor to ensure the environmental
management controls are effective. Monitoring of the environmental controls should consider the
performance indicators each of the environmental issues provided in Section 4.
Issues arising from site inspections should be addressed as soon as possible, in some cases nonconformance reports may be raised. Issues identified should also be discussed at toolbox or site meetings
together with any improvement measures that have been implemented.
Monitoring records should be retained by the Site Supervisor. A suggested typical monitoring schedule is
outlined below:
Frequency
Prior to works
Daily
Before/during rainfall
events
Weekly/monthly
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Issues
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Compound/worksite controls are in place, locations for
materials/stockpiles and access identified
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Location of sensitive neighbours

Location of stormwater entry points, drainage lines, water courses
identified

Location of spill control measures and spill kits available

Site is neat and tidy

Waste contained appropriately

Chemicals and materials stored appropriately

No evidence of dust nuisance

No evidence of water contamination/runoff form site

Adjacent roads clean (not covered in sediment etc).

Runoff controls in place and maintained

Protection of stormwater entry points

Adjacent roads clean (not covered in sediment etc).

Drainage lines clear of debris

Overall environmental management measures as per EMP in place.
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4.5.1 Audits and Inspections
During the construction phase of the project Environmental Services (in conjunction with the Project
Manager) may undertake inspections/audits of the contractor to ensure compliance with the requirements
of the project environmental controls.
4.5.2 Non -conformance and corrective actions
A process for handling non-conformances should be in place. As a minimum requirement this should
include procedures for the identification and reporting of any non-conformances with the project
documentation, including the EMP.
If inspections/monitoring/auditing activities identify an environmental non-conformance the following
actions should be undertaken:
 Inspect/Review the non-conformance, where necessary stop/control the activity until the
environmental non-conformance is addressed
 Reporting of the non-conformance by the contractor to SA Water’s project manager
 Investigate the reasons for the non-conformance and
 Implement appropriate action to address the non-conformance, amend project EMP/Project plans
as necessary
 Record details of the non-conformances
5
Emergency Response and Environmental Incidents
5.1 Emergency Planning, Preparedness and Response
Emergency response and incident procedures should be in place for the project, these procedures should
provide an effective response whilst minimising environmental harm or disruption (refer EMS_70
Environmental Emergency Response Plans).
The Emergency Response Procedure should be available and on display at the worksite/site office and all
personnel must be inducted into its requirements. The procedure should include key contact details
Also included on the contact list should be the details of: (1) a person(s) for emergencies that will be
available 24 hours a day, seven days a week, and has the authority to stop or direct works (2) emergency
response personnel (3) the SA Water Project Manager (4) local councils and the local hospital(s) and (5) if
necessary, nearby residents
In the event of an emergency the emergency response procedure should be enacted. Post the event a
review should be undertaken to evaluate the effectiveness of the response against the procedure and
determine if any amendments are considered appropriate.
Contact
Contact details
SA Water Project Manager
Tony Lennon
SA Water Environment Impact Assessment Officer
Tara Hage
Police, Fire and Ambulance
000
Country Fire Service (CFS)
1300 362 361
Metropolitan Fire Service (MFS)
(08) 8204 3600
SafeWork SA
1300 365 255 / 1800 777 209 (for serious incidents/ injuries)
Environment Protection Authority (EPA)
(08) 8204 2004 / 1800 623 445
RSPCA (Head Office, Adelaide)
(08) 8231 6931
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Contact
Contact details
National Parks and Wildlife South Australia
(08) 8204 1910
5.2 Environmental Incident Management
In the event of an incident action should be taken to stop/modify the work to effectively minimise impacts
to the environment. Where an environmental incident occurs that causes or threatens to cause serious or
material environmental harm (breach of legislative requirements, widespread impact etc) then as per
Section 82 of the Environment Protection Act the EPA should be notified.
Incidents may include: main burst/flooding events, sewer spills, chemical or fuel spills, discharge if
contaminated water, unauthorised/unintended impacts to vegetation etc.
Any environmental incidents should be investigated and reported to the SA Water’s Project Manager as
soon as practicable or no later than 24 hours after the incident is identified. Reports should include details
of the incident and any corrective actions taken.
A record of all incidents should be maintained (refer EMS 82 Environmental Incident Reporting).
In the case of an environmental emergency the Emergency Response Procedure/Plan should be followed.
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Environmental Management Controls
The following pages include suggested control measures to be used during the works to mitigate environmental impacts. The effectiveness of the controls should
be monitored as per Section 4.
Environmental Impact
Water Quality Impacts / Pollution of Water
Objective
Prevent or minimise adverse effects on surface water and groundwater quality, flows and drainage
Performance indicators


Controls
No deterioration on receiving waterway quality including for pH, turbidity, dissolved oxygen, chlorine residual and visual oils and greases.
Construction materials and sediment laden runoff prevented from entering waterbodies/stormwater
Pre Construction
 Review construction area to minimise potential for surface runoff to enter the site and to identify controls for runoff leaving the site
 Identify water bodies/drainage lines (including stormwater side entry pits) and identify sediment /erosion control requirements eg silt fences
around stockpiles, silt sock locations at stormwater entry pits etc.
 Review project activities that will require protection and installation of controls
 Identify designated stockpile/laydown areas away from drainage lines.
 Schedule works that will occur in watercourses /drainage lines for periods of favourable weather (eg dry periods) or implement construct
techniques that reduce construction footprint (eg directional drilling)
Construction
 No discharge to a watercourse (including stormwater system) without approval from Environmental Services
 Install erosion and sediment control devices prior to works commencing (silt fences, silt socks, hay bales diversion drains, geotextile fabric) and
ensure maintained (eg remove debris from sediment control items regularly)
 Ensure stockpiles have erosion control devices installed, particularly on downslope of stockpiles
 Monitor weather forecasts to identify rain events and ensure control measures in place
 Inspect and maintain/clean sediment control items regularly
 Clearly define access tracks and routes and use these
 Use a street sweeper or similar to clean sediment/debris form public roads
 Compact, backfill and resurface disturbed or unsealed areas as soon as possible
 No onsite refuelling, service or maintenance or cleaning in areas where runoff/wastewater may enter stormwater system or waterbodies.
 All equipment washdown to be undertaken within an identified washdown area, no discharge of washdown water to stormwater or watercourse.
 Turbid water from concrete cutting etc not to be directed to stormwater or watercourses.
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Environmental Impact
Damage to Vegetation
Objective
Protect and minimise impacts to vegetation as part of the works
 No unauthorised clearance
 Protection in place (bunting, marking off) for vegetation on site where appropriate
Performance indicators
Controls
SA Water
Design and Pre construction

 Identify vegetation in/adjacent to the works area that may be impacted and plan access routes, plant/vehicle parking, stockpiles and material
storage locations away from vegetation
 Plan works to avoid in first instance or minimise impacts to vegetation (Significant/Regulated trees or Native Vegetation)
 Seek approval for any impacts to Sig/Reg trees or native vegetation clearance prior to works
Construction
 No clearing of native vegetation (unless approved or covered by maintenance/operational exemption as per SA Water’s Native Veg SOP )
 Utilise existing access tracks/roads where available or ensure access via previously disturbed cleared areas.
 Park vehicles and store equipment or stockpiles (including soil) in areas that are designated/pre-marked as laydown areas or already cleared (e.g.
tracks) to avoid smothering or damaging native vegetation.
 Avoid impacts to roots (10m from drip line optimal) wherever possible. If roots (≥ 50mm) are discovered during the works these are to be bridged
where possible. Roots discovered <50mm which are broken are to be clean cut with a saw.
 Where working in roadside areas care shall be taken not to impact in areas where Department of Planning, Transport and Infrastructure or district
council based ‘Roadside Significant Markers’ are present. These identify that a section of roadside reserve contains a significant feature such as
rare flora, matters of cultural heritage or significant native vegetation. Contact Environmental Services for details if working in these areas.
Environmental Impact
Objectives
Performance indicator
Controls
Introduction of weeds and pathogens
 Pest plants / pathogens not introduced into worksite or spread as result of works
 No movement of declared plants in a uncontrolled manner.
 No new incursions of declared plants or plant pathogens post construction
 Weed and hygiene measures in place
Preconstruction
 Ensure any declared plants within work area are identified
 Ensure plant and machinery washed down prior to entry to work zone.
Construction
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Ensure imported material is ‘weed free’ by applying a risk based approach, material is considered weed/pest free if:
o Quarry material is sourced at depth and is not stockpiled/surface material.
o classified as standard TS-4.
o Sourced from a licenced quarry (and/or quarry site inspected by the local NRM Board with records to confirm appropriate weed
management strategy is in place that minimises the risk of weed contamination of material taken from that site).
o If quarry material is considered top soil, inspection by suitably qualified person is required to ensure fill is weed/pest free.
Locate stockpiles away from weed infested areas where possible
Appropriate washdown of machinery if sourced from weed or disease risk areas or have carried imported material.
All equipment washdown to be undertaken within an identified washdown area and water contained within that area (no discharge of washdown
water to stormwater or watercourse).
Environmental Impact
Fauna
Objective
Prevent or minimise disturbance to native fauna and their habitat.
Performance Indicator
Controls

SA Water
Fauna within works area not adversely impacted
Pre-construction
 Ensure contact list for local/regional fauna rescue organisation available
Construction
 Any injury or death of native wildlife caused by the construction activity will be reported to the SA Water Environment Officer
 If tree hollows are present and trees require pruning/ clearing, these must be checked for fauna before removal
 If any fauna is found, the SA Water Site Representative will report the details of discovered fauna to the SA Water Environment and Heritage Services
Team for relocation if required.
 Where native fauna is likely to be present within works area minimise risk of entrapment (eg close trenches overnight)
Environmental Impact
Stockpile, Erosion and Stormwater Management
Objective
Minimise the potential for environmental impacts associated with poor stockpile management.
 No sediment laden runoff leaving works area
 No dust from stockpiles leaving site and impacting sensitive land uses (residents/schools, sensitive habitats)
 Management of contaminated spoil in accordance with EPA requirements
Performance indicator
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Controls
SA Water
Preconstruction
 Identify designated stockpile/laydown areas away from drainage lines, drip lines of trees/vegetated areas
 Identify potential soil contamination that may require management and ensure appropriate areas for stockpiling established
Construction
 Follow requirements of the SA EPA Guideline for stockpile management including:
o Materials with a potential to produce leachate and contaminated runoff should be stored in a sealed and bunded area.
o Limit stockpile height
o Materials must be stored away from surface watercourses, flood zones and groundwater recharge areas to prevent environmental harm to
water.
 Locate designates fill stockpiles away from vegetation and drainage lines.
 No stockpiling within the drip lines of trees to minimise compaction of the root zones.
 Maintain separate stockpiles for different materials
 Remove excess spoil from the site and dispose of in accordance with EPA requirements including at EPA licenced landfill or other appropriate location
as approved by SA Water’s Environment Officer.
 Install erosion control measures such as silt fences, hay bales, sedimentation sumps, sand bags, geotextile fabric, diversion drains or other appropriate
measures on the down slope side of stockpiles.
Environmental Impact
Air Quality (Dust, emissions, odours )
Objective:
Ensure that particulate and gaseous emissions do not cause environmental nuisance or harm to surrounding community and environment.
 No community complaints during construction regarding air quality (dust, odours)
 No impact to adjacent sensitive land uses (eg houses, schools)
 Results from visual inspections show no visible dust leaving boundaries of construction site
Performance indicator
Controls
Preconstruction
 Identify site access, laydown areas and stockpile locations
 Identify sensitive receivers and dust monitoring requirements.
Construction
 Restrict high risk activities during extreme weather events (strong winds, hot dry weather) to dry/calm conditions if required to limit dust
generation.
 Water cart available to control dust if required.
 Minimising the extent of exposed and stripped surface areas within the project area
 Ensure construction facilities are designed and operated to prevent the emission of smoke, dust, cement dust and other potentially deleterious
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SA Water
matter into the atmosphere.
Maintenance of vehicles and equipment.
Reduce idling time of vehicles and plant.
Reduce vehicle speeds on dirt roads to reduce dust emissions.
Cover loads if dust is an issue.
Stockpiles to be managed to reduce dust (manage height, covering wetting as required)
Undertake inspections of dust/ emissions controls and activities and respond accordingly
Environmental Impact
Noise and Vibration impacts
Objective:
To ensure noise and/or vibration from construction does not cause an environmental nuisance or adversely impact amenity/ people or result in
damage to property.
 No complaints related to noise or vibration
 No property damage resulting from vibration
Performance Indicator
Controls
Preconstruction
 Plan timing of noisy activities to avoid impacts on nearby residents
 Select good plant and equipment that generates low noise and vibration
 Consult with stakeholders (though SA Water) in advance of works
 Ensure machinery has appropriate mufflers, silencers and/or enclosures fitted
 Investigate alternative processes/methods that will reduce noise and vibration
Construction
 Construction activities should be in accordance with the EPA Construction Noise Information Sheet (EPA 425/10).
o Normal hours of work should be between 7am and 7pm, Monday to Saturday
o Work outside these times may be permitted to avoid impacts such as unreasonable interruption of vehicle or pedestrian traffic movement,
Environmental Services should be advised in such cases.
 Notify nearby residents/landowners if any project activities proposed outside of normal construction times (though SA Water)
 Use appropriate equipment for the task
 Regularly maintain plant and equipment used during construction (eg rotating parts to be balanced)
 Enclose, where practical, stationary constant noise sources such as air compressors, generators etc to reduce noise levels
 Maximise the distance between vibration sources and receivers if possible
 Maintain complaints register and respond to complaints received
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Environmental Impact
Storage and Handling of Hazardous Substances
Objective
Manage the storage of hazardous substances to avoid contamination of surrounding soils and water.
 Hazardous substances stored appropriately and spill kits on site.
 No impact to soil/groundwater associated with storage use of hazardous substances.
Performance Indicators
Controls
SA Water
Preconstruction
 Plan for sufficient plant and equipment to ensure minimal maintenance and refuelling required on site
 Identify areas for storage, refuelling and spill kits.
 Establish bunded area and/or where appropriate lockable bunded container in compound for storage
Construction
 Hydrocarbon spill kit available and personnel trained in the efficient use spill kits readily available.
 Minimise quantities of hazardous substances, fuels and lubricants stored on site. Store and handle chemicals/hydrocarbons as per the product
MSDS. MSDS to be available at all times for hazardous substances that are used or stored.
 Storage and management requirements for hazardous substances in accordance with legislative guidelines including bunding, impervious floor and
in a location not subject to flooding and within a pre-marked laydown area.
 All waste oil to be collected and disposed of at an EPA Licensed Recycling Depot.
 Ensure no discharge of hazardous substances or fuels/lubricants into water courses or storm water.
 The decanting, mixing, applying, storing of chemicals including paint, or the refuelling of vehicles or equipment shall not be conducted within 50 m
of a watercourse or drainage channel.
 In the event of a minor spill (e.g. diesel), affected soil to be excavated and disposed of at an appropriately licenced landfill.
 In the event of a major fuel or chemical spill, immediately notify SA Water Site Representative of the spill and if known, any associated details (e.g.
Type of spill, source, time of incident).
Environmental Impact
Objective
Performance Indicator
Controls
Contamination
 Identify potential contamination issues on site.
 Manage such issues to protect employees, the public and the environment.
 No impact to soil/groundwater associated with contaminated material.
 No risk to employees from encountering and managing contaminated material.
Preconstruction
 Undertake assessment of risk of encountering contamination based on historical or surrounding land uses
Construction
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Heritage Impact
Objectives
Performance indicators
Controls
SA Water
In the case of unusual odours or visual observation being made during excavation that indicates soil/groundwater contamination work is to cease and
the SA Water Environmental officer contacted.
The discovery of contaminated soil and/or groundwater is to be immediately reported to the SA Water Site Representative so as the appropriate
authorities can be notified.
Contaminated material must be transported and disposed of in accordance with EPA requirements (licenced waste transporter and to EPA licenced
facility).
Waste transfer certificates retained for contaminated material and available on request.
If contaminated discovered: Isolate the suspected contaminated area.
o Separate any suspected soil/fill, store on impervious material (tarp/fortecon) and cover to prevent rain or wind mobilising material. Any
contaminated fill requires NATA Certified Laboratory Test Results and must be disposed to an EPA licensed landfill (contact Environmental
Heritage Services to arrange this)
o Groundwater contamination is required by law to be reported to the EPA.
o No disposal of contaminated groundwater to a stormwater or watercourse.
Aboriginal Heritage Management
 Prevent or minimise Disturbance to cultural heritage sites
 Ensure all statutory requirements are complied with and controls listed below are implemented to minimise potential disturbance to unknown
sites.

Management of any Aboriginal discoveries in accordance with SA Waters SOP for the discovery of Aboriginal Heritage (refer Appendix A)
Pre Construction
 For all works not limited to within building or on existing infrastructure, undertake an AAR register search to determine if known heritage sites within
the works area and complete heritage risk assessment
Construction
 SA Water’s procedure for the discovery Aboriginal Heritage must be available on site and all construction personnel inducted into this procedure.
 In the event of potential a potential heritage site or object being discovered during construction, works in the area must stop and the procedure for
the Discovery of Aboriginal Heritage followed (refer Appendix A)
Environment Impact
Objective
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Fire Management
 Ensure compliance with South Australian Country Fire Act 1989
 To ensure that construction activities do not cause and emergency incident such as starting a fire.
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No emergency incidents as a result of construction activities.
Performance indicator
Controls
Pre Construction
 Review fire danger season and schedule works to minimise risks associated with fire, where possible
 Conduct a risk assessment on days notified as total fire ban days before undertaking any works on site
 Have in place an emergency response plan for the works
Construction
 Fire extinguishers/on site fire fighting equipment to be available on site and in work vehicles, major plant and equipment and ensure workers trained
in their use
 Hot work permits required for ‘hot works’ on total fire ban days, no works on catastrophic fire rating days unless approved.
 Maintain all machinery and vehicles in good condition to minimise risk of fires
 Fit plant with spark arrestors
 No burning off or burning of wastes
Impact
Objective
Waste Management
 To ensure all statutory requirements are complied with relating to management of waste (including Waste to Resources Policy)
 Maximise reuse and recycling of materials

Compliance with waste management requirements
Performance indicators
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Controls
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Pre Construction
 Adopt the principles of the waste management hierarchy and plan/procure materials that :
o Avoid the production of waste
o Minimise the production of waste
o Maximise reuse and/or recycling of waste
o Recovery of energy or other resources from waste
o Treatment of waste
o Disposal of waste in environmentally sound manner
 Confirm the relevant statutory requirements for disposal of wastes from site
Construction
 Carry out works to minimise waste production
 Segregate wastes to maximise reuse/recycling  Provide and use sealed waste and recycling bins
 Dispose of waste materials, waste oils etc at EPA licence facilities
 Waste to be removed from site using appropriately licenced waste transporters
 No burning of wastes
Impact
Objective
Visual Amenity
 Prevent or minimise negative impacts from construction activities on the visual amenity of the local area.

No community complaints regarding visual amenity during the construction period or post project associated with site condition (eg demobilisation)
Performance indicators
Controls
Pre Construction
 Assessment of potential visual impacts and opportunities to mitigate or improve visual amenity (eg landscaping/screening).
 The establishment of site facilities or undertaking other activities which are likely to adversely affect the visual amenity of the surrounding area are
not permitted
Construction
 Implement waste and dust management controls
 Stockpiles, equipment and large plant to be located in areas of the project least likely to affect visual amenity (away from houses etc).
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Impact
Objective
SA Water
Ensure good housekeeping and waste management on site.
Traffic Management
 To minimise the impact to the public associated with the construction of this project

Minimise complaints from the public regarding traffic management
Performance indicators
Controls
Pre Construction
 Assess impacts on traffic flow, direction and timing as part of project.
 Assess traffic management requirements to ensure safety to site workers and community
 Develop traffic management plan for works
Construction
 Traffic management controls implemented as per traffic management plan
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Environment and Heritage Services – Environment and Heritage Assessment Report and Project
Environmental Management Plan (PEMP) Project:
Appendix A
SA Water
Aboriginal Heritage Discovery Procedure
Have you found a site, object or skeletal remains that may be Aboriginal Heritage?
 See example pictures on next page.
Do not disturb/remove/touch or displace the site, object or skeletal remains.


It is an offence to disturb or interfere with Aboriginal heritage or skeletal remains.
Restrict access. Site supervisor to take note of:
 Location in relation to site works (pref GPS).
Any immediate threats to heritage e.g. construction activities, vandalism, water level.
 Name and contact details of the person who made the discovery.

Site Supervisor to immediately notify:
 SA Water representative : ADD CONTACT
Local Police or 131 444. If suspected human remains have been discovered.
The SA Water EHS Team will appropriately manage the incident with appropriate guidance from:
 Local Police (where skeletal remains have been discovered).
 Aboriginal Affairs and Reconciliation .
 The local Aboriginal community.
 An Archaeologist may also be consulted.
The SA Water Project Manager will notify the contractor when works can resume.
 This decision will be made in partnership between the PM and EHS team.

 There may be conditions that need to be followed to allow work to resume.
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Environmental Management Plan (PEMP) Project:
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Example Pictures
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