FCAP Remediation Project Fact Sheet - April 2016

Former ChlorAlkali Plant Mercury Remediation Project
Community Fact Sheet
Updated April 2016
Orica is remediating mercury contaminated soil at the site of the Former ChlorAlkali Plant (FCAP) at the Botany Industrial
Park. Orica’s FCAP operations date back to 1944 and used mercury in the manufacture of chlorine, caustic soda and
hydrogen. These operations have resulted in the soil and groundwater at the FCAP Remediation Project Site being
contaminated with mercury. Orica no longer uses mercury at Botany.
The FCAP site, prior to the commencement of remediation works, is shown in the following figure. Block G is the main site
of the former operations, and is also the main location of mercury impact. A large building, known as the Temporary
Emissions Control Enclosure (or TECE) (see below) was constructed over Block G.
Remediation Approach
A Remediation Options Appraisal Report and
subsequent independent expert review identified onsite containment as the most appropriate
remediation option. Two Remediation Action Plans
(RAPs) have been prepared on this basis.
For Blocks A and M the remediation approach was
to excavate mercury contaminated materials,
validate the excavation surfaces against the
remediation criterion agreed with the NSW
Environment Protection Authority (EPA), and backfill
the excavations with soil that meets the same
remediation criterion.
Block G remediation involved the targeted removal
of mercury and mercury contaminated materials to
the extent practicable, and then the construction of a
purpose-built vapour barrier and cut-off wall to
isolate any residual on-site mercury from
surrounding groundwater and to prevent mercury
vapour egress.
Recovered mercury is stored on site and mercury
contaminated materials from all excavations is
disposed of off site at a licensed landfill.
The FCAP site prior to remediation commencing
TECE and ECSs (removed during Stage 3 of the
project)
• The Temporary Emissions Control Enclosure
(TECE) was a work enclosure built over Block G
to control emission of dust and mercury vapour
from Block G.
•
Two Emission Control Systems (ECSs), using
filters and absorbent carbon beds, were utilised
to remove dust and mercury vapour from the
TECE air before discharge through two stacks
(known as monitoring points 37 and 38).
•
The ECSs were monitored continuously to verify
effective operation.
The TECE
FCAP Remediation Project Fact Sheet April 2016
available at www.orica.com/Botany
Former ChlorAlkali Plant Mercury Remediation Project
Remediation Stages
The remediation is being conducted in four stages:
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Stage 1 – Blocks A and M excavation and reinstatement – completed November 2013;
Stage 2 – Block G targeted excavation and reinstatement – completed December 2013;
Stage 3 – decontamination and site preparation, and removal of the TECE and associated ECSs – completed
November 2014; and
Stage 4 – construction of cut-off wall and installation of capping system.
The four stages of work will take approximately three years.
The timing for each of these stages is updated on www.orica.com/Botany
Regulation
The FCAP Project is regulated under a Management Order (no. 20131406) issued by the NSW EPA on 2 August 2013
and amended from time to time as required. Environmental standards for the project are set out in Environment
Protection Licence 2148 (EPL2148) issued by the NSW EPA.
The Project is being undertaken in accordance with relevant workplace health and safety and environmental standards,
laws and policies, which require that soil and surface water are appropriately managed, dust emissions be confined within
the site boundary and that no odours be detected at the site boundary.
Environmental Management
Orica’s focus is to ensure that health and safety considerations drive the implementation of the FCAP remediation works
to ensure that the RAPs are implemented safely.
A series of detailed environmental management plans were prepared at the outset of the project to assess the potential
environmental impacts of the remediation works and to ensure that adequate monitoring and control processes are in
place. These plans, which were reviewed by the EPA, set out the specific responsibilities of the project team members,
the training requirements, how compliance tracking and recording will occur, and how incidents or emergencies will be
managed.
The purpose of the environmental management plans is to:
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Prevent detrimental effects on the environment or human health caused by potential discharges or emissions
from the remediation works;
Provide a framework for compliance with legal requirements;
Develop control measures for the environmental management issues identified in the Remediation Action Plans
and subsequent hazard identification processes; and
Provide a framework for communicating, implementing and documenting environmental control measures.
At the conclusion of the remediation works a Long Term Site Environmental Management Plan will be implemented,
including monitoring of groundwater and soil vapour to monitor the performance of the cut-off wall and vapour barrier and
to manage appropriate ongoing use of the site.
FCAP Remediation Project Fact Sheet April 2016
available at www.orica.com/Botany
Former ChlorAlkali Plant Mercury Remediation Project
Air Monitoring
Air monitoring is being conducted during the FCAP
Remediation Project to ensure that controls are
effectively managing potential environmental and
human health impacts.
The program focuses on protection of the
surrounding environment and ensuring that the
project does not present unacceptable risks to the
health of workers or the community. It includes air
quality monitoring at the site boundary and on site.
Three types of air monitoring for mercury vapour will
be conducted over the course of the FCAP Project:
1. Monitoring at the discharge points on the
Emission Control Systems (ECSs) at the TECE
– monitoring points 37 and 38. The ECSs, their
associated monitoring points and the TECE
were successfully removed as part of the
completion of Stage 3 works;
2. Ambient monitoring at three fixed BIP boundary
locations. The number of locations and
frequency of monitoring has been reduced over
time as the project has progressed and as
approved by the EPA; and
3. Workplace monitoring using handheld mercury
meters inside and outside the TECE for
occupational health and safety purposes and to
manage the remediation work schedule and
activities to achieve the boundary air quality
objectives.
The fixed point monitoring locations used at various
times across the project are shown in the adjacent
map. Following completion of the capping system
Licence Point 39 will continue to be monitored until
alternative arrangements are agreed with the EPA
as part of a Long Term Site Environment
Management Plan.
EPL2148 references a detailed Air Quality
Management Plan that sets out the stringent
emission limits and monitoring requirements.
Publication of Air Monitoring Results
Monitoring results are reported on the Orica website. Follow these steps from the Orica Botany home page >
Environmental Data > Mercury Remediation Project> Monitoring Data.
FCAP Remediation Project Fact Sheet April 2016
available at www.orica.com/Botany
Former ChlorAlkali Plant Mercury Remediation Project
Monitoring Groundwater Contamination
The FCAP operations resulted in mercury contamination in groundwater both at the BIP and downgradient, under off-site
industrial/commercial areas (groundwater in the Botany area moves in a south-westerly direction). No mercury
contaminated groundwater has been detected reaching any surface water bodies, including Springvale Drain, Floodvale
Drain and Penrhyn Estuary.
All of the off-site wells included in the Orica investigations are situated in industrial/commercial areas on Beauchamp
Road and McPherson Street, Banksmeadow, and fall under the Groundwater Extraction Exclusion Area where the
domestic use of groundwater is prohibited.
The aim of the FCAP remediation work is to reduce long-term groundwater impacts. The remediation works have been
managed so that groundwater quality is not adversely affected.
Block G cut-off wall construction extends to bedrock. The wall is located outside the area where mercury contaminated
soils are expected to be encountered, so the principal source area of mercury contamination is isolated from the
groundwater.
Groundwater monitoring is carried out according to a Groundwater Monitoring Plan. The latest report on groundwater
monitoring is provided on Orica’s website.
For more information
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www.orica.com/Botany for project details and progress updates, monitoring results and
documents including the RAPs and Remediation Options Appraisal Report
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Project updates are provided at meetings of the Orica Botany Liaison Committee
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NSW Health community information on mercury and health – available at
http://www.health.nsw.gov.au/environment/factsheets/Pages/mercury.aspx
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EPL2148 available by searching for licence 2148 at http://www.epa.nsw.gov.au/prpoeoapp/
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Or contact Orica:
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by email to [email protected]
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by phoning our Community Hotline for complaints enquiries and feedback - 1800 025 138
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by writing to Community Matters, 16-20 Beauchamp Road, Matraville 2036
FCAP Remediation Project Fact Sheet April 2016
available at www.orica.com/Botany