Project update

This project is now complete. See below for background about the project and advice from an independent consultant and the EPA Accredited Auditor.

Project update - April 2022.

Council recently engaged a consultant and an EPA Accredited Auditor to meet the requirements as set out by the EPA Clean Up Notice 90011425 and this was submitted, on time, last year.

As part of this submission:

• Council submitted the audited Clean Up Plan and Verification and Assessment Report to the EPA and the Daylesford Field and Game Environmental Management Plan (EMP) for future shooting activities on the site.
• The EPA accepted the report and revoked the Clean Up Notice 90011425. It issued Council with a Duty to Manage Contaminated Land notice and Council began implementation of the proposed Clean Up Plan early in 2022.
• The EPA accepted the EMP recommendations with some small changes recommended for its completion.
• Council re-engaged the consultant and the EPA Accredited Auditor in early 2022 and they have recently finalised their work investigating the potential soil contamination on the Glenlyon Recreation Reserve.
• The work undertaken was to:
  • Carry out further sampling of soil and surface water, as requested by the EPA Accredited Auditor.
  • Determine site specific upper contaminant limits that considers the form of contaminants, available scientific analysis on clay targets and an amended possible exposure based on use of the Reserve.
  • Based on the above, carry out a risk assessment and determine if there is any public health or environmental risk.
  • Propose a remediation strategy, if required, based on the risk analysis.
  • The risk posed by contaminants of concern associated with clay target shooting (i.e. lead and PAH compounds) in the Site’s soil and surface water to all identified receptors is considered to be low and acceptable.
  • Given the risks are considered to be low and acceptable, no further risk assessment, remedial actions or further management controls are required for the Site based on its ongoing use as a public recreational reserve.
  • The management measures (such as temporary fencing, etc.) being taken by the Council to manage the potential short-term exposure risk to public health and the environment are no longer considered to be required. It is recommended, however, that the risk mitigation measures outlined in an Environmental Management Plan are employed as part of the recommencement of clay target shooting activities at the Site.

As part of implementation of the Clean Up Plan works:

• Council re-engaged the consultant and the EPA Accredited Auditor in early 2022 and they have recently finalised their work investigating the potential soil contamination on the Glenlyon Recreation Reserve.
• The work undertaken was to:
  • Carry out further sampling of soil and surface water, as requested by the EPA Accredited Auditor.
  • Determine site specific upper contaminant limits that considers the form of contaminants, available scientific analysis on clay targets and an amended possible exposure based on use of the Reserve.
  • Based on the above, carry out a risk assessment and determine if there is any public health or environmental risk.
  • Propose a remediation strategy, if required, based on the risk analysis.
  • The risk posed by contaminants of concern associated with clay target shooting (i.e. lead and PAH compounds) in the Site’s soil and surface water to all identified receptors is considered to be low and acceptable.
  • Given the risks are considered to be low and acceptable, no further risk assessment, remedial actions or further management controls are required for the Site based on its ongoing use as a public recreational reserve.
  • The management measures (such as temporary fencing, etc.) being taken by the Council to manage the potential short-term exposure risk to public health and the environment are no longer considered to be required. It is recommended, however, that the risk mitigation measures outlined in an Environmental Management Plan are employed as part of the recommencement of clay target shooting activities at the Site.

• The conclusions drawn from the risk assessment report and validated by the EPA Accredited Auditor were as follows:

o The risk posed by contaminants of concern associated with clay target shooting (i.e. lead and PAH compounds) in the Site’s soil and surface water to all identified receptors is considered to be low and acceptable.

o Given the risks are considered to be low and acceptable, no further risk assessment, remedial actions or further management controls are required for the Site based on its ongoing use as a public recreational reserve.

o The management measures (such as temporary fencing, etc.) being taken by the Council to manage the potential short-term exposure risk to public health and the environment are no longer considered to be required. It is recommended, however, that the risk mitigation measures outlined in an Environmental Management Plan are employed as part of the recommencement of clay target shooting activities at the Site.

The Glenlyon Recreation Reserve is a popular site for locals and visitors to Glenlyon to undertake a range of activities.

In 2019, the potential for soil contamination at the Glenlyon Recreation Reserve was identified and a qualified, experienced and independent consultant, Beveridge Williams, completed a Preliminary Soil Contamination Assessment in November. The report showed elevated levels of lead and polycyclic aromatic hydrocarbons (PAHs) in central areas of the reserve. You can view the Beveridge Williams report in the Document Library (to the right of this page).

Council self-notified the results of the Beveridge Williams report to the regulator, the Environment Protection Authority Victoria (EPA), and, under direction from the EPA, implemented precautionary measures to reduce public health risks and further pollution on the site. These precautionary measures enabled continued modified use of the site and included:

• public health signage;
• fencing;
• assistance to Reserve User Groups with event management planning;
• watering down of soil to reduce dust generated by horses and vehicles and,
• a temporary suspension of shooting activities on the site.

The implementation of these measures by Council was supported by the Section 86 Glenlyon Recreation Reserve Special Committee and Reserve User Groups.

In January 2020, the EPA issued a Clean-Up Notice that required an Environmental Site Assessment (ESA) to look at the extent and level of contamination of soil, groundwater and surface water on the site. The legal notice required the ESA to be completed in accordance with the National Environment Protection Measure (NEPM) (Assessment of Site Contamination) 1999.

As a result, Council engaged a qualified and experienced, independent consultant, Kleinfelder, to undertake the ESA. Their assessment was completed and submitted to the EPA on 27 May 2020 to meet the requirements of the Clean Up Notice. In January 2021 Kleinfelder updated their assessment, a full breakdown of which can be found in the Document Library (to the right of this page).

Council will continue to meet the requirements as directed by the EPA, including maintaining current precautionary measures. The Landowner, the Department of Environment, Land, Water and Planning (DELWP), has been notified and will continue to be kept informed throughout the project. DELWP have advised they will participate in all future discussions.

The Reports

The ESA report found the extent and severity of soil contamination is less than indicated in the preliminary assessment.

The preliminary assessment used X-ray fluorescence (XRF) technology (a hand-held device for immediate assessment) to determine contaminant levels and found that lead and PAH levels were higher than the NEPM levels for recreational use. This was appropriate to provide an immediate understanding of the issue and inform decision-making.

The second assessment, the ESA, was completed in accordance with the NEPM. This assessment used a laboratory-based soil testing method. It included soil sampling at 100 locations, ground water sampling at 4 boreholes, and water sampling at three locations (2 water courses discharging to Loddon River and Glenlyon Community Dam), which were analysed by a National Association of Testing Authorities (NATA) certified lab.

Key findings from the ESA:

Lead contamination

Results show that lead contamination is lower than indicated in the preliminary assessment. In the ESA, lead contamination levels were reported below the NEPM Health Investigation Level applicable for recreation areas.

PAH contamination

As found in the preliminary findings, results show that PAH contamination is elevated and above NEPM Health Investigation Level for recreational areas, within the racecourse perimeter.

Ground water and surface water

Results show that both groundwater and surface water have not been affected by the lead or PAH contamination.

Soil testing in other areas of the Reserve

Soil testing results in the areas of high community use (e.g. playground, camping) and at other potential construction sites (e.g. BBQ area, pony yards, disability mounting block, pavilion) did not identify lead or PAH contamination that represent either a human or environmental risk.

A Community Briefing was held on Saturday 8 August 2020. Click here to view a copy of the presentation.

Following the community briefing and last update in August, Council has begun procurement for the next stage to meet a Clean Up Notice issued by the EPA to develop a Clean Up Plan for the Glenlyon Recreation Reserve. This Clean Up Plan will be developed by an independent consultant and verified by an EPA accredited Auditor.

The Clean Up Plan will inform what management and/or what remediation works may be required to be undertaken at the Glenlyon Recreational Reserve.

At the moment, we are hoping to have this Clean Up Plan completed by end of May 2021.

Given the results of the detailed Environmental Site Assessment and a subsequent Pollution Abatement Notice issued to Council by the EPA to maintain interim public health precautionary measures at the Reserve, temporary fencing and signage has been installed. Essentially these fences allow more use of the reserve, however we are taking a precautionary approach to fencing these areas and the Clean-up Plan will determine if and what remediation may be required.

This fencing:

• assists to precautionary delineate areas where concentration levels of lead and PAH were found to be elevated compared to the relevant national guideline limits;
• assists in delineating areas available to use for possible events at the reserve and
• will be reviewed during the Clean Up Plan process and areas may reduce slightly following assessment.

The 8 approximate areas where fencing has been installed are shown by the map below. These fenced off areas have the following signage installed: