Asbestos Survey and
Assessment – Anzac Rifle
Range, Malabar Headland
New South Wales
May 2010
United Group Process Solutions
Parsons Brinckerhoff Australia Pty Limited
ABN 80 078 004 798
Level 27, Ernst & Young Centre
680 George Street
SYDNEY NSW 2000
GPO Box 5394
SYDNEY NSW 2001
Australia
Telephone +61 2 9272 5100
Facsimile
+61 2 9272 5101
Email
sydney@pb.com.au
PR_1184 RevB
Certified to ISO 9001, ISO 14001, AS/NZS 4801
Revision
Details
Date
Amended By
00
Original
November 2009
MA
01
Revision
February 2010
MA
B
Revision
May 2010
TR
©Parsons Brinckerhoff Australia Pty Limited (PB) [2010].
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undertakes no duty and accepts no responsibility to any third party who may use or rely upon this document or the information.
Author:
.......................................................... John Batty & Tracy Rosser
Signed:
.....................................................................................................
Reviewer:
............................................................................ Adrian Spankie
Signed:
.....................................................................................................
Approved by:
............................................................................ Adrian Spankie
Signed:
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Date:
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2160572A PR_1184 RevB
Parsons
Brinckerhoff
Australia
Pty Limited
ABN 80 078 004 798
Our reference
2160752A/PR_1184/MA/dz
Level 27, Ernst & Young Centre
680 George Street
SYDNEY NSW 2000
GPO Box 5394
SYDNEY NSW 2001
Australia
Telephone +61 2 9272 5100
Facsimile +61 2 9272 5101
Email sydney@pb.com.au
Certified to ISO 9001; ISO 14001;
AS/NZS 4801
10 May 2010
Ms Rene Polski
Senior Asset Manager
United Group Process Solutions
Level 4, 64 Northbourne Avenue
Canberra ACT 2600
Dear Ms Polski
Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland
Parsons Brinckerhoff is pleased to submit our final report on the findings and assessment of the above
site with respect to asbestos containing materials.
We would welcome the opportunity to discuss any aspect of the report and the recommendations
Yours sincerely
John Batty
Senior Consultant
Parsons Brinckerhoff Australia Pty Limited
Over a Century of
Engineering Excellence
Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
Contents
Page number
Executive summary
1.
iii
Introduction
1
1.1
Background
1
1.2
1.1.1
Site History
Site description
1
2
2.
Scope of work
3
3.
Methodology
4
4.
Health effects of asbestos
5
4.1
What is asbestos?
5
4.2
Health Hazards
5
4.2.1
4.2.2
4.2.3
5
5
6
5.
6.
Findings
7
5.1
Rationale for determination of categories
7
5.2
Visual observations
7
5.2.1
5.2.2
5.2.3
8
8
9
Areas 4-21 Category 1
Areas 1-3 – Category 2
Areas 22-42 – Category 3
Asbestos related health risks
16
6.1
16
General
6.1.1
6.1.2
6.1.3
6.1.4
6.1.5
6.1.6
7.
Causes
Effects
‘Hazard’ and ‘Risk’
Asbestosis risk
Lung cancer risk
Mesothelioma risk
Screening guidelines for asbestos related disease
Occupational exposure standards
Risks in general
16
17
17
18
18
19
Air monitoring
20
7.1
Introduction
20
7.2
Limitations of the method
20
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
7.3
8.
9.
Results
20
Discussion
21
8.1
Asbestos in soil
21
8.2
8.1.1
Risk
21
22
Non-occupational environments
Recommendations
23
9.1
Short term management
23
9.2
9.1.1
Stakeholder Management
9.1.2
Remediation / Cleanup
Ongoing management
23
23
24
9.3
9.2.1
Asbestos management plan
9.2.2
Objective
Additional management options
24
25
25
10.
Conclusions
26
11.
Relevant NSW legislation
27
List of tables
Table 5-1
Table 5-2
Findings
Accessibility
10
15
Appendices
Appendix A
Appendix C
Appendix D
Appendix E
Maps Appendix B
Photographs
Air monitoring results
Limitations of an asbestos inspection
Occupational exposure standard documentation
PARSONS BRINCKERHOFF
PR_1184 REVB.DOC
Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South
Wales
Executive summary
Parsons Brinckerhoff (PB) was engaged by United Group Process Solutions (UGPS) on behalf of the
Department of Finance and Deregulation, to carry out a visual inspection and investigation of the surface
and exposed areas of the ‘site’ known as Anzac Rifle Range, Malabar with respect to surface
contamination of the site by asbestos containing materials (ACM).
This report provides a summary of the following:

background and site description

the methodology for conducting the site inspections

health risks

the finding of the visual inspections

risk assessments

discussion

recommendations.
The survey and inspection of the site was conducted by PB surveyors, Mr. John Batty, Ms. Haley Bates
and Mr. Mandev Kler, in October and November 2009.
In summary, the visual inspection identified that extensive but varying amounts of ACM debris and small
amounts of asbestos rope were identified across the site with concentrated amounts located in the areas
categorised as follows:
Areas 4-21 - Category 1 (Red)
High priority for surface clean up: areas of the site where significant volumes of fibrous ACM fragments
were identified >10fragments/100m2. These areas are readily accessible to site users and often involve
high usage activities which have a significant impact on disturbing the ground surface, such as horse
riding and access by the public and therefore increasing the risk to health.
Areas 1-3 - Category 2 (Blue)
Moderate priority for surface clean up: the areas were ‘fly tipping’ of ACM’s has occurred. These areas
have limited accessibility and may only be accessible by 4WD vehicles and/or by using the walking trails.
Fly tipped material may have been recently dumped and could therefore contain friable ACM.
Areas 22-42 - Category 3 (Green)
Low priority for surface clean up: areas were small volumes of fibrous ACM fragments were identified <10
fragments/ 100m2. The areas are less accessible to the public and site activity is minimal or infrequent.
The above categories and numbered areas are documented in Figure 1 (Appendix A).
Based on the visual observations made with respect to the site activities, the type and condition of the
identified ACM’s, the locations of the ACM’s and the air monitoring tests, the health risk from exposure to
airborne asbestos fibres is considered to be low.
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South
Wales
Notwithstanding the above, consideration should be given to the development of a short term remedial
action plan to cleanup and remove the visible and accessible ACM’s from the areas within the site.
Due to the characteristic nature of the site with respect to the types of soil, the types of buried wastes, the
types of site activities that occur at the Malabar Headland, exposure to the elements and natural soil
erosion, it is possible that further occurrences of ACM will continue to present themselves.
Longer term management issues can be addressed with the development and implementation of an
Asbestos Management Plan to mitigate future risks associated with potential buried asbestos.
PARSONS BRINCKERHOFF
PR_1184 REVB.DOC
Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
1.
Introduction
Parsons Brinckerhoff (PB) was engaged by United Group Process Solutions (UGPS) on
behalf of the Department of Finance and Deregulation to carry out a visual inspection and
investigation of the surface and exposed areas of the ‘site’ known as Anzac Rifle Range,
Malabar.
United Group Process Solutions (UGPS) manages the Commonwealth of Australia owned
non-defence domestic property portfolio in a strategic alliance with the Department of
Finance & Deregulation (Finance).
The visual inspection and investigation was to determine and map the distribution and
occurrences of asbestos containing materials (ACM) across the site.
In addition there is a requirement to develop a Surface Asbestos Management Plan to assist
in the management the potential health risk in the future.
1.1
Background
The site is located in an area known as the Malabar Headland approximately 13 kilometres
south east from the Sydney CBD.
The Site has been operating as a Rifle Range since the early 1900s.
A number of other activities that take place across the site include the following:
 equestrian activities including permanent stabling and trail riding areas
 model aeroplane flying
 bush regeneration.
Some of the non-approved activities that take place are:
 bushwalking
 jogging
 bird watching
 fishing.
1.1.1
Site History
Land filling occurred across 71 hectares of Lot 1 from the 1940s to the 1990s. Sand mining
on the site was also conducted concurrent to the land filling activities.
From 1970 onward, the site was ‘backfilled’ with clean inert building material. Anecdotal
evidence however, indicates that waste materials from local industries continued to be
deposited at the site up until 1988.
Ground subsidence at the small bore rifle range between 1984 and 1988, combined with
reports of subsurface fires in the same area, suggests volumes of putrescibles waste were
also deposited with the landfill areas.
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
Fill material deposited at the site was not compacted and reports indicating that the rubbish
was covered with a layer of sand and sandstone gravel (usually 0.5 m to 1.0 m thick) at the
end of each day.
Anecdotal evidence also indicates that the fill material is possibly 15 to 20 metres thick in
some areas of the site where sand mining occurred, and volume estimates have calculated
an approximate volume of 1.4 million m3 of fill material at the site.
Due to the historical and uncontrolled filling at the site and the unfenced nature of large
sections of the site perimeter, it has been identified that there is a potential for asbestos
containing materials (ACM) to be widespread across the site.
Previous site investigations have also shown that ‘fly-tipped’ waste is present at numerous
locations within the site boundary. This sort of waste has also been noted to contain ACM’s.
1.1.1.1
Environment and heritage details
The site is listed on the Register of the National Estate and protected under the
Commonwealth Environment Protection and Biodiversity Conservation Act 1999 (EPBC Act).
Malabar Headland is also listed on the Commonwealth Heritage List and contains a number
of important Aboriginal and European cultural heritage sites.
In addition to the above, the Malabar Headland comprises significant ecological values,
including remnant areas of Eastern Suburbs Banksia Scrub, which is an endangered
ecological community listed under the EPBC Act that is particularly susceptible to changes in
soil conditions.
Currently the site contains extensive patches of weeds including Bitou Bush and Lantana
which have grown over parts of the site which have been disturbed due to previous landfill
activities.
The presence of Bitou Bush and Lantana was taken into account by PB whilst undertaking
the site inspection work.
1.2
Site description
Malabar Headland covers an area of approximately 177 hectares of Commonwealth land.
The majority of the site boundary is formed by coastline which adjoins Maroubra Beach to
the north, as well as the Sydney Water Treatment Plant to the southwest.
The site’s western boundary lies adjacent to residential areas and a number of small parks.
Some Sydney Water sewerage and water supply infrastructure is located within the site,
including pipe conduits.
Refer to Appendix A for Location Plan, Site Description (being Lots 1, 2 and 4 of DP809094)
and Aerial Photograph, respectively.
PARSONS BRINCKERHOFF
PR_1184 REVB.DOC
Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
2.
Scope of work
The scope of the task was to survey and visually inspect the site to identify the location,
determine the condition of any ACM debris and to assess the potential health risks posed by
the ACM’s.
A visual survey and inspection of the site was undertaken in accordance with guidelines
provided in Department of Health and Ageing, enHEALTH – Management of Asbestos in the
Non-Occupational Environment (2005) as well PB in-house asbestos surveying
documentation.
For each occurrence of ACM’s that were observed during the visual inspection, the following
information was recorded:
 the location of ACM’s
 the type of ACM’s and an assumption of asbestos content
 the amount of ACM within the areas (waste dump sites)
 condition of the ACM’s
 wear and weathering
 soil type and the state of the site surface
 accessibility
 site activity in the vicinity of the identified ACM’s.
Sampling of ACM’s for analytical testing was not undertaken. A valued judgement was made
based on the inspector’s extensive knowledge and experience as to the type of ACM’s
observed.
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
3.
Methodology
A general field survey was undertaken in order to visually identify (as far as reasonably
practicable) the occurrences of ACM’s on the surface of all physically accessible areas of the
site. Photographs were taken to record areas of interest and referenced against the
recorded GPS co-ordinates (refer appendix B).
 the site was subdivided into manageable areas (100 metre grids) with the transects
plotted on to an aerial picture for ease of reference
 each sub-site (100 metre grid section) was visually assessed by walking back and forth
along parallel transects across each sub-site and / or driving where deemed appropriate.
Those areas were access during the visual inspection to the ground surface is restricted
by grassed and shrubs will be categorised as follows:
 limited access – 50% of ground surface covered by shrubs and grasses
 restricted access – 80% of ground surface covered by shrubs and grasses
 no access – the area could not be physically accessed during the site inspection
 each transect was logged into the GPS unit to provide evidence and confirm that all areas
of the site have been investigated
 the surveyors recorded each location where ACM’s were observed on the surface using a
GPS data logging unit
 photographs were also taken where this provided additional information and to show
types of waste material observed
 a series of air tests were carried out to assist with the determination of the potential
health risk from airborne asbestos fibres
 any areas that were identified as what could be considered to be in the ‘high risk’
category were referred to UGPS for immediate management action
 spatial coordinates were geo-referenced to AMG 2000 where applicable.
NOTE:
No trenching or test pitting was undertaken as part of the assessment. The terrain on the site
is variable with some areas openly accessible while other sections are heavily overgrown
bushland and vegetation with very limited or no access afforded.
PARSONS BRINCKERHOFF
PR_1184 REVB.DOC
Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
4.
Health effects of asbestos
4.1
What is asbestos?
Asbestos is the name given to a group of fibrous silicate minerals that occur naturally in the
environment.
It was commonly used in many building materials between the 1940’s and late 1980’s
because of its durability, fire resistance and excellent insulating properties. It was also used
in friction and sealing products in many types of vehicles and industrial applications including
brakes, clutches and gaskets.
The presence of asbestos may pose a risk if it is:



broken
in poor deteriorated condition
disturbed during activities that produce dust containing asbestos fibres.
There are two major and common groups of asbestos minerals:
The Serpentine group -- The serpentine group contains chrysotile, commonly known as
white asbestos.
The Amphibole group - The Amphibole group contains amosite (brown asbestos), crocidolite
(blue asbestos) and other less common types.
4.2
Health Hazards
4.2.1
Causes
Asbestos fibres are made of very fine fibrils, so as asbestos is further processed or disturbed
the fibres become finer and more hazardous. The most dangerous fibres are those that are
invisible to the naked eye as they penetrate the deepest part of the lung.
4.2.2
Effects
Inhaling of fibres brings a risk of asbestosis, lung cancer and mesothelioma.
Asbestos-related diseases have a delay period of between 20 to 40 years (possibly more)
between exposure, onset of symptoms and detection of the disease.
The disease is generally associated with long-term exposure to asbestos in an occupational
setting. However, as the level of exposure that may cause adverse health effects is
unknown, exposure to asbestos fibres or dust containing asbestos fibres should always be
kept to a minimum.
Asbestosis is the scarring of lung tissue that can result from the inhalation of substantial
amounts of asbestos over a period of years. Asbestosis causes breathlessness, and in some
cases, early death.
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
Lung cancer is related to the amount of fibre inhaled and is increased in persons who also
smoke cigarettes.
Mesothelioma is a cancer of the outer lung lining or of the lining of the abdominal cavity.
4.2.3
‘Hazard’ and ‘Risk’
The presence of asbestos is a health hazard, because asbestos has the potential to cause
harm to humans. For a human health risk to exist there must also be an exposure pathway
by which persons are exposed to respirable asbestos fibres. Thus, asbestos cannot pose a
risk simply by being present; a risk can only exist when there is also a complete exposure
pathway.
Human health risk is based on exposure to a potential hazard and is defined as:
Risk = Hazard x Exposure.
Consequently, risk can be removed or managed by removal/management of the hazard
and/or removal/management of the exposure pathway.
The principal exposure pathway for asbestos is via inhalation of ‘respirable’ asbestos fibres.
'Respirable‟ asbestos fibres are broadly defined as fibres less than three micrometres in
width, and greater than five micrometres in length.
Asbestos fibre bundles and asbestos fibres of larger size than the above dimensions are not
classed as respirable. Therefore, for a risk to exist it is necessary for respirable asbestos
fibres to be present and for these to be respired or be capable of being respired. Further,
where respirable asbestos fibres are present, the magnitude of risk will be dependent upon
the concentration of airborne asbestos fibres actually respired by a person, and the duration
of exposure.
Asbestos related diseases only occur when significant amounts of airborne asbestos fibres
are respired over a considerable period of time.
Many thousands of people have suffered illness or died over the years as a result of direct
exposure to asbestos.
However, these diseases are believed not to occur as the result of acute, (i.e. short term)
exposure to very low concentrations of airborne asbestos fibres.
Evidence suggests that exposure to significant concentrations of airborne asbestos fibres for
many years of a working life may lead to various asbestos related diseases.
PARSONS BRINCKERHOFF
PR_1184 REVB.DOC
Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
5.
Findings
5.1
Rationale for determination of categories
The visual site survey and inspection was carried out by PB from 19 October to 3 November
2009.
For the ease if referencing the areas and being able to plot and record the findings of the
visual assessment as the inspection progressed, the sites where ACM has been identified
have been sequentially numbered and the findings categorised (see below).
For the purposes of reporting the findings of these inspections and determining what
remedial actions maybe relevant depending on the extent and condition of ACM
contamination, the surveyed areas have been divided into the following three (3) categories:
Areas 4-21 - Category 1 (Red)
High priority for surface clean up: areas of the site where significant volumes of fibrous ACM
fragments were identified >10fragments/100m2. These areas are readily accessible to site
users and often involve high usage activities which have a significant impact on disturbing
the ground surface, such as horse riding and access by the public and therefore increasing
the risk to health.
Areas 1-3 - Category 2 (Blue)
Moderate priority for surface clean up: the areas were ‘fly tipping’ of ACM’s has occurred.
These areas have limited accessibility and may only be accessible by 4WD vehicles and/or
by foot. Fly tipped material may have been recently dumped and could therefore contain
friable ACM.
Areas 22-42 - Category 3 (Green)
Low priority for surface clean up: areas were small volumes of fibrous ACM fragments were
identified <10 fragments/ 100m2. The areas are less accessible to the public and site activity
is minimal or infrequent.
The above categories and numbered areas are documented in Figure 1 (Appendix A).
5.2
Visual observations
As far as reasonably practicable all areas across the site were accessed and visually
inspected. However, it should be noted that some areas of the site could not be accessed
due to the amount of heavy vegetation and lack of physical access. These inaccessible
areas are noted on the site maps presented in Appendix A.
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
5.2.1
Areas 4-21 Category 1
High concentrations of bonded fibrous cement fragments (Category 1) were noted in the
areas were high impact activities such as the horse riding and driving occurred. Few
fragments were noted along walking tracks and in those areas affected by weather
conditions such as wind and rain.
As access to these areas is readily available and the activities undertaken in these areas
have a considerable impact on the ground surface, they should be treated as high risk and
the surface fragment removed to minimise the risk to human health through airborne
asbestos fibres. . Refer to Appendix B photographs 5-13 for pictures of the areas.
5.2.2
Areas 1-3 – Category 2
These areas are situated at the far south-eastern end of the Malabar Headland. Access to
these areas is limited and could only be accessed along a series of walking trails and a
number of 4WD tracks.
The vegetation coverage in this portion of the site ranged from very heavy coverage with
plants covering up to 90% of the ground surface, to open sandstone areas with no
vegetation (at the far eastern tip of the headland) (see photo No’s 1-3 in Appendix B).
Access to areas 1-3 were undertaken by initially driving along the 4WD tracks (where
possible) then alighting from the vehicle and walking along the intersecting walking trails.
The visual observations made and the occurrences of ACM materials noted in these areas
consisted of what appears to be ACM’s that have been dumped on the site by “fly-tipping”
and sporadic occurrences of ACM’s that possibly have come from the piles of “fly-tipped
waste and inadvertently spread around the areas by authorised site activities.
Due to the uncertain nature of fly tipped material, i.e. when the material was dumped and the
increased likely hood that the material may contain friable material, the areas were this has
occurred should be treated as a moderate risk.
Photographic evidence as to a typical example of fly –tipping” is provided in Photo No 4.
This photograph shows the typical types of waste that has been dumped in this particular
spot on the site.
A variety of different sized ACM fragments were observed intermingled amongst the rubbish
at these sites. The ACM ranged in size from large sized fragments of ACM sheet (both
corrugated and flat) measuring 500mm x 500mm to much smaller sized fragments
measuring 20mm x 20mm and smaller.
Generally the ACM’s identified were ‘bonded’ ACM i.e. flat or corrugated asbestos cement
sheet.
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
5.2.3
Areas 22-42 – Category 3
These areas are located across the site and are comprised of grassed areas, paths/roads
and scrub. Generally these areas are readily accessible by users of the grounds however
activities are usually low impact such as model air plane flying and shooting. The ground
coverage in these areas is fairly dense with 90% of the surface being covered with
vegetation i.e. grass cover.
Bonded fibrous cement fragments were noted in these areas at low concentration,
<10fragments/100m2. A majority of these fragments were noted along access tracks through
these areas. As the concentrations of fibre cement fragments were found to be low and
general impact to the grounds via activities were also found to be low the risk associated
with this material can be categorised as low.
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
Table 5-1
Findings
Category
Area
Number
Location
Type of
ACM
2
1
Sandstone
cliffs south east
corner of site
2
2
2
1
1
1
Public/ site
users
Accessibility
Description
Condition
Soil Type & State of
Surface
Asbestos
cement
fragments
5-7% of surface scattered with AC
fragments
Fair
Sandstone cliffs
1
Bush area
south of cliff
access road
Asbestos
cement
fragments
Fly tipped material including AC
flat and corrugated sheeting. AC
material approximately 10% of
surface material
Fair
Sand and fill material
with some shrubbery
3
Bush area
north of cliff
access road
Asbestos
cement
fragments
Fly tipped material including AC
flat and corrugated sheeting. AC
material approximately 10% of
surface material
Fair
4
The track
junction in
bush area
between track
from shooting
range and
track from
Sydney water
Southern most
shooting range
and road/track
extending from
beginning of
central range
to top of stop
butts
Asbestos
cement
fragments
Sandy track - fragments appear to
have migrated to surface
approximately 1% cover
Asbestos
cement
fragments
Asbestos
cement
fragments
5
6
Central range Embankment
before targets
and
embankment
directly south
of targets
PARSONS BRINCKERHOFF
Site
Activity
Photo
N/A
1,2
1
Restricted
access
N/A
3
Sand and fill material
with some shrubbery
1
Restricted
access
N/A
4
Fair
Sand and fill material
1
Restricted
access
Track
N/A
AC fragments scattered
throughout area. Approximately
1% cover. Fragments
concentrated on road and bare
patches of ground.
Fair
Sand and fill material
with grass cover
Accessible to
shooters
Car park
and
shooting
range
5
AC fragments spread throughout
area especially throughout central
mound.
Fair
Compacted sand and
fill material with grass
cover
Accessible to
shooters
Shooting
range
6
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
Category
Area
Number
1
7
1
1
1
1
1
1
1
Site
Activity
Description
Condition
Central range South west
grass area
position of
horse jumps
Asbestos
cement
fragments
Due to horse activity and wear of
grass fragments have migrated to
surface. Approximately 1% cover
Fair
Sand and fill material
with grass cover
Accessible to
shooters and
horses
Shooting
range and
horse
jump
8
Drummoyne
shooting range
- Embankment
north of range
Asbestos
cement
fragments
Embankment constructed with fill
material. AC fragments exposed
due to weathering
Poor
Compacted rock and
fill material
Accessible to
shooters
Shooting
range
9
Mounds
produced by
landfill material
Asbestos
cement
fragments
AC fragments mixed with landfill
material. Migrated to surface at
exposed bare patches
Fair
Sand and fill material
with grass and shrub
cover
10
Rock area west
of road
Asbestos
cement
broken
sheeting
AC broken sheeting spread in area
and extending onto road. 40% of
surface area
Fair
11
Road between
south west
buildings
Asbestos
cement
fragments
Small fragments within unsealed
road. Most probably brought in as
fill material for road construction
12
Terracotta
gravel car park
area east of
south west
buildings
Asbestos
cement
fragments
13
Horse
paddocks
14
Mound east of
riding school Top of mound
east and track
extending to
main range
PARSONS BRINCKERHOFF
Soil Type & State of
Surface
Public/ site
users
Accessibility
Type of
ACM
Location
1
Photo
7
N/
A
Restricted
access
Track
N/A
Rock and grass
Access to all
Adjacent
to road
N/A
Fair
Gravel and sand
Access to all
Road
N/A
Small fragments within unsealed
car park. Most probably brought in
with fill material for car park
construction
Fair
Terracotta gravel, fill
material and sand
Access to all
Road/car
park
N/A
Asbestos
cement
fragments
Fragments spread throughout
paddocks. Concentrated within
sand paddock.
Fair
Access to riding
school
Horse
paddocks
N/A
Asbestos
cement
fragments
Fragments spread throughout
exposed (warn) areas
Fair
North paddocks
(stables) ground cover
only sand.
Other paddocks sand
and fill material with
grass cover
Sand and fill material
with some grass cover
Access to riding
school
Horse
tracks and
jumps
N/A
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Category
Area
Number
1
15
Track
extending
through bush
area
1
16
1
Location
Type of
ACM
Soil Type & State of
Surface
Public/ site
users
Accessibility
Site
Activity
Photo
Description
Condition
Asbestos
cement
fragments
Fragments spread throughout
exposed (warn) walking track
Fair
Sand and fill material
with grass cover and
shrubs
Access to all
Walking
track
N/A
1. Road
extending
through to top
of main
shooting range.
2. Bush area
north and west
of track to
pistol club.
3. Bush west of
pistol club
4.Pistol club
car park.
5. Grounds
east of road to
top of main
shooting range
Asbestos
cement
fragments
1. Fragments found throughout
unsealed road and sidings.
2. Fragments found throughout
exposed areas of bush,
specifically adjacent to road and
top of rise.
3. Fragments found spread
throughout exposed areas of bush
specifically tracks and top of rise.
4. Fragments in car park and ash
tray area.
5. During periods of rain AC
fragments have travelled from rise
down road and into grassed area.
Surface also bare of grass
Fair
Sand and fill material
with some grass cover
and shrubbery
Access to riding
school and
shooters
Road, car
park and
bush
8, 9, 10, 11
17
Bare patches
in main
shooting range
Asbestos
cement
fragments
Fragments found in warn areas of
range
Fair
Sand and fill material
with grass cover
Access to all
Shooting
range
N/A
1
18
Bare patches
adjacent to
ditch
Asbestos
cement
fragments
Fragments found in warn areas
Fair
Sand and fill material
with grass cover
Access to all
N/A
N/A
1
19
North boundary
road and
central spine
road
Asbestos
cement
fragments
Fragments spread throughout
unsealed sandy road
Fair
Sand and fill material
Access to all
Road
12
1
20
Grass area
adjacent to
residence
Asbestos
cement
fragments
Fragments found in warn areas
Fair
Sand and fill material
with grass cover
Access to all
N/A
N/A
1
21
North western
track
Asbestos
cement
fragments
Fragments spread throughout
unsealed sandy road
Fair
Sand and fill material
Access to all
Road
N/A
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Public/ site
users
Accessibility
Site
Activity
Photo
Limited access
N/A
N/A
Limited access
N/A
N/A
Accessible to
shooters
Track
used to
access
flag poles
N/A
Limited access
N/A
N/A
Sand and fill material
with grass cover
Access to all
Shooting
range and
horse
jump
N/A
Fair
Fill material (gravel,
ceramic tiles,
terracotta tiles)
Access to
shooters
Road
N/A
Some fragments identified in bare
patches
Fair
Sand and fill material
Access to all
Shooting
range
N/A
Asbestos
cement
fragments
Some fragments identified in bare
patches and surrounding parked
horse floats
Fair
Sand and fill material
with grass cover
Access to all
Road
siding and
horse
float park
N/A
Central range north east
grassed area
Asbestos
cement
fragments
Some fragments identified in bare
patches
Fair
Sand and fill material
with grass cover
Access to all
Shooting
range
N/A
Central range eastern road
Asbestos
cement
fragments
Some fragments on road
Fair
Fill material (gravel,
ceramic tiles,
terracotta tiles)
Access to
shooters
Road
N/A
Category
Area
Number
3
22
Grass area
with
shrubs
above central
range stop
butts
3
23
Type of
ACM
Soil Type & State of
Surface
Description
Condition
Asbestos
cement
fragments
Small amount of fragments spread
through area
Fair
Sand and fill material
with grass cover and
shrubbery
2
Track in shrub
area
Asbestos
cement
fragments
3 fragments identified in area
Fair
Sand and fill material
with some grass cover
and shrubbery
2
24
Top of stop
butts to south
and central
shooting
ranges
Asbestos
cement
fragments
Sporadic fragment distribution
identified in bare patches of
ground
Fair
Sand and fill material
with grass cover
3
25
Track leading
around cleared
area
Asbestos
cement
fragments
Some fragments identified on track
and surrounding area
Fair
Sand and fill material
3
26
Central range south west
corner in
position of
horse jumps
Asbestos
cement
fragments
Some fragments identified in bare
patches
Fair
3
27
Central range central spine
road
Asbestos
cement
fragments
Some fragments on road
3
28
Central range North central
grassed area
Asbestos
cement
fragments
3
29
Riding school
south road
siding
3
30
3
31
3
Location
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Category
Area
Number
3
32
Drummoyne
pistol club
3
33
34
3
3
3
3
3
3
35
36
Location
Soil Type & State of
Surface
Public/ site
users
Accessibility
Site
Activity
Fair
Sand and fill material
with some grass cover
Access to
shooters
Shooting
range
N/A
Some fragments on road and bare
patches. Broken down pipes and
gutters from the building also
identified on ground surface
Fair
Fill material (gravel,
ceramic tiles,
terracotta tiles) some
grass cover
Access all
Road
N/A
Asbestos
cement
fragments
Some fragments identified in bare
patches
Fair
Sand and fill material
with grass cover
Access to
shooters
Shooting
range
N/A
Asbestos
cement
fragments
Some fragments identified in bare
patches
Fair
Sand and fill material
with grass cover
Access to
shooters
Shooting
range
N/A
Asbestos
cement
fragments
and barge
capping from
building
Some fragments identified on
nature strip. Broken AC barge
capping from building also
identified on ground surface
Fair
Sand and fill material
with grass cover
Access all
Road and
foot path
13
Type of
ACM
Description
Condition
Asbestos
cement
fragments
Some fragments identified in bare
patches
Areas
surrounding 3
buildings in
south west
corner of site
Asbestos
cement
fragments
Area south
west of care
takers
residence
Grassed area
between care
takers
residence and
road
Nature strip
area
surrounding
building
Photo
37
Large mound
east of riding
school
Asbestos
cement
fragments
Some fragments identified in bare
patches specifically adjacent to
horse jumps
Fair
Sand and fill material
with grass cover
Access to riders
Horse
track and
jumps
N/A
38
Main range Track running
around south
west perimeter
of the main
range
Main range Area north east
of ditch position of
model aircraft
parking
Asbestos
cement
fragments
Some fragments on road
Fair
Sand and Fill material
(gravel, ceramic tiles,
terracotta tiles)
Access to
shooters
Road
N/A
Asbestos
cement
fragments
Some fragments identified in bare
patches
Fair
Sand and fill material
with grass cover
Access to
shooters and
model aircraft
flyers
Car park
and
shooting
range
N/A
39
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Category
Area
Number
3
40
Main range Grassed area
east of central
road
3
41
3
42
Type of
ACM
Location
Soil Type & State of
Surface
Public/ site
users
Accessibility
Site
Activity
Photo
Description
Condition
Asbestos
cement
fragments
Some fragments identified in bare
patches
Fair
Sand and fill material
with grass cover
Access to
shooters and
model aircraft
flyers
Shooting
range
N/A
Main range area directly in
front of targets
Asbestos
cement
fragments
Some fragments identified in bare
patches
Fair
Sand and fill material
with grass cover
Access to
shooters
Shooting
range
NA/
Horse jump
area north of
paddocks
Asbestos
cement
fragments
Some fragments identified in bare
patches and specifically adjacent
to log jumps
Fair
Sand and fill material
with grass cover
Access to
shooters
Shooting
range
N/A
1
Restricted access – Access is not readily available to the public and land site users
2
Limited access – - Access is limited to walking tracks - limited vehicular access
The following table lists the areas were access was either limited or the areas were not non accessible.
Table 5-2
Accessibility
Area
Description
Access
Observation
A
Bush area to the west of the
site
No Access
No access to this area due to the thick scrub, cliffs and rocky outcrops to the east and fence
traveling around perimeter of area.
B
Ditch within main shooting
range.
No Access
No access due to thick vegetation and steep descent into area. Deemed unsafe to access.
C
Steep embankment north
west of site
No Access
No access due to thick vegetation and steep descent. Deemed unsafe to access.
D
North and north east
perimeter of site
No Access
No access due to thick vegetation and steep descents, fencing around pond area and
unknown position of cliffs. Deemed unsafe to access.
E
South east bush area.
Limited access
Limited access to area due to thick shrub throughout area. Only tracks, cleared areas and cliff
to the south east were accessed.
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6.
Asbestos related health risks
In order to contextualise a discussion on the asbestos related health risks to the public and
adjoining properties, a general commentary on asbestos disease risk is provided.
6.1
General
As discussed in Section 2, the three main diseases which may result from asbestos
exposure are asbestosis, lung cancer and mesothelioma.
The ACM’s observed at the ANZAC Rifle Range consisted most of fibrous cement products
and some textile materials. Chrysotile (white asbestos) would be the most likely asbestos
material used in these products.
The following discussion centres on the risk of developing asbestos related diseases from
exposure to chrysotile. It is emphasised that there is a great deal of uncertainty in estimating
asbestos disease risk. It involves the field of epidemiology, which is a branch of medical
science concerned with the occurrence and control of diseases in populations. The sort of
problems with risk estimates which arise include:

accurately assessing past exposures in various industrial occupations

accounting for fibre size (such as difference in fibre size between different chrysotile
industries, probably influences the degree of hazard and/or potency)

uncertainty regarding a threshold for disease

the high background level of lung cancer in the general population due to smoking.
Cases of lung cancer attributable to asbestos cannot be distinguished from those due to
smoking. Attribution can only be assessed in terms of excess of lung cancers above a
control population; hence the choice of control population is critical

the identification of the disease is dependent on medical diagnosis, however autopsies
are not always conducted.

problems with using data collected for high occupational exposures (in studies of mining
textiles industries etc, and extrapolating low-dose risk, the assumption being that there
is a linear relationship. However as insufficient data exists to indicate a threshold
exposure for effect, the linear extrapolation methodology provides a conservative worstcase scenario estimate of risk.
6.1.1
Asbestosis risk
In 1985 the Ontario Royal Commission suggested a threshold for asbestosis of 25 fibreyears (fibre.year/ml).
‘One fibre-year’ represents a daily exposure of 1 fibre/ml for a year. Therefore 25 fibre/mLyears represents an average daily exposure of 1 fibre/ml for a 25 years. Equivalent lifetime
doses or equivalent, for example, 0.5 fibre/ml for a 15 years or 5 fibre/ml for 5 years.
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6.1.2
Lung cancer risk
With respect to lung cancer, a linear dose–response relationship has been adopted for lung
cancer risk estimates at low exposures. This approach assumes that there is no threshold
below which there is no risk of asbestos-induced lung cancer.
However there are recent suggestions that there may be an exposure threshold for the
development of lung cancer from asbestos exposure.
NOHSC have reviewed the available epidemiological data on the risk of lung cancer
associated with chrysotile. It was decided that risk estimates in Australia should be based on
data from mining and friction product manufacturing industries.
Estimated risk of lung cancer at various levels of exposure to chrysotile exposure
(yearly average fibre/mL) (assuming mixed smoking habits and 40 years continuous
exposure)
1
Exposure (yearly average fibre/mL)
Excess risk (per 100,000 persons exposed)
1
173
0.5
86
0.1
17
1
Excess risk = Risk coefficient x lifetime exposure (yrs) x average exposure level (f/mL) x background risk* ,
[*A cumulative background risk for lung cancer in the male population was used in these calculations (i.e.,
7,200/100,000 assuming mixed smoking habits)].
It has been shown that smoking and asbestos act together to increase the overall risk of lung
cancer.
Cumulative exposure to 25 fibre-years (fibres.year/mL) is sufficient to cause lung cancer.
6.1.3
Mesothelioma risk
The type of asbestos fibre seems to be important in the development of mesothelioma.
Crocidolite and other amphiboles are most potent in the development of mesothelioma.
Chrysotile is generally considered to be a less potent carcinogen than amphibole fibres
(including crocidolite and amosite). Hodgson and Danton (2000) suggest that the ratio of
fibre potency to cause mesothelioma is a ratio of 1:100:500 for chrysotile, amosite,
crocidolite respectively.
It is also apparent that smoking doesn’t affect the development of mesothelioma.
A model to describe the risk of mesothelioma from asbestos exposure was developed Doll
and Peto 1985)
The model indicates that:

The risk from continuous exposure to levels that cause mesothelioma is mainly
determined in the first 10 years of exposure.

the risk of mesothelioma increases rapidly with continuous exposure up to 10 years,
slowly with increasing exposure for 10–19 years and then very little.
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 The mathematical equation derived by Doll and Peto to describe mesothelioma risk from
chrysotile exposure is as follows:

L(t) = 0.62 x 10
10
L[(t – t1)4 – (t - t2) 4] where:
a) I(t) is the incidence at a given age
b) L is the average exposure in fibre/ml
c) t1 is the age at first exposure
d) t2 is the age at the end of the exposure period
6.1.4
Screening guidelines for asbestos related disease
An international expert meeting was held in Finland (Helsinki) in 1997 concerning asbestos
related disease. A major outcome of this meeting was a consensus on attribution and
screening guidelines for mesothelioma, lung cancer and asbestosis, which included the
following;

brief, low level exposure was regarded as sufficient to cause mesothelioma;
 all fibres can cause mesothelioma, but amphiboles (crocidolite and amosite) are more
potent carcinogens than serpentine asbestos (chrysotile)

cumulative exposure to 25 fibre-years (fibres/year/mL) is sufficient to cause lung cancer;

asbestosis is not a necessary prerequisite for lung cancer;
6.1.5
Occupational exposure standards
Occupational exposure standards (OESs) for controlling workplace exposures to various
forms of asbestos have been developed by NOHSC (now known as Safework Australia).
The documentation provided by Safework Australia on the development of the occupational
exposure standards for asbestos is provided in Appendix F
By definition OESs represent airborne concentrations of individual chemical substances
which, according to current knowledge, should neither impair the health of nor cause undue
discomfort to nearly all workers. These standards do not represent ‘no effect levels’.
OESs are intended for the evaluation of hazards posed by atmospheric contaminants in the
working environment. They should not be used as a basis for the evaluation of community
air quality, or for long term, non-occupational exposures.
The OES for chrysotile is currently 0.1 fibres ml as an 8 hour TWA being reduced from 1.0
fibre/ml in July 2003.
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6.1.6
Risks in general
In order to contextualise risk in general, the following risks can be considered in the light of
risk as discussed in the following sections:

risk of being struck by lightning: 1 in 10,000,000 (one in ten million)

risk of death from homicide: 1 in 100,000 (one in hundred thousand)

risk of being dying in a plane crash: 1 in 20,000 (one in twenty thousand)

risk of death in road accident: 1 in 8,000 (one in eight thousand)

risk of death from smoking 10 cigarettes a day: 1 in 200 (one in two
hundred).
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Asbestos Survey and Assessment – Anzac Rifle Range, Malabar Headland New South Wales
7.
Air monitoring
7.1
Introduction
Airborne asbestos fibre concentrations are assessed using phase contrast optical
microscopy by the Membrane Filter Method (NOHSC:3003(2005)].
This method was originally developed for measurement of asbestos fibre concentrations in
circumstances where the airborne particles were predominantly asbestos fibres, such as in
industries handling asbestos during manufacture and use, and in asbestos removal work.
7.2
Limitations of the method
The analysis method involves the physical counting of fibres according to a particular size
criterion in 100 randomly-selected graticule fields for each filter comprising a sample. The
regulatory definition of a ‘fibre’ is any object which has an aspect ratio greater than 3:1, a
length greater than 5 µm and a width less than 3 µm.
The method does not distinguish between asbestos fibres and non-asbestos fibres (such as
clay minerals, iron oxide, gypsum, mica, hornblende and talc) or other particles conforming
to the size criteria for a fibre. As a consequence, assessment of “fibre” exposure using the
Membrane Filter Method will tend to overestimate true asbestos fibre concentrations.
7.3
Results
A series of background air monitoring tests were conducted across the site at six (6)
locations (refer Appendix D). These locations were chosen because these areas where
identified as being heavily contaminated with ACM.
The tests were undertaken during what could be considered to be a ‘normal’ day of activities
at the site i.e. shooting at the main range, horse riding activities and general public activities
The weather was fine and sunny with a slight to medium breeze coming from the east.
The concentration of respirable airborne fibres was well below the detection limit, 0.01 fibres
per millilitre of air for the monitoring method employed (based on the National Occupational
Health and Safety Commission’s Guidance Note on the Membrane Filter Method for
Estimating Airborne Asbestos Fibre [NOHSC:3003(2005)]).
The National Exposure Standard (NES) is 0.1 fibres/ml for airborne contaminants in the
occupational environment.
The results are well below the NES which provides some evidence that at the time of testing
the level of airborne asbestos fibres were no more than the normal background environment.
This occupational measure was used in absence of a non-occupational standard or
guidance. Refer also to Section 7.2 of this report for on-going monitoring recommendations.
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8.
Discussion
8.1
Asbestos in soil
8.1.1
Non-occupational environments
Non occupational environment can be categorised into the following:

asbestos products in and around the home
 demolition control by local government or private building surveyors in
some jurisdictions

land contaminated with asbestos

transport and disposal of asbestos.
The Malabar Headland site could be defined as a non-occupational environment and as
such asbestos management for the site should aim to employ protective control measures
for when ACM’s or deposits are disturbed.
Failure to control the potential release of fibres may result in short-term asbestos fibre levels
comparable to those seen in neighbourhood exposure.
Numerous studies have shown that due to the lack of accurate and reliable exposure data, it
has not been possible to determine an acceptable level of airborne asbestos in nonoccupational environments; therefore management strategies for an asbestos contaminated
site should aim to keep exposure to airborne fibres as low as reasonably possible.
Health risks from asbestos-containing materials in soil will depend on the potential for
asbestos fibres to be disturbed, become airborne and be inhaled.
If the material is readily accessible it may be vulnerable to disturbance by people, vehicles or
other activities. For example, vehicle movements or construction work may release the
fibres or generate dust.
Calculation of the concentration of asbestos in soil is extremely difficult, and is not
necessarily a reliable indicator of risk posed by the asbestos. The following needs to be
considered:
 Typically asbestos is bound within the cement sheet product. Loose asbestos fibres on
the broken edges and worn faces may be liberated into the soil and/or into the air when
disturbed.
 Loose fibres or free formed asbestos are considered the main risk as they have the
greatest propensity to become airborne (compared with bonded fibres within the main
body of the material).
 The risk posed by asbestos cement fragments is related to the surface area of the broken
edges and worn faces of the product, as well as the calculable size of fragments.
 The degradation of asbestos cement overtime is also a factor in the liberation of fibres
both into the soil and air.
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 Soil types, alkalinity/acidity, rainfall, exposure, and a combination thereof all contribute
unpredictably to the condition of the material.
With respect to the location, type and condition of the ACM’s that have been identified with
the boundaries of the Malabar Headland site, there would be no significant migration of
asbestos fibres through the soil, other than possibly from excessive disturbance of the soil
caused by uncontrolled human activities or major geological disturbance.
8.2
Risk
Any circumstance or activity that has the potential to disturb ACM may lead to increased
dispersal of fibres into the air. If the material is readily accessible it may be vulnerable to
accidental or deliberate disturbance or damage.
Asbestos in soil does not present a risk unless it is disturbed and asbestos fibres become
airborne. The concentrations of asbestos fibres in air cannot be reliably estimated from
asbestos in soil concentrations. Thus, in managing risk posed by asbestos in soil the
following needs to be considered:

proposed land use;

potential for generation of airborne asbestos fibres;

available remediation techniques and costs;

community/industrial relation issues associated with asbestos; and
 possible long term health issues arising through poor on-going management of the
hazard.
Where asbestos fibres are present in low concentrations and are bound within a stable
material, such as asbestos cement, they are less likely to generate dangerous levels of
airborne fibres than where they are friable.
The type of asbestos is also important. In most non-occupational environments the main
asbestos contaminant is chrysotile
Based on the current air monitoring results, it is considered that risk of exposure above
national exposure standards is low, if not negligible, if the ACM’s are left undisturbed.
However, since some of the contaminated areas are accessible to the public, human
disturbance of the asbestos cement debris is possible and therefore the level of risk will
possibly increase.
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9.
Recommendations
The following site recommendations are consistent with the general guidelines present in the
enHealth document titled Management of Asbestos in the Non-occupational Environment,
2005 together with the experience of PB.
Due to the large area and estimated volumes of buried waste(s), the removal of ACM’s from
the site would be considered impractical from both a cost and logistical perspective.
To achieve this it would be necessary to either remove and dispose of all fill material and
waste from the site or excavate all fill material and undertake a comprehensive asbestos
screening program. Both these options are likely to involve significant cost.
9.1
Short term management
9.1.1
Stakeholder Management
Stakeholders should be informed as soon as possible that asbestos is on-site
An Asbestos Management Plan should be developed taking into account the needs of the
different legal users of the site
Stakeholder groups should be consulted during the development of the Surface Asbestos
Management Plan
9.1.2
Remediation / Cleanup
It is strongly recommended that an immediate and thorough surface cleanup (‘emu-picking’)
is undertaken to remove loose fibrous cement fragments from the ground surface of the
following areas:
 Area 13 – due the amount of ACM fragments noted and the high rate of site activity
(Horse Riding Club).
A remedial action plan that allows for the cleanup and removal within 3 months should be
developed and implemented for those areas placed into Category 1 (of which there are 17).
Although category 2 areas have limited accessibility, the increased risk associated with
identifying friable asbestos within the ‘fly tipped’ material means that a remedial action plan
that allows for the cleanup and removal within 3 – 6 months should be developed and
implemented in these areas (of which there are 3).
Due to the infrequent use and low impact activity undertaken within these areas, a remedial
action plan that allows for the cleanup and removal within 12 months should be developed
and implemented for those areas placed into Category 3 (of which there are 20).
It is recommended that a bonded asbestos licensed contractor is engaged to carry out the
work, using four to five suitably trained people to form a line and sweep the areas in a
systematic fashion. All work is to be carried out in accordance with the following Codes and
NSW Acts and regulations:
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 The Approved Code of Practice for the Management and Control of Asbestos in the
Workplace [NOHSC:2018 (2005)].

The Approved Code of Practice for the Safe Removal of Asbestos. 2nd Edition
[NOHSC:2002(2005)].

NSW Occupational Health and Safety Act 2000.

NSW Occupational Health and Safety Regulation 2001.

NSW Protection of the Environment Operations Act 1997

NSW WorkCover requirements.
Environmental air monitoring is recommended during the cleanup process to provide
demonstrable evidence that the activities associated with the cleanup do not generate
airborne asbestos fibres above national exposure levels (based on collecting loose materials
only and appropriate risk controls).
9.2
Ongoing management
9.2.1
Asbestos management plan
Based on the findings of the survey and inspection of the Malabar Headland, there is a need
to develop and implement an Asbestos Management Plan (AMP).
The purpose of the AMP is to manage contamination on the site in a manner that protects
human health and the environment.

The short term goal is to minimise the risk to human health.

The medium-term goal is to minimise the risk to human health and the
environment.
 The long term goal of implementing an AMP is to minimise the environmental liability of
the impact by either control, containment, removal or a composite of these methods.
The AMP will need to capture all aspects of the management process so that both the
perceived and potential health risks are managed in a manner that is acceptable to all
stakeholders.
One of the most critical aspects in the implementation of the AMP is the consultation
process.
The understandable stakeholder concern regarding asbestos health risks demands that high
quality consultation is undertaken for asbestos removal projects.
There have been recent examples where such consultation has been less than thorough,
leading to significant project problems. It should also be recognised that consultation will
create an informed community, who will therefore expect high standards to be employed
during asbestos removal projects and the ongoing management of the site.
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The AMP will describe the most appropriate strategy for the management and remediation of
the identified site contamination.
The development of the AMP will help ensure that there are implementation management
systems which will minimise the future potential risk to health from ACM’s.
9.2.2
Objective
Objectives of the Asbestos Management Plan are to:
 provide an approach through which the ACM debris and other identified contaminates
can be safely managed
 assigns the responsibilities for asbestos management at the sites
 provide effective management of the potential health risks
 detail the procedures for any remediation activities in the short term and any future
remedial activities
 ensure that all future activities are managed in a manner that will not adversely impact
the ongoing use of the site.
9.3
Additional management options
In addition to the development and implementation of the AMP, it is recommended that
regular inspections (suggested 3-6 monthly intervals) for those areas where large amounts
of ACM’s have been identified.
Review inspections should also be considered immediately post any significant storm /
weather activity or post significant environmental disturbance/erosion. Clean up work should
coincide with independent inspections and assessments by a competent consultant.
Programmed air monitoring on a monthly basis for twelve months is recommended to
monitor over a greater period of time whilst encompassing broader environmental conditions
(e.g. seasonal variations, wind direction changes, etc). Increasing the sampling data
obtained over this period militates against the once off ‘snapshot’: results obtained to date
and demonstrates on-going assessment and hazard management.
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10.
Conclusions
The observations made during the visual site inspection has shown that due to a
combination of the site being utilised as a landfill and the extent of “fly tipping” that was
observed, the extent of both surface contamination and buried ACM’s varies significantly
across the Malabar Headland.
Across the site, the degree of ACM contamination varies from fragments of ACM that are
clearly visible of the surface, fragments of ACM that will be present just below the subsurface (0-100mm BGL) and ACM fragments and ACM waste that has been buried as part of
the sites previous landfill activities.
It is also very likely that other and varied amounts of buried wastes could be located
throughout the site that could not be visually observed during the inspection.
The areas on the site where ACM’s and contamination have been observed have been
divided into the following three (3) categories:
 Category 1: areas were fly tipping has occurred;
 Category 2: areas were small volumes of fibrous cement fragments were identified <10
fragments/ 100m2; and
 Category 3: areas were significant volumes of fibrous cement fragments were identified
>10/100m2.
It has been presumed that the ACM fragments identified in Category’s 2 and 3 were initially
buried within the fill and have migrated to the ground surface through a combination of time,
ineffective burial and cover methods, continual exposure to the elements (soil erosion) and
from a variety of activities such as vehicle movement, horse and foot traffic.
Based on the current air monitoring results, it is considered that risk of exposure above
national exposure standards is low, if not negligible, if the ACM’s are left undisturbed.
The implementation of a short term management plan to clean up the visual occurrences of
ACM i.e. emu pick - will certainly address the immediate risks and existing aesthetic issues.
However, continued surface soil erosion issues due to ongoing activities and site usage may
continue to bring more ACM debris to the surface and therefore without the implementation
of major remedial works and excavation to remove the large volume of buried wastes
(estimated to be 1.4 million m3), continued site management will be required for the
foreseeable future.
A longer term management plan for the site will address issues associated with the ACM to
minimise the environmental liability of the impact by either control, containment, removal or a
composite of these methods.
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11.
Relevant NSW legislation
The following information is provided as it relates to the relevant NSW Legislation and
Regulations that are applicable and to which any current and / or future activities may be
affected by the ACM contamination on the site.
This would include any remedial works or activities that may cause disturbance of the soil.
 NSW Occupational Health and Safety Act 2000
 NSW Occupational Health and Safety Regulation 2001
 NSW Protection of the Environment Operations Act 1997
 Code of Practice for the Management and Control of Asbestos in Workplaces [NOHSC:
2018 (2005)]
 Code of Practice for the Safe Removal of Asbestos 2nd Edition [NOHSC: 2002 (2005)].
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