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RFI - Attachment E - Acid Sulfate Soil Management Plan · MCU25/0053
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Acid Sulfate Soil Management Plan
PTG/01608 – 0002 – Rev 0
Proposed Residential Development
7 Noosa Parade, Noosa Heads
11 April 2025
www.ptgconsulting.com.au
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REPORT DETAILS
Unique Document Identification
Document Title Acid Sulfate Soil Investigation Management Plan - Proposed Residential Development
Project Number PTG/01608
Document ID PTG/01608 – 0002 – Rev 0
Client SCG Consulting Engineers
Client Contact Tom Harrington
PTG Office Details
Location Gold Coast
Address U3/36 Blanck Street, Ormeau, QLD, 4208
Telephone 1300 911 304
Email [email protected]
Web www.ptgconsulting.com.au
Revision Details
Revision No. Date Comments
1 11th April 2025 Final
Document Approval
Written By:
Russell Howchin
Senior Geoscientist
p | 0408 754 631
e | [email protected]
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1 REPORT SCOPE 4
2 PROJECT DESCRIPTION 4
3 SUBSURFACE CONDITIONS 4
CONTENTS 4 LABORATORY TEST RESULTS 4
5 SUMMARY 5
5.1 Soils 5
5.2 Groundwater 5
5.3 Acid Sulfate Soil Management Plan 5
5.3.1 Background 6
5.3.2 Recommended Management of Acid Sulfate Soils & Groundwater 6
5.3.3 REFERENCES 9
6 LIMITATIONS 10
TABLE
Table 1: Acid Sulfate Soil Management for Proposed Site Earthworks ...........................................................................6
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1 REPORT SCOPE
This report presents the Acid Sulfate Soil Management Plan produced for the proposed residential development at 7 Noosa
Parade, Noosa Heads (the ‘site’).
The work was commissioned by SCG Consulting Engineers Pty Ltd (the ‘Client’).
Please note that a geotechnical investigation including Acid Sulfate Soil (ASS) investigation has also been produced and it is
recommended that the following document is read in conjunction with this report:
» ‘Geotechnical Investigation Report – Proposed Residential Development – 7 Noosa Parade, Noosa Heads’, Document ID
PTG/01608-0001-Rev 0, dated 28/02/25 (herein referred to as the ‘PTG Geotechnical Investigation Report’)
The PTG Geotechnical Investigation Report included a field investigation and laboratory testing of selected samples undertaken
in general accordance with PTG’s proposal PTGT/01451/Rev 0. Please refer to this report for information regarding site
description, borehole locations, borehole record sheets, and laboratory test results. It is intended that this Acid Sulfate Soil
Management Plan and report is read in conjunction with the PTG Geotechnical Investigation Report.
This Acid Sulfate Soil Management Plan and report includes a summary of the subsurface profile information and laboratory
test results from the PTG Geotechnical Investigation Report, which was based on the drilling of four boreholes to a depth of
4.5 m.
The results of the PTG Geotechnical Investigation Report indicated the presence of Acid Sulfate Soil (Potential Acid Sulfate Soil).
On this basis, an Acid Sulfate Soil Management Plan is required.
This Acid Sulfate Soil Management Plan and report has been produced in accordance with the following documents:
» Noosa Plan 2020 Acid Sulfate Soils Overlay Code;
» National Acid Sulfate Soils Guidance – National Acid Sulfate Soils Sampling and Identification Methods Manual, June, 2018
(Australian Government Department of Agriculture and Water Resources, Canberra ACT. CC BY 4.0) (herein referred to
as the ‘Acid Sulfate Soils Sampling and Identification Manual’) ;
» Queensland Acid Sulfate Soil Technical Manual – Soil Management Guidelines Ver 5.1 (Department of Resources and
Department of Environment, Science and Innovation, Queensland, 2024)
2 PROJECT DESCRIPTION
Based on the information provided by the Client, it is understood that the proposed development will include the excavation of
a single level basement over an area of 471 m2 with two residential levels above ground.
3 SUBSURFACE CONDITIONS
The subsurface conditions in the PTG Geotechnical Investigation Report boreholes beneath the paver surface typically
comprised silty sand fill extending to the termination depths of 4.5 m.
Groundwater seepages were not encountered in the boreholes. However, as a precaution, information regarding groundwater
management is included in the Acid Sulfate Soil Management Plan.
The presence and depth to groundwater is dependent on the Noosa River water level, rainfall and subsurface material type and
permeability.
4 LABORATORY TEST RESULTS
The laboratory test results from the PTG Geotechnical Investigation Report included both pH screening and Chromium
Reducible Sulfur tests.
The results of the pH screening tests typically indicated the presence of Acid Sulfate Soils (Potential Acid Sulfate Soils) in several
samples.
On this basis, Chromium Reducible Sulfur tests were carried out.
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The highest Chromium Reducible Sulfur test result was associated with the sample taken in borehole BH3 at a depth of 3.75 m-
4 m which had a net acidity value of 128 mol H+/t.
Assuming a maximum excavation depth of 3.5 m for the single level basement, the highest Chromium Reducible Sulfur test
result was associated with the sample taken in borehole BH2 at a depth of 2.25 m-2.5 m which had a net acidity value of 90 mol
H+/t, equating to a lime treatment rate of 7 kg/tonne based on a Factor of Safety of 1.5.
5 SUMMARY
Recommendations regarding soil management are outlined in Section 5.1.
Recommendations regarding groundwater management (where required) are described in Section 5.2.
General information regarding the Acid Sulfate Soil Management Plan is provided in Section 5.3.
5.1 Soils
Based on the soil test results, it is recommended that:
» The earthworks are managed by a reputable and suitably qualified consultant experienced in the field of Acid Sulfate Soils
and treatment;
» Soils excavated below RL 5 m AHD in the existing fill profile will require lime treatment;
» As an alternative to lime treatment of excavated soils, the excavated soils may be transported offsite untreated, where
disposed of at a suitably licenced landfill facility which is able to accept untreated Acid Sulfate Soil. The Acid Sulfate Soil
may still require lime treatment once placed at the landfill facility which would be required to be checked.
Refer to the Acid Sulfate Soil Management Plan in Section 5.3 for further information regarding lime treatment rates and
general earthworks recommendations.
5.2 Groundwater
Where groundwater is expected or seeps into the excavation, groundwater monitoring must be carried out.
Groundwater must be monitored before, during and after earthworks for groundwater level, pH, Electrical Conductivity, and
Iron (Fe) & Aluminium (Al) content (dissolved and total analyses).
Refer to the Acid Sulfate Soil Management Plan in Section 5.3 for further information regarding groundwater monitoring.
5.3 Acid Sulfate Soil Management Plan
Acid Sulfate Soil in the form of Potential Acid Sulfate Soils were encountered in the tested soil samples based on an analysis of
the results in the PTG Geotechnical Investigation Report. An Acid Sulfate Soils Management Plan (ASSMP) has been
produced as 11 of the 18 tested soil samples breached the ‘action criteria’ as described in the ‘Acid Sulfate Soil Sampling and
Identification Manual’.
This Acid Sulfate Soils Management Plan (ASSMP) must be followed where soil disturbance below RL5m AHD and soil lime
treatment is carried out as part of earthworks for the proposed basement at the site.
If soil-lime treatment is carried out offsite, site specific ASSMP’s must be followed where they exist, otherwise this ASSMP
must be used. Discussions between the site contractor and the owner/s of the soil disposal site must be carried out. This
ASSMP should be sent to the Noosa Shire Council for potential further comments and for final approval. This should be done
before any earthworks or soil disturbance is carried out at the site.
Based on the information provided by the Client, it is understood that the proposed development will include the excavation of
a single level basement over an area of 471 m2 and two residential levels above ground. Assuming an estimated soil bulk density
of 1.7 t/m3, it is estimated that 800 t of soil will be excavated below RL 5 m AHD.
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In accordance with the ‘Queensland Acid Sulfate Soil Technical Manual – Soil Management Guidelines Version 5.1’ (Qld
Government, 2024), a “Very High Level of Treatment” is required at this site based on:
» Approximately 800 tonnes of soil to be disturbed below RL 5 m AHD; and
» Highest recorded net acidity value of 90 mol H+/t in the ground surface to 3.5 m depth range.
As a “Very High Level of Treatment” is required, an Environmental Management Plan and closure report are also required in
accordance with the information presented in the ‘Queensland Acid Sulfate Soil Technical Manual – Soil Management
Guidelines Version 5.1’.
An experienced, competent and suitably qualified soil scientist or engineer must be present onsite to ensure that the lime
treatment activities including validation testing, and groundwater monitoring (where required), described in this ASSMP are
followed onsite.
5.3.1 Background
It should be noted that Acid Sulfate Soils are typically observed in the field as a grey, or dark grey brown to black soil in colour,
sometimes with a yellow mottle. Acid Sulfate Soils may also emit a hydrogen sulfide (‘rotten egg smell’) gas/odour, especially
when the soil is disturbed such as during earthworks and excavation operations.
The aims of the ASSMP are as follows:
» Analysis of the data from the investigation and assess the severity of Acid Sulfate Soil within the project area and formulate
a suitable lime treatment regime for the soils to be disturbed by earthworks, and reduce the potential for acid generation
due to the site earthworks; and
» Monitor groundwater (where encountered) during earthworks.
In order to reduce the potential for acid generation due to the proposed earthworks, soil treatment and groundwater
monitoring (where required) should be carried out in accordance with the information presented in Section 5.3.2 of this
ASSMP as follows.
5.3.2 Recommended Management of Acid Sulfate Soils & Groundwater
The proposal to manage Acid Sulfate Soil and groundwater (as required) as part of the planned site earthworks below
RL 5 m AHD covers the following issues, which are detailed further in Table 1.
Table 1: Acid Sulfate Soil Management for Proposed Site Earthworks
Issue: Acid Sulfate Management and Treatment, Groundwater Monitoring and Potential Treatment
Operational Policy: To effectively manage the Acid Sulfate Soils and groundwater at the site and avoid any adverse
environmental impacts before, during and after site earthworks.
Performance » Validation sampling indicates that the appropriate treatment procedures have been employed
Criteria: such that results of these tests do not exceed the Action Criteria levels of 18 mol H+/tonne,
assuming that more than 1000 tonnes of soils are disturbed below RL 5 m AHD.
» Groundwater should be monitored for depth/level, pH, Electrical Conductivity, aluminium
content and iron content, before, during and after the earthworks period. On site performance
criteria for water monitoring should be based on the Queensland Water Quality Guidelines 2009
(revised in 2013), herein referred to as the ‘QLD DEHP Guidelines’ (DEHP, 2013). For any
parameter values not covered in the QLD DEHP Guidelines, refer to the Australian and New
Zealand Guidelines for Fresh and Marine Water Quality (ANZECC and ARMCANZ, 2000).
Soils: Based on the soil test results, it is recommended that:
» The earthworks are managed by a reputable and suitably qualified consultant experienced in the
field of Acid Sulfate Soils and treatment.
» Soils excavated below RL 5 m AHD in the existing fill profile will require lime treatment. The lime
treatment rate for soils excavated in the existing fill profile is 4 kg/tonne (6.8 kg/m3). The values
presented as kg/m3 assume a bulk density conversion factor 1.7 t/m3.
» A bulk density factor will be required to convert from kg/tonne to kg/m3. A bulk density
conversion factor of 1.7t/m3 has been used in the absence of soil test results, however it is
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Soils (continued): recommended that density testing of the soil is carried out to provide a better estimate of the in-
situ soil density.
» As an alternative to lime treatment of excavated soils, the excavated soils may be transported
offsite untreated, where disposed of at a suitably licenced landfill facility which is able to accept
untreated Acid Sulfate Soil. The Acid Sulfate Soil may still require lime treatment once placed at
the landfill facility, to be checked with the site owner.
» If onsite materials won from cuts below RL 5 m AHD are to be used as fill, these soils will be
required to be lime treated and validated to ensure that the soil acidity has been neutralised prior
to placement as fill.
» Note that higher Acid Sulfate Soil contents and soil lime treatment rates may be encountered
within the untested soils between the small diameter boreholes tested. This must be understood
by the contractor before excavations are carried out.
» If soil is to be disturbed below the depths tested, or outside the areas tested as indicated in this
report, further soil testing will be required prior to earthworks to confirm treatment requirements.
» Soils excavated below RL 5 m AHD are to be adequately treated with lime at the recommended
rates on a lime pad constructed either at the site or offsite so as to achieve neutralisation. All
materials to be treated must be thoroughly mixed in thin layers typically less than 300 mm
thickness with a rotary hoe or similar device. The lime pad is to be prepared by compacting a clay
layer typically 300 mm thick, then constructing earth bunds around the perimeter using soils
known to be free of Acid Sulfate Soils. Finally, a ‘lime guard layer’ is to be placed at a rate of
5 kg/m2/300 mm layer of stockpile. The treatment area must be located away from surface water
flow paths. Refer to Figure 1 found later in this ASSMP to observe an example treatment pad
section.
» The contractor responsible for soil lime treatment needs to ensure the soils are adequately and
properly treated with lime to ensure neutralisation.
» Once the soils are treated with lime, audit/validation testing must be carried out to ensure that
the soils have been neutralised. Acid Sulfate Soils which are not neutralised during the first round
of soil lime mixing will require a second round of treatment by adding lime to the soils at rates
based on the results of the validation testing. Refer to the ‘Validation Testing’ section of this
ASSMP for further information. Validation testing must be carried out prior to removal of the soils
from the site, or replacement at the site.
» Provide earth bunds constructed using materials known to be free of Acid Sulfate Soil at locations
surrounding the earthworks/development area so as to reduce the potential of surface water
running off the site.
» 0.5 kg of lime/m2 will be applied to the base of all excavated areas to ensure ‘hotspots’ or isolated
areas not tested are neutralised.
» A lime spray will be used on excavation faces using a nominal lime:water ratio.
» 500 kg of agricultural lime must be kept on site at all times in case of emergency treatment.
» The pH of any water collected within bunds or sumps is to be monitored. A pH value of between
6 and 8 is to be maintained before release or reuse onsite. Note that the results of the pre-
excavation groundwater pH testing may indicate a pH value outside this range which may be
deemed as a ‘natural’ value based on the assessment of a suitably qualified and competent
groundwater consultant. Further water criteria may apply based on Noosa Shire Council
requirements and this should be checked.
» It is noted that construction materials may need to be suitably protected from the acidic soil
environment. A suitably qualified and competent corrosion engineer should be contacted for
further advice.
Groundwater: Although groundwater was not encountered in the boreholes drilled as part of the PTG Geotechnical
Investigation Report, information is provided regarding groundwater monitoring as a precaution.
Depending on the earthworks duration and timeline, earthworks may be carried out during wet
weather periods and groundwater may rise and develop further within the soil profile. The
groundwater level may also be affected by the water level in Noosa River adjacent to the site.
Groundwater monitoring is recommended to check that the earthworks do not adversely affect
groundwater.
Where guideline values are provided, on site performance criteria for groundwater monitoring should
be based on the QLD DEHP Guidelines. For any parameter values not covered in the QLD DEHP
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Groundwater guidelines, refer to the Australian and New Zealand Guidelines for Fresh and Marine Water Quality
(continued): (ANZECC and ARMCANZ, 2000).
The groundwater should be monitored before, during, and after earthworks have been completed,
based on the following test criteria:-
» Groundwater testing should be carried out before the earthworks begin to establish baseline
testing values for groundwater level, pH, Electrical Conductivity, aluminium content and iron
content. Pre-development ‘baseline’ values should be recorded by a suitably qualified and
competent consultant as close as possible to, and before the first day of earthworks.
» Groundwater will be required to be monitored for groundwater level, pH, Electrical Conductivity,
aluminium content and iron content during the earthworks period, and prior to discharge from the
site.
» A groundwater sample should be obtained by a suitably qualified and competent groundwater
consultant as soon as possible after the earthworks period has been completed to monitor any
change in the groundwater level, pH, Electrical Conductivity, aluminium content and iron content.
» Groundwater pH should be monitored on daily basis and prior to discharge, and range between
pH 6 and pH 8 (‘National Acid Sulfate Soils Guidance – National acid sulfate soils sampling and
identification methods manual, June, 2018’, Australian Government, 2018), unless an assessment
by a suitably qualified and competent groundwater consultant deems there to be an alternative
‘natural/baseline’ range which can be used.
» Electrical Conductivity (EC) should be monitored on a daily basis and prior to discharge, and
should be less than 520 µS/cm (QLD DEHP, 2013).
» Dissolved and Total Aluminium (Al) content monitored on a weekly basis and prior to discharge,
and should be less than 0.055 mg/L (ANZECC and ARMCANZ, 2000).
» Dissolved and Total Iron (Fe) content monitored on a weekly basis and prior to discharge, and
should be less than 0.3 mg/L (ANZECC and ARMCANZ, 2000).
» It is recommended that a suitably qualified and competent groundwater consultant be contacted
for further information on groundwater testing, monitoring and any treatment requirements
before earthworks are carried out on the site, and where the groundwater test results do not meet
the required test criteria.
» Specific groundwater monitoring criteria may need to be achieved to satisfy Noosa Shire Council
before water is discharged offsite and this should be checked.
» Specialist, competent and suitably qualified groundwater consultants should be contacted prior
to the proposed earthworks and any dewatering.
» As a precaution, excess agricultural lime should always be kept as a standby measure to treat any
acidic groundwater produced during earthworks. Hydrated lime is not recommended for
groundwater treatment, as this material can have adverse effects on water such as producing
highly alkaline groundwater with pH levels greater than pH 9 or pH 10. A suitably qualified and
competent groundwater consultant should be contacted should groundwater pH or other
groundwater monitoring test results suggest that groundwater treatment is required.
Monitoring: Three phases of Acid Sulfate Soil testing will be undertaken:
» Phase 1 – In-situ testing (completed).
» Phase 2 – Groundwater level and pH monitoring before, during and after earthworks (where
required), and
» Phase 3 – Validation testing of lime-treated material.
Areas exposed during the development shall be monitored daily for evidence of iron staining of soils
and water, yellow efflorescence on soil surface, sulfurous odours (“rotten egg gas”) and low soil pH.
Once the soil excavated as part of the proposed earthworks below RL 5 m AHD is lime treated at the
required rates, a suitably qualified and competent environmental or geotechnical consultant is to be
contacted to ensure validation sampling and testing of the lime treated soil is carried out. This process
ensures that the lime has been thoroughly mixed through the Acid Sulfate Soil and that the acidity has
been neutralised. Once the lime treated soil is validated, it may be transported or used offsite, subject
to further contamination, geotechnical or other quality testing as required.
Refer to the ‘Validation’ section of this ASSMP for further information on validation testing.
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Reporting: The site contractor should keep lime dockets to ensure that a record is kept onsite of all lime quantities
brought on to site – a copy may be taken to prevent fading of original invoices/weighbridge dockets
as required.
All records will be available for inspection on site during earthworks.
Corrective Action: If Phase 2 daily groundwater monitoring indicates a change in acidity conditions during earthworks,
groundwater treatment may be required. In this case, a suitably qualified and competent groundwater
consultant should be contacted for further information.
If Phase 3 sampling indicates that the excavated material has not been fully neutralised, additional
lime will be applied based on the Phase 3 test results until the material passes subsequent validation
testing.
Lime Guard Layer:
Acid Sulfate Soil
(300mm layer)
Bund Wall
Lime Guard Layer
(5kg/m2/300mm
layer)
Leachate Drain
Compacted
Clay Layer
(300mm thick)
Figure 1 – Acid Sulfate Soil treatment pad design
Validation Testing: » Validation/audit testing must be carried out once lime is thoroughly mixed with the Acid Sulfate
Soil at the recommended rate. This testing will ensure all acidity has been neutralised and excess
neutralising capacity is available and reported. Dockets for lime (neutralising agent) must be kept.
An audit report shall be written at the completion of earthworks by a competent and qualified
consultant.
» The recommended laboratory method to ensure there is sufficient lime to neutralise the acidity is
the Chromium Reducible Sulfur (SCR) method. On the basis that no more than 471 m3 of soil will
be disturbed below RL 5 m AHD, a total of three SCR tests are recommended to be carried out on
excavated and lime treated soil. The final number of tests will be dependent on the total
disturbance volume below RL 5 m AHD based on the following (<250 m3 = two samples; between
250 m3 and 500 m3 = three samples, >500 m3 and <2% Sulfur = three samples, plus one sample
per additional 500 m3).
» All soil samples will be collected by a qualified person and delivered to an approved laboratory for
analysis. A minimum factor of safety of 1.5 is to be used to ensure that there is an excess amount
of acid neutralising capacity in the lime treated soil, and to account for incomplete lime mixing.
» It should be noted that the results produced from validation testing may reveal acidic soils or soils
with excessive lime content (an excessively alkaline soil). Proper care taken during soil lime
mixing should ensure that this risk is reduced.
» An Acid Sulfate Soils ‘closure’ report will be required in accordance with the ‘Queensland Acid
Sulfate Soil Technical Manual – Soil Management Guidelines Ver 5.1’ (Qld Government, 2024)
after the earthworks are complete.
5.3.3 REFERENCES
Australian Government, 2018. ‘National Acid Sulfate Soils Guidance – National acid sulfate soils sampling and identification
methods manual, June, 2018’. Department of Agriculture and Water Resources, Canberra ACT. CC BY 4.0.
ANZECC & ARMCANZ, 2000. ‘Australian and New Zealand Guidelines for Fresh and Marine Water Quality – Volume 1, The
Guidelines’. National Water Quality Management Strategy Paper No 4, Australian and New Zealand Environment and
Conservation Council & Agriculture and Resource Management Council of Australia and New Zealand, Canberra.
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QLD DEHP, 2013. ‘Queensland Water Quality Guideline Version 3, 2013’. Queensland Department of Environment and
Heritage Protection, Brisbane, QLD
Qld Government, 2024. ‘Queensland Acid Sulfate Soil Technical Manual – Soil Management Guidelines Ver 5.1’. Department of
Resources and Department of Environment, Science and Innovation, Queensland.
6 LIMITATIONS
PTG Consulting has prepared this report (or services) for this project in accordance with PTG's proposal and acceptance
received from the Client. These limitations apply whether the report was created under PTG’s own terms and conditions or
otherwise.
This report is provided for the exclusive use of SCG Consulting Engineers for the Acid Sulfate Soil investigation scope of works
and proposed residential development at 7 Noosa Parade, Noosa Heads. The report should not be used by or relied upon for
other projects or purposes on the same or other site or by a third party. Any party so relying upon this report beyond its exclusive
use and purpose as stated above, and without the express written consent of PTG, does so entirely at its own risk and without
recourse to PTG for any loss or damage. In preparing this report, PTG has necessarily relied upon information provided by the
client and/or their agents.
PTG's advice is based on information gained from limited subsurface excavations and sampling supplemented by knowledge of
local geology and experience. The accuracy of the advice provided by PTG in this report may be affected by undetected
variations in ground conditions across the site between and beyond the sampling and/or testing locations. For this reason our
reports include an interpretation of conditions between the test points. There are unknowns or variations in ground conditions
between test locations that cannot be inferred or predicted. Such variations may occur after PTG's field testing has been
completed. The precision and reliability of interpretive assessment between discrete points is dependent on the uniformity of
the subsurface strata, as well as the frequency, detail, and method of sampling or testing.
Geotechnical information represents an opinion and is based extensively on judgment of both data and interpretive assessments
or observation. This report and its associated documentation are provided explicitly based on PTG’s opinion of the site at the
time of inspection, and cannot be extended beyond this. Any recommendations or design suggestions will need to be verified
on site during project implementation or construction. Inspection and verification on site may be conducted by a suitably
qualified geotechnical consultant or engineer, and where subsurface conditions or interpretations differ from those provided in
this document or otherwise anticipated, PTG must be notified and be provided with an opportunity to review the
recommendations.
The report has been prepared by qualified personnel, and is based on the information obtained from field and laboratory testing,
and has been undertaken to current engineering standards of interpretation and analysis. The information and interpretation
may not be relevant if the development proposal is changed. If this happens then PTG Engineering will be pleased to review the
report and the sufficiency of the investigation work.
Every care is taken with the report as it relates to interpretation of subsurface conditions, and the discussion and
recommendations or suggestions relating to the geotechnical aspects of the scope of works. However, PTG Engineering cannot
always anticipate or assume responsibility for:
» Unexpected variations in ground conditions.
» Changes in policy or interpretations of policy by statutory authorities.
» The actions of contractors responding to commercial pressures.
The contents of this report do not constitute formal design components, as required by Health and Safety Legislation and
Regulations, to be included in a Safety Report specifying the hazards likely to be encountered during construction and the
controls required to mitigate risk. This design process requires risk assessment to be undertaken, with such assessment being
dependent upon factors relating to the likelihood of occurrence and consequences of damage to property and to life. This, in
turn, requires project data and analysis presently beyond the knowledge and project role respectively of PTG.
This report must be read in conjunction with all of the attached documents and should be kept in its entirety without separation
of individual pages or sections. PTG cannot be held responsible for interpretations or conclusions made by others unless they
are supported by an expressed statement, interpretation, outcome, or conclusion stated in this report.
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