Thursday 13th
March 2003


Robin Saunders

  CICCC / Chairperson

John Luppino

  City of Maribyr, GM City Dev /committee

Carlo Fasolino

 State Man. Terminals P/L / committee

Paul Hayward

 Operations Man.
Terminals P/L

Ian Thomas

 community rep./ CICCC committee

Dr Peter Brotherton

 Combined Enviro. Groups / committee

Deborah Macfarlane

  community rep./ committee

Michael Isaachsen 
 community rep./ committee

Jim Clements

Protection Authority/ex off comm

Bronwyn Brookman Smith

 MH Div / WorkSafe/ex
off comm

Quentin Cooke

 Env. Protection Authority / ex off comm

Trevor Perkins

  MF&ESB / ex off comm

Sarah Coward

 City of Maribyrnong/Councillor

Alex Mikov


Mark Stevenson


Elizabeth Attard

  standin minute taker



* Robin welcomed the committee members and the other people attending the CICCC. 

Introductions made during course of the meeting:

The new participants were introduced to the committee – Paul Hayward is a chemical engineer who has been with Terminals for approximately 3 years and had worked on site maintenance during that time. Alex Mikov and Mark Stevenson from ERM, consultants hired by Terminals, and Elizabeth Attard from Terminals is standing in as minute taker for Vanessa.


* Apologies received from Faye Simpson, George Horman, Vanessa Richardson,
Margaret Donnan and Jarrod Edwards


* The draft agenda was adopted.

ITEM 4: Appreciation to Sarah Coward (City of Maribyrnong-Retiring Councillor)

Robin expressed the committee’s appreciation to Sarah Coward for her good work in helping to establish the committee and representing Council on the Committee in its first few months. Ian complimented Sarah on her brilliant work as Chairperson at the beginning. As the Mayor in the year of the committee’s inception Sarah was instrumental in setting up the committee which has now been in operation for 6 years. Sarah was not standing for re-election as a Councillor at

Sarah expressed her delight at being at the meeting and mentioned how necessary the establishment of the committee was and that the committee’s work had made an impact on the management of hazardous materials in the community. She felt that new members would help to regenerate the committee, and that the council had a role to play advising that co-operation and participation would help to achieve safe outcomes.


Robin asked if all members had received both copies that had been sent to them. Response was in the affirmative

Trevor advised that the MFB would be making comments on the report to the appropriate parties for consideration, which would be completed over the next couple of days.

Robin stated that this would be the last time to deal with it and that if the MFB had further comments that these should be directed to Terminals and the EPA.

Peter expressed his concern with the signing off the report at this stage if it was to be modified in 2 days time.

Trevor advised that the modifications would only enhance the document as nothing new would be added nor would there be any policy issues as a result.

Jim, in response to the Chair’s request for comments advised that the EPA’s view was to encourage discussion of the document by the group and take these comments on board including TP’s comments. Although finality was wanted on this document he was in favour of adding to it to achieve better outcomes.

Trevor confirmed that there would not be any large submissions made, only changing of minor details.

Carlo also expressed his wish to close off the document.

Robin in reply to MI’s question regarding the status of the report confirmed that this was the last draft which would also include what was agreed to tonight.

In response to Michael’s query regarding any additions to the report Carlo advised that a new EIP would be prepared in 2004 and that any amendments to the present EIP would occur using the IAP (Improvement Action Report) which would have periodical updates. He also confirmed in response to MI’s query to possible new procedures being introduced that the IAP would act as an addendum process incorporating any further recommendations. This had been agreed to in the past and that the EIP would remain the same.

Robin confirmed that the committee had agreed to this, that recommendations from studies would be added to the Improvement Action Report. The east side had not been included in the EIP and if it was decided to provide details in the EIP process, they would be included in the Improvement Action Report.

IT expressed his delight that TP wished to have some input and that the committee should assist him. He was concerned however with Jim from the EPA signing off as he believed it was entirely to do with the committee and environmental groups and that he believed their signing off would show good intent moving towards the Manchester Agreement. 

Robin & Peter referred to Section 4.3.1 – 2nd sentence: 
“It is anticipated that the involvement of the community will continue into the future.”
It was suggested that this section either be removed or have the wording changed to clarify Terminals’ future commitment.

Carlo advised that he would be happy to remove it and would leave it to the committee to decide.

Robin believed the first sentence was fine but that more was needed

Peter advised that – “It” should be replaced with “Terminals”.

ACTION: EPA & Terminals to adopt this change (replacement of “It” with “Terminals” in second sentence of Section 4.3.1) in the EIP

Ian Thomas had proposed a wording modification which George did not favour. He felt that although his wording was not the only way to express the point he stated he would like to have his wording minuted, as follows:

“In recognising the potential of the committee to make sensible and beneficial suggestions, Terminals Pty Ltd will at all times consider such suggestions and will reject them only where they are clearly impractical.”


Trevor reported that there had been a number of discussions held regarding the Emergency Plan under the Safety Case and that the EIP had recently been looked at regarding issues to determine the intent of clauses in it. 

Bronwyn reported that she has worked with Geoff Millard (Terminals) on the VECS Risk Assessment. She has also conducted consultations with the MFB regarding emergency response co-ordination with the MFB – Terminals was to comment.

Carlo confirmed that Terminals had received its licence (18.12.02). Geoff had the master copy (ie of the Safety Plan). Geelong Terminals had received their licence 8 months ago. After last meeting’s presentation by Geoff nothing had changed, assessed through the usual process.

Bronwyn advised that WorkSafe were currently preparing the Post Licensing Oversight Plans for facilities which have MHF licences. The current target is to have plans prepared by June. 

ACTION: WorkSafe to conduct a presentation and report when post licence overview had been completed.

EPA – Quentin reported:
1. Annual Monitoring Report – submitted by Terminals. It was a good report and
complied with licence conditions and was submitted on time.
2. One monthly monitoring – test showed one of the Propylene Oxide scrubbers was not working on properly. This licence non-conformance was being addressed.

PH advised that testing had been completed by MGT. He believed the spike was possibly due to too much gas and not enough water.

Carlo advised that different testing had been attempted but could not reproduce this result. MGT were used to conduct the onsite testing. The cause was uncertain and Paul Hayward was soon to submit a report.

Robin asked if it may have been caused by operator error.

Paul replied that it may possibly have been an operator error however the operator was very experienced. A tool box talk was held.

Quentin advised that supervisory input was required when using the scrubber.

Ian congratulated Quentin in raising this issue. As he was concerned with Propylene Oxide this would be considered at the next HS&E meeting to be held on Tuesday 18 March.

Carlo pointed out that there was only one non compliance in 167 samples tested, and that based on previous years it was an improvement.

Terminals’ Report – Carlo

1. Operations Report was deferred till later however as time had run out it has
been included in the attachments. See Attachment 1.
2. Internal Risk Assessment as a condition on the licence would be soon sent to
3. As Marstel were now finally neighbours would discuss issues regarding demolition, and the Sparge Curtain extension.

Paul mentioned that he had opened communication channels with Marstel having held informal talks with Marstel personnel in an effort to ensure that work would be completed correctly.

Robin enquired about the gap.

Carlo replied that 12 months remediation was required so demolition would have to commence at the end of this year.

Paul added that internal demolition would take 4 weeks.

Robin calculated that as the lease extension was to the end of January 2005, and if 12 months remediation was required, Terminals would need to stop operating the east side at the beginning of 2004. It was unlikely that Marstel would have construction and commissioning of their new plant complete before mid 2004, so it was likely that there would be a further 6 month gap.

Ian requested to add another item in here to which Robin agreed.

Ian’s Report

IT has regained contact with Matt Wylie who is in Malaysia, and working for Petrogas Malaysia. 

IT is to attend a meeting being held at the Risk Engineering Society on 7 April at Engineers House 21 Bedford Street Nth Melbourne regarding MHF regulations and compliance.

ACTION: Ian to ensure that the flyer regarding this meeting (7/4) is distributed to the other committee

Also Ian will be attending an international conference ‘ICOMS 2003’ being held in Perth which MESA (Maintenance Engineering Society Australia) will be hosting on 20-23 May where he will present a paper on Dangerous Goods Compliance.

Ian advised that Marstel was 45% owned the Deutsche Bank

Ian also had discussions with lawyers on ways to obtain further disclosure from Terminals regarding what happened in the1991 fire.

Report on Community Early Warning Alert Project – John

At the last meeting of the CICCC it was noted that a meeting had been
scheduled to meet with Bruce Esplin of the Office of Emergency Services
Commissioner to discuss the next stage of the Community Early Warning Alert
Project, given that it had been some 19 months since the project commenced.

John reported that a meeting took place at the office of the City of Maribyrnong in late
February. The meeting was attended by Bruce Esplin and Robyn Betts from
the Office of Emergency Services Commissioner, the Mayor Cr Horrocks, the
Acting CEO Anthony Smith, Theo Pykoulas MERO and John Luppino. 

At the meeting the Mayor expressed his concerns that there had been slow progress
with the project since the completion of the first stage which involved
significant community consultation and focused on stakeholder partnership,
communication and coordination of stakeholder emergency management plans.
Mr Esplin understood Council’s concerns and reaffirmed his commitment to
the development of a warning and information system for the communities
residing near the major hazard facilities sited on Coode Island. This
aspect of emergency management was becoming increasingly important given
world events and threats of terrorist events.

In the weeks following the meeting, Council was advised by the Office of Emergency Services Commissioner that Mr Esplin had been successful in obtaining approval from the Minister for Police & Emergency Services for the next stage of the Community Early Warning Alert project which, involved the trialing of a telephone messaging system across 
areas of the municipality surveyed last year, comprising some 5000 properties.

A draft press release was being coordinated between the Office of Emergency Services Commissioner and the City of Maribyrnong. The draft press release was read to the committee.

Deborah asked if the Kensington area could be included in the project as certain parts of Kensington were more prone to pollution than certain areas of Footscray. IT also asked if the committee’s phone numbers could be included.

John replied that he could not see a problem provided that the technology and the exchange worked.



Robin advised that the February CICCC discussion in this had been deferred. Robin was concerned that the CICCC had not made significant progress with this important part of its charter.

Peter agreed advising that he believed that most people did not know about the committee’s activities.

Robin offered some suggestions that included: 

1. The preparation of a newsletter
2. A briefing session with the community (although this had been done 3 years ago and 
had been poorly attended)
3. Media releases which were a useful activity
4. Deborah’s education initiative with primary and secondary schools – Peter saw this as

Peter raised issues to be considered:
1. Extent of press releases taken up by the media
2. The number of hits on the CICCC web site.
Peter asked for statistics regarding this over the last 6-9 months.

ACTION: Robin to run a report on these statistics and distribute to members. 

Discussion occurred in assessing the general media response with DM pointing out that a lack of activity reflected a lack of interest. IT advised that his last letter to the Herald Sun was not published. In response to DM’s query regarding local papers he advised that he had given up on sending them letters. DM observed that local papers published items from various community groups eg Colleen Hartland (Hazmag). 
MI suggested that JL keep tabs on the local media. Paul Hayward advised that Elizabeth Attard kept such a file at Terminals. Elizabeth offered the file for the committee’s use if required.

ACTION: Elizabeth to prepare 2 copies of the local media file kept at Terminals for DB’s education initiative and for CICCC’s records.

Michael suggested that statistics regarding the number of times the CICCC received a mention in the media be

Further discussion ensued regarding the degree to which Coode Island was covered in the media. Carlo suggested using an experienced Media Monitor. 

ACTION: Elizabeth to give statistics to Carlo regarding media coverage (including The Age and Herald Sun) on Coode Island.

In response to Robin’s question regarding whether the Committee saw communicating with the community was a serious matter, Ian believed that it could call into question the existence of the CICCC if people did not know enough about what it was doing.

Discussion continued regarding an attempt to ascertain the level community interest with Robin advising that there had been a decreased interest rather than an increase and that this lack of interest may be due to a lack of concern. Robin then indicated that this could be as a result of the demonstrable improvement in the Terminals’ facility. 

Peter concluded that the next step was the obtaining of data and development of the education initiative. 

Deborah suggested the putting together of some ideas and submitting these to a public relations company whilst Ian suggested using existing resources.

ACTION: Robin to talk to John regarding any media advice

ACTION: Deborah to get newspaper cuttings from Ian.


Discussion occurred on what Quentin was to talk about as the issue had occurred over 3 months ago. Quentin was not sure whether he was to discuss what the current procedure was for monitoring benzene or what it should be.

Quentin distributed a copy of the Terminals Combustor Monitoring Report. See Attachment 2.

Quentin continued: Benzene was related to 3 main sources – shipping, emission source in tanks when product breathed and repackaging (in drums).

Licence/No 2.18 – treat all vapour emissions of benzene. To comply with licence vapours need to be collected and directed to the VECS. It is a licence requirement for a new VECS to be installed as the previous one could not handle the quantities.

IT reiterated saying that Terminals had to put in a system of the same type but with sufficient capacity.

Quentin – licence is specific on emission limits – 30grams per minute can be emitted from the combustor with a combined emission not to exceed 36 grams.

MI asked why this was called a ‘bubble’?

Quentin replied that it was known as a ‘bubble’ as each combustor emission was a maximum of 30gm and that the combined total of both was 36gm.

IT suggested that the ‘bubble concept’ was an EPA term.

Jim advised that the tendency with an accredited licence that the maximum amount included fugitive emissions so it was a licence for emissions as a whole.

IT asked what the difference was between an ordinary and accredited licence.

Accredited licence – high performance to maintain it with a number of criteria to
meet performance requirements – 

a) Environmental Management System, certified by an authority.
b) Environment Improvement Plan has audits performed by an EPA approved
auditor undertaking a number of different audits to check compliance for 
wastes / risk / environmental impact.

The advantage of this licence is that a works approval is not required unless the works are significant under the Act. Also the fee can be reduced by 25% and can be more simplified reducing the number of pages required. If the company’s performance drops it is reviewed and accreditation can be revoked. Qenos had shown bad performance and a review was undertaken however they did not lose their accredited licence but were prosecuted.
IT stated that in the case of Terminals, it was not an accredited licence. 
Quentin confirmed that a company could have both an accredited licence and a bubble licence.

Monitoring – the Licence has four clauses about benzene monitoring:

– Installation of a device to record and measure temperatures
– VECS system
– Temperature monitoring which is continuous
– Combustors vary performance, temperature kept above minimum level.
Combustor – install a device measuring the rate of carbon discharge ie to install monitoring device on benzene emission for discharge of the combustors.

3.2 Waste Discharge – check frequency. Monitoring to be done in first month then every 3 months to see if within the limit of 30 gms and a total of 36gms. Quentin confirmed that the bubble limit is less than 36 gms. Bubble assumes only 2 pipes. All emissions directed to VECS which simplifies the bubble in a practical extent. 

Licence/3.5 During unloading of ships – Sampling of stacks to be taken when ships were being unloaded.

Each year a report is submitted on the performance results monitoring. This included all results over the 12 months. This is an attempt to ensure that benzene levels are minimised to a maximum extent achievable. 

There has been an increase in shipping however Carlo advised that the ships were the limiting factor. Quentin noted that Terminals could handle more ships. The current performance is significantly better than in the past. Able to unload ships much more quickly.

Carlo advised at the moment gas was being used continuously to keep the combustors on stand-by.

Paul advised that in future Terminals would be able to better anticipate when combustors would be required and so would be able to switch them off at night.

Robin thanked Quentin for this information but then advised that was not the information that was requested previously. He referred to the minutes of 14 November on page 6 regarding the use of carbon beds as a temporary backup when combustors were out of operation and which were to be used as an alternative method for the time combustors were not in use. There had been discussion about the monitoring regime for the carbon beds, and further advice was sought

Robin advised that there was a need for the committee to have the benzene emissions reported back to it.

Carlo stated that carbon beds were less stressed as a result as less of a load, so they absorbed benzene more quickly. He said there were 2 beds so if one was full would swap over to the next one. 

Robin stressed that the issue was how the carbon beds were monitored.

Carlo advised that 5 minute carbon sample were taken and that the readings between carbon and benzene were close, and that this monitoring told them when to change the beds. 

The item was closed. 


See Attachment 3.

Ian asked who owned ERM. Alex Mikov replied that ERM was 51% owned by a venture capital company in Europe involved in global consulting and was situated in the UK, Europe and Middle East

Air Sparge System
¨ An insitu technique to reduce contaminants in groundwater including petro hydrocarbons (petrol) and chlorinated hydrocarbons (solvents).
¨ Injection of air reduces level of contaminants through volatilisation (in-situ stripping) and enhancement of biodegradation process due to increased oxygen.
¨ Schematic view of sparge system 
¨ Air compressor
¨ Injection of air, series of sparge points
¨ Means to capture vapour
¨ Advantages of air sparging:
– in situ technique
– rapid reduction in contaminant concentrations
– addresses saturated and unsaturated zones
– able to control migration of contamination
¨ Limitations of air sparging:
– limited application in low permeability / high heterogeneous soils
– requires saturated depth (minimum 3 – 5m)
– careful design required to minimise potential for crack formation, soil liquefaction and settlement
– careful design required to minimise potential for migration of vapours
¨ The application’s objective at the Terminals’ site is to minimise the rate of contamination migration towards the Maribyrnong River
¨ Terminals’ air sparge operation:
– installation completed in November 2000
– system operated on a pulsed basis (1 hour on, 3 hours off)
– reduction in down gradient groundwater concentrations
– proposed system extension (as part of the Groundwater Management Plan

Alex advised that international testing – 99% of volatiles removed and was probably better than this.

Robin asked if carbon in the small carbon canisters (used to purify the return air containing
volatiles) was replaced to which Alex replied every 3 years.

Alex further advised that calculations were made comparing original contamination level and improved level to find the amount being bio-degraded. Robin commented that this was important to know, and asked for the calculations to be provided.

Alex emphasised that the priority of this system was to protect the Maribyrnong River and that the data confirmed this to be happening. This system prevents migration of the contaminants.

In response to Robin’s query regarding these calculations and the components involved Carlo reconfirmed that this system was not being used to clean up the ground but to stop migration which was the number one priority. This system was used to protect the Maribyrnong River not clean up the ground.

In response to Robin’s question Alex Mikov confirmed that he could obtain the required information in broad terms and would give this to Carlo to present to the next committee meeting.

Ian asked if volatile components were removed first to which Mark replied in the affirmative

Deborah asked if using this biodegradable method was better than using chemicals to which Mark replied that this was a more natural method than using chemicals. Mark confirmed that this system used the bugs that occurred naturally in the ground. 

Robin queried if the system was monitored to which Alex replied that water was displaced which created a mound and anything in the water is stopped. 

Robin asked if the sparge curtain needed to operate continually to ensure the work continued 
and Alex replied that the aim of the system was not to remediate the site but to protect the river. Sparge systems work better when switched on and off.

Ian asked if the mound was of ground water below the surface to which Alex answered in the affirmative.

Carlo pointed out that they dug down to the depth where water was found. Alex confirmed that this was usually approximately half a meter.

Michael asked that if the system was switched off would the mound be removed to which Alex answered that it would take approximately one hour. The migration rate was less than a couple of centimetres per year.

Alex advised that the saturated and unsaturated zones were addressed; the volatile contaminants were contained. The application of the air sparge system as a curtain was a recognised technique which could be used to clean up a site but that it did not have to be used as such as it is also a method of containment.

Deborah asked if it had low permeability, if it was clay to which both Alex and Mark replied in the affirmative.

Robin stated that if it moved one or two centimetres a year, as advised, it would suggest very low permeability.

Alex agreed saying that it the hydraulic gradient not very steep, the tide pushes it back the other way.

Peter suggested that the tidal effect goes both ways.

Robin asked about the length of the sparge curtain with Alex replying that it was 140 meters

Deborah mentioned that this acted like a curtain to which Alex replied in the affirmative qualifying it as a ‘bubble curtain”.

Alex repeated that the objective was to manage contaminants moving towards the river. 
He confirmed that a track of pipes was laid outside the fence line. The sparge system was to be extended down two boundaries. High bunds collect the rain water so sparge curtain blocks contamination.

Robin calculated that if the groundwater moved 2cm per year it would take 500 years to pick up the effect at the monitoring positions 10 metres away from the edge of the curtain.

Alex replied that he could get the actual figures for him, and that the migration rate was a pure theoretical mathematical rate.

Robin asked if the monitoring bores were within the or outside the extent of zone of the sparge curtain air bubbles, to which Alex replied that it was the outside zone – it was 5 meters away.

Carlo advised that in reality the movement would not even be picked up.

Alex advised that it could only be estimated. The system was completed in 2000 and was pulse operated for best results and had been designed to allow for an extension.

ACTION: Alex to email overheads to Elizabeth (ie revised overheads) within the next week.

Jim raised concern that no sparge curtain in the middle which might have a bypassing effect to which Alex replied in the affirmative however he was not finding that this had any impact on the results. 

Robin pointed out that if the sparge curtain was not continuous then Jim could be correct.

Al confirmed that if the contaminated area increased then it was likely to occur at the other boundary as well. Robin then asked if a problem was found would they then respond to which Alex answered in the affirmative.

Regarding past spills Alex advised that it was too complex a matter to try to determine where they originated from. Mark added that could be from multiple sources.

Ian asked the cost of the system per meter?
Paul advised that it the initial installation cost $250,000 and the extension would cost a further $200,000.
Ian suggested that if ground water contamination was important it would be better to prevent this happening by sealing the surface first. He also asked that after installation costs of $250,000 what were the running costs. Paul Hayward replied the cost of power whilst Ian noted that the air was free noting that Liquid Air also benefited in this way.

ACTION: Alex to provide additional information to document:

The mass balance of contaminants;
§ The percentage of contaminants removed by each mechanism;
§ The correlation between improved ground water quality and the amount of volatiles collected in the carbon canisters;
§ The permeability of the ground if the sparge curtain effect was picked up at the monitoring bores in about one year.



Carlo stated that the EIP would be closed off soon, the agenda items would no longer be as full as previously and he was getting tired as it was late.

IT agreed and suggested adjourning this to the next meeting.

Peter suggested that the meeting should end at a more reasonable time.

IT advised that as the EIP had works that the committee had a responsibility to keep its eye on Terminals which was now greater not less.

Robin advised that the matter should be debated and would be adjourned to the next meeting.

Peter added that bimonthly or quarterly meetings became a waste of time. Need to look at level of importance of business.

Robin mentioned that there was a light agenda for the next meeting, however if something major occurred that it would be ‘cold news’ by the time of the next meeting held, if long periods in between.

Carlo stated that Improvement Report would not change much from one month to another.

Robin believed that the substance of matters to be dealt with would decrease if held every 2 months might lose the plot. He put forward the suggestion to keep meetings on a monthly basis but to make them shorter such as of only 1.5 hours duration.

IT added that this is what Marstel did. He recalled that these meetings would go on until 11pm during Peter Reddie’s time as MD of Terminals and that presently they continued till about 10pm.

Robin advised that this item would be placed on the agenda for the next meeting.

Jim wanted to share the experiences of other consultative committees who met every 2 to 3 months and found that these were still effective. He mentioned one example where meetings were held every 2 months however staff also conducted internal environmental management meetings to discuss their own issues and monitor performance.


The minutes were accepted with the following changes to be made:

“prescribed industrial wastes” to replace “prescribed wastes” on page 4.

Delete paragraph on page 9 “*The Hazardous Waste Committee which met to find a site……… this time.”




*A copy of the Marstel submission on Melbourne 2030 paper. See Attachment 4.
ACTION: Copies to be included in the attachments sent to committee members

* Carlo received a draft of the Bund Report.




* Robin advised that he will be absent from the May meeting and that Ian has agreed to act as chairperson (Fay declined).

*He also reported that he had obtained information regarding the meeting of School Principals to be held sometime in June and having access to the meeting’s agenda. He was to give this information to Deborah for the educational initiative after the meeting. 

ACTION: Robin to give details of the School Principals’ meeting to Deborah after the meeting.

*IT reported that following his discussion with MB (EPA Chairman) at the last meeting he was pleased to report that MB had reported back advising that Keith Smithers had been given the responsibility to investigate IT’s allegations that the EPA targeted some companies and not others. KS has advised that there was a difference in the way the three metropolitan regions of the EPA treat industries depending on where they were situated which determined whether they were targeted. Also there were companies that had not been targeted. IT was delighted with MB’s presentation and follow up.

QUENTIN advised that he had a different record of interview and had a document containing KS’ notes of the meeting.

Robin advised that 2 people’s recollection would be different.

Agreement was reached that the matter was followed up with further follow up to be made.

QUENTIN further advised that if there was any concern regarding an un-level playing field that this should be communicated to the EPA.

The EPA was congratulated for its prompt action.

Meeting closed at 10.10 pm



13 March 2003

Attachment 1 Terminals P/L Monthly Operations Report (Carlo)
Attachment 2 Terminals’ Combustor Monitoring Report (QUENTIN)
Attachment 3 ERM’S Overheads on Air Sparge System
Attachment 4 The Marstel Submission on Melbourne 2030