Do Australian Clean Up Projects Currently Accord with the Concept of Sustainable Remediation?

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1 Do Australian Clean Up Projects Currently Accord with the Concept of Sustainable Remediation? Peter Nadebaum Australasian Land and Groundwater Association SuRF Australia, CRC CARE, GHD Pty Ltd

2 Clean Up in Australia Each project: Must achieve the project objectives Must comply with regulatory requirements Must be acceptable to stakeholders Balance of risk and cost Australian regulatory system Flexible Allows range of endpoints/solutions Does this encourage solutions that accord with the concepts of Sustainable Remediation?

3 Australian remediation system Key requirements: Performance objective (not mandated clean up method) Comply with regulatory requirements relating to protection of human health and the environment ( no adverse effect ) Allows consideration of Land use (eg industrial - less sensitive) Groundwater use (uses that are relevant) Consultation with stakeholders (for larger projects)

4 What constitutes Sustainable Remediation? No formal framework in place at this time CRC CARE is preparing a National Framework SuRF Australia has prepared a Framework for Sustainable Remediation - draws on UK Framework Key requirements: Meets regulatory requirements Acceptable level of risk Achieves a balance between environmental, social and economic factors? Also at what point in the project cycle is sustainability considered?

5 Case examples: Filled quarries: 10 deep uncontrolled landfills reconstituted, capped and developed for mixed residential use (South Australia) Harbour land: 25 ha of deep uncontrolled filling and hydrocarbon contamination developed for mixed high value commercial and residential use (Northern Territory) Industrial badly contaminated filled site: remediated for high value residential development (New South Wales) Petroleum pipeline: leak resulting in extensive NAPL plume (Victoria) All sites involved consultation with EPA and stakeholders

6 Risk and balance of environmental, social, economic factors? Identified allowable options for each, and assessed 1. Risk that something goes wrong [final solution/clean up works] 2. Sustainable Remediation: indicators of impact (SuRF Australia/UK Framework) Environmental Social Economic 1. impacts on air; 2. impacts on soil; 3. impacts on water; 4. impacts on ecology; 5. use of natural resources and generation of wastes; 6. intrusiveness. 1. impacts on human health and safety; 2. ethical and equity considerations; 3. impacts on neighborhoods or regions; 4. community involvement and satisfaction; 5. compliance with policy objectives and strategies; 6. uncertainty and evidence. 1. direct economic costs and benefits; 2. indirect economic costs and benefits 3. employment and capital gain; 4. induced economic benefit; 5. life-span and project risks ; 6. project flexibility. Ranked in terms of impact: 1 3 low (best); 4 7 medium; 8 10 high (worst)

7 Ten Filled quarries residential and park land PAHs and metals Options: 1.Adopted: pre-validate, excavate, sort, reuse as fill or landfill, cap, control land use 2.Excavate and landfill 3.Existing + treat PAHs + stabilise metals 4.Existing but relocate more contaminated material to separate cell 5.No excavation, cap, pile

8 Risk The quarries - The adopted solution provides a reasonable balance of risk vs impact Impact (of the works) - Other options have either higher risk or higher impact

9 Harbour Land Hydrocarbons, NAPL, heavy metals (spilt ore), pesticides, asbestos, solid waste

10 Harbour Land Approach: Identify and remove unacceptable soil/napl contamination Confirm residual soil contamination not a health risk Redirect groundwater so not an environmental risk

11 Harbour Land

12 Harbour land - options 1. Existing: assess risk, remove/landfill unacceptable soil/napl from building footprints, redirect groundwater/skim/discharge, CUTEP 2. Excavate all soil and landfill, redirect groundwater 3. Excavate all soil and landfill, groundwater MNA 4. Excavate all soil and landfill, treat groundwater 5. Excavate soil, sort, treat and return to site or landfill, treat groundwater CUTEP: Clean up to the extent practicable

13 Risk Harbour land - The adopted solution provides a reasonable balance of risk vs impact - Other options have higher risk and higher impact Impact (of the works) Note: - Complete clean up: although final site condition has lower risk, the overall risk is increased by the clean up work - Groundwater treatment: difficult and unlikely to be successful; diversion likely to be lower risk and lower impact

14 Petroleum Pipeline leak Rural location, fractured rock, groundwater used for stock Options: 1. Existing excavate/ landfill source, MPE, skim, CUTEP 2. Less recovery + CUTEP 3. Full recovery CUTEP: Clean UP to Extent Practicable

15 Risk The Petroleum Leak - The adopted solution provides a reasonable balance of risk vs impact - Full clean up has lowest final site risk, but with a much greater impact of the clean up works (particularly greater resource usage) Impact (of the works) Note: The adopted solution requires ongoing administrative controls (hence higher risk than a full clean up approach)

16 Heavily contaminated site chlorinated organics, dioxins, metals Options 1.Adopted: assess health risk, excavate most contaminated soil and return to site + contain at depth less contaminated soil, contain groundwater 2.Full soil treatment + groundwater containment 3.Full soil treatment + groundwater treatment 4.In-situ treatment not feasible

17 Risk The heavily contaminated site - The adopted solution provides a reasonable balance of risk vs impact - Other options have higher impact with little or no reduction in overall risk Impact (of the works) Note: Full treatment will provide lowest risk, but with considerably greater impact especially increased cost and use of resources

18 Note The ranking has been qualitative and indicative - does depend on the considerations applied it is not absolute risk has been ranked in terms of likelihood of something going wrong and the result not being acceptable other perspectives could be applied impact has been ranked in terms of adverse impact of the works (benefit is similar in most cases) Focus on major impacts of each option not whether sustainable methods have been applied to particular options

19 Findings In assessing options, need to consider both risk (outcome might not be acceptable) and impact of the works If the risk is too high do not consider

20 Findings, cont d For each example the option adopted appears to provide a reasonable balance in terms of risk (final site condition and clean up works) vs impact of the works The approach being adopted in Australia does appear to (informally) apply the principles of sustainable remediation and management But there are sites where the Australian system did not achieve balanced solutions Particularly where the endpoint is not risk-based, but is policy based. Eg asbestos ( none allowable ) Debate about landfill levies zero waste policy The application of Clean Up to the Extent Practicable is important in achieving sustainable outcomes

21 Findings, cont d Similar ranking using only the most important indicators suggests simplification This analysis post remediation The approach could be used to assess clean up and management options prior to adoption to better understand the factors involved 20

22 Conclude In Australia the current regulatory regime has flexibility and allows different clean up and management solutions allows options that provide a reasonable balance in terms of risk and impact The current process for selecting a remedial solution does not necessarily lead to an imbalance in risk vs impact ie generally does not force a solution that costs too much for benefit realised Risk is the primary basis for selecting acceptable options Risk-based Sustainable Remediation