Reviewing Contaminated Site Assessment Reports. What the NEPM means for you

Transcription

1 Reviewing Contaminated Site Assessment Reports What the NEPM means for you

2 Legislative Framework EPAA (1979) EPAA Regulation (2000) State Environmental Planning Policy 55 POEO Act(1997) POEO Regulations (key = Waste 2014) CLMA(1997) Guidelines (sct 105) NEPM 2013

3 Begin with the end in Mind Why are you reviewing? Change of use Change of zoning Compliance with legislation Results of regular Inspections Who or what is at risk Which legislation Applies EPAA (SEPP55) CLM POEO

4 Investigation vs Assessment Investigation programs have the objective of identifying the nature, concentrations and extent of contaminants in relevant environmental media Assessment programs have the objective of identifying and quantifying the risk posed to human health and to the environment by the contaminants identified in the investigation program

5 Environmental Investigations Environmental investigation programs should be carried out so that there is a 95 % probability of identifying significant contamination This is achieved by following a staged approach outlined in the NEPM and NSW EPA guidelines

6 General Stages 1. Stage 1 - Preliminary Site Investigation (PSIs) Desktop Study Initial conceptual site model (CSM) 2. Stage 2 Detailed Site Investigation (DSI) Sampling Analysis and Quality Plan (SAQP) Data Quality Objectives (DQO) for data collection 3. Human Health and Environmental Risk Assessment (HHERA) if required 4. Remedial Action Plans (RAP) if required 5. Site Validation and ongoing monitoring if required

7 PSI 1. Site Identification Lot & DP, geographical coordinates, surrounds 2. Desktop enquires Current and historical use Review of historical air photos; Council, EPA and Dangerous Goods records, groundwater usage, title history. 3. Site Visit & Interview 4. CSM creation (source, pathway, receptor) 5. Reporting

8 Phase 1 Tips 1. Ensure Accurate Description of site address and legal identifier 2. Include copies of Historical Aerial Photographs with Site marked. 3. Council records include Section 149 certificate + council records if relevant. 4. NSW EPA search information about the site in three locations on EPA website 5. Dangerous goods records, work cover searches take 2-4 weeks and cost 6. Land titles often don t supply much but can be important 7. Near Maps show current information 8. Other reports (Hazardous Materials reports, Heritage Assessment Reports)

9 Checking Facts PSI As Auditor I check : Google Maps Near Maps Six Maps NSW EPA Website Historical Atlas Site visit

10 Google Maps - Rosebery

11 Near Maps Jan 2010 Jan 2013 Nov 2014 Apr 2015 Jun 2015

12 Six Maps (1) Current 1943

13 Six Maps (2) Lot and DP

14 Historical Atlas Atlas of Suburbs

15 Historical Aerial Photographs

16 NSW EPA Lists CLM Act Record on line Orders, Voluntary Management Proposals and anything on public record CLM Act Duty to report List of sites reported to EPA POEO Licences, notices, convictions etc

17 Site Visit Remember the pipes Pouring something into sewer with gloves Suspected Asbestos after a residential site had been remediated

18 Plans & Cross Sections

19 Conceptual Site Model NEPM defines CSM as.. a representation of site related information regarding contamination sources, receptors and exposure pathways between those sources and receptors.

20 Conceptual Site Model Key elements include: Known and potential sources of contamination and contaminants of concern (including mechanisms of contamination) Primary and secondary sources Pipe leak, pour, spill etc Potentially affected media (soil, sediment, groundwater, surface water, indoor air, ambient air) Human and ecological receptors Potential and complete exposure pathways

21 DSI 1. Commence with Conceptual Site Model from PSI Lot & DP, geographical coordinates, surrounds 2. SAQP Aim = delineate Lateral and vertical extent of contamination Includes detail sampling location, methodology, intent. 3. Field Sampling & Analysis Include methods Tips = Soil vapour and groundwater could need several rounds, soil samples should prove and sample natural ground 4. Reporting Results compared with Risk based guidance Discussion includes uncertainties and context.

22 Figures & Boreholes

23 NEPM Risk Based Guidance

24 Asbestos Sampling Tips NEPM now provides Guidance Defines ACM vs FA and AF Provides approach for sampling density Provides sampling methodology Defines risk in guidelines as %Wt/Wt But beware of NATA vs NEPM methods

25 Soil Vapour - Tips NEPM provides detail on Soil Vapour sampling Consider CSM what is the concern? target points vulnerability (lift shafts below basement levels) Probe depth governed by CSM Make sure good well construction (seals, teflon) Background concentrations to be considered Leak testing (QA/QC) Calibration all equipment

26 Checking Facts DSI As Auditor CSM as a guide Figures (all impacts noted) Borehole logs (odours, deleterious material) Results (tabulated, correct guidelines etc) Discussion contamination/pathway/risk Conclusion

27 Risk Assessment Problem formulation Why is an HHRA needed? What risks will it consider? What information is available from community? Process to assess risk What will happen to risk assessment? Contamination Exposure Risk Pathways Receptors 27

28 Risk Management Risk Management decisions consider investigation and assessment Include No action Monitoring (soil vapour, groundwater etc) Remediation Site Management Further Assessment 28

29 Begin with the end in Mind Risk Development Legislative constraints

30 Thanks for listening Any questions Kylie Lloyd Managing Director NSW EPA Accredited Auditor Zoic Environmental