Remediation and management of contaminated …...During the remediation and management of...

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Remediation and management of contaminated sites

Guideline for documentation, record-keeping and reporting

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National Framework for Remediation and Management of Contaminated Sites in Australia The following guideline fits within the National Framework for Remediation and Management of Contaminated Sites in Australia. The Framework was developed to enable a nationally consistent approach to the remediation of contaminated sites. The Framework provides the context, philosophy and principles underlying the remediation and management of contaminated sites in Australia. It also offers general guidance and links to further information to assist with remediation planning, implementation, review, and long-term management.

Remediation and management of contaminated sites Guideline for reporting, documentation and record-keeping

This guideline provides general guidance in relation to reporting, documentation and record-keeping during the remediation and management of contaminated sites. It also provides references to a range of other potentially useful information. While the aim of this guideline is to provide a practical and up-to-date resource that can be used at contaminated sites across Australia, it does not replace specific laws, regulations and guidance provided at a local level. Specific reporting, documentation and record-keeping requirements related to contaminated sites vary across the states and territories of Australia. There is, however, a general consistency in the type of information that practitioners are expected to develop, maintain and make available during site remediation and management.

Readers are advised to consult with their state or territory environment protection authority and other relevant Commonwealth, state or territory government authorities, including local councils, before commencing any remediation project to ensure that they are complying with any specific requirements.

Sources of information and referencing

Material in this guideline has been drawn, often verbatim, from a range of publicly available government and non-government sources. This reflects the fact that one of the objectives of this guideline is to harmonise existing guidance. The sources are acknowledged in the reference boxes located at the end of each section. Referencing has been done in this manner in order to maximise readability and to simultaneously recognise specific sources. This referencing and acknowledgement style does not follow conventional styles, as by definition, this guideline does not represent a work of original research. Its originality lies in the approach to harmonisation which is a hallmark of the National Remediation Framework.

As indicated above, this guideline also provides references to a range of other potentially useful information.

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TABLE OF CONTENTS

1 GOVERNMENT ENVIRONMENT PROTECTION AUTHORITIES 5

2 GLOSSARY 6

3 ABBREVIATIONS AND SHORT FORMS 7

4 INTRODUCTION 8

5 PURPOSE OF GUIDELINE 8

6 SCOPE OF GUIDELINE 8

7 DOCUMENTATION, RECORD-KEEPING AND REPORTING ON CONTAMINATED SITES 10

7.1 Setting the context 10

7.2 Documentation, record-keeping and reporting processes 11

8 DOCUMENTATION, RECORD-KEEPING AND REPORTING DURING REMEDIATION AND MANAGEMENT OF A CONTAMINATED SITE 13

8.1 Remediation and management objectives and options 13 8.1.1 Remediation and management objectives 13 8.1.2 Remediation and management options and associated technologies 13

8.2 Operational and site-specific plans 16 8.2.1 Site preparation and administration 17 8.2.2 Planning documentation, record-keeping and reporting—general guidance 17 8.2.3 Planning documentation, record-keeping and reporting—specific guidance 18

8.3 Auditing/third party review 25

8.4 Institutional controls 26

9 REFERENCES 28

9.1 Framework for Remediation and Management of Contaminated Sites Materials 28 9.1.1 Development of remediation and management plan 28 9.1.2 Implementation of remediation and management plan 28 9.1.3 Post-remediation considerations 28

9.2 NEPM Materials 29

9.3 Jurisdictional guidance 29 9.3.1 Australian Capital Territory 29 9.3.2 New South Wales 29 9.3.3 Northern Territory 30 9.3.4 Queensland 30

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9.3.5 South Australia 30 9.3.6 Tasmania 31 9.3.7 Victoria 31 9.3.8 Western Australia 32

9.4 Other references 33

APPENDIX A: EXAMPLE REMEDIATION AND MANAGEMENT PLAN 34

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1 GOVERNMENT ENVIRONMENT PROTECTION AUTHORITIES Government Agency Website Commonwealth

Department of the Environment

www.environment.gov.au

Western Australia

Department of Environment Regulation

www.der.wa.gov.au

South Australia

Environment Protection Authority

www.epa.sa.gov.au

Tasmania


www.epa.tas.gov.au

Queensland

Department of Environment and Heritage Protection

www.ehp.qld.gov.au

Australian Capital Territory


www.environment.act.gov.au

Northern Territory


www.ntepa.nt.gov.au

New South Wales


www.epa.nsw.gov.au

Victoria


www.epa.vic.gov.au

http://www.environment.gov.au/

http://www.der.wa.gov.au/

http://www.epa.sa.gov.au/

http://epa.tas.gov.au/epa/

http://www.ehp.qld.gov.au/

http://www.environment.act.gov.au/environment/environment_protection_authority

http://www.ntepa.nt.gov.au/

http://www.epa.nsw.gov.au/

http://www.epa.vic.gov.au/

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2 GLOSSARY Contamination means the condition of land or water where any chemical substance or waste has been added as a direct or indirect result of human activity at above background level and represents, or potentially represents, an adverse health or environmental impact. Environment protection authority refers to the government agency in each state or territory that has responsibility for matters relating to contaminated sites. Environmental value (beneficial use) means a use of the environment or any element or segment of the environment which:

• is conducive to public benefit, welfare, safety, health or aesthetic enjoyment and which requires protection from the effects of waste discharges, emissions or deposits or of the emission of noise or

• is declared in state or territory environment protection policy to be a beneficial use. Practitioner means those in the private sector professionally engaged in the assessment, remediation or management of contaminated sites. Site means the parcel of land where remediation activity is occurring.

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3 ABBREVIATIONS AND SHORT FORMS EPA Environment(al) protection authority NEPM National Environment Protection (Assessment of Site Contamination) Measure

1999, as amended 2013 SEPP State environmental planning policy (NSW) State environment protection policy (VIC)

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4 INTRODUCTION During the remediation and management of contaminated sites, a range of activities may be undertaken. All of these activities take place following careful planning to address site-specific conditions. Good documentation and record-keeping practices assist practitioners to effectively manage remediation and management activities and easily meet the reporting requirements of environment protection and other regulatory authorities. This guideline aims to provide general guidance to practitioners as they consider the information they should develop, maintain and make available during the remediation and management of contaminated sites. Information about further sources of assistance is provided throughout the document. 5 PURPOSE OF GUIDELINE The purpose of this guideline is to present guidance on the information that should be developed and maintained during the remediation and management of contaminated sites so that practitioners can effectively record the process and meet the reporting requirements of relevant national, state and territory government agencies. 6 SCOPE OF GUIDELINE Documentation, record-keeping and reporting are ongoing responsibilities of practitioners as they manage the entire remediation and management process on a contaminated site. These responsibilities begin during the assessment stage—a time when the extent of contamination on a site is investigated and when the primary record of site activities, a remediation and management plan, is first developed. They are ongoing while remediation activities are taking place, and continue beyond the completion of works on site. Information about reporting, documentation and record-keeping requirements related to the assessment of contamination is available through state and territory environment protection authorities and is not the focus of this guideline. Rather, this guideline aims to highlight likely documentation, record-keeping and reporting requirements related to remedial or management activities on a contaminated site. However, because of the close links between assessment and remediation, and the fact that the same plan is generally used for both stages, this guideline will, when relevant, make reference to material that may have been collected, developed or reported during the assessment stage. It is important to note that documentation, record-keeping and reporting requirements are administrative aspects of the management of a contaminated site. Other available guidance provides detailed information about the remedial and management activities themselves. In this guideline, documentation, record-keeping and reporting requirements related to the implementation of a remediation and management plan are considered under the following headings:

• site-specific remediation objectives and remedial options, including the selection of remedial technologies, treatability studies and cost-benefit analysis

• regulator submission requirements, including operational and site-specific plans, validation and closure, and monitoring

• auditing/third party review • institutional controls.

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Because of the limitations presented by differences in the regulation of contaminated sites across Australia, this guideline can only provide general guidance. Environment protection authorities in all states and territories have their own specific requirements, covering content, method and process of reporting on each aspect of remediation and management. In addition, because every contaminated site is different, practitioners may need to consider legislated reporting requirements and guidance associated with a range of remediation-related activities. Practitioners should make regular contact with relevant Commonwealth, state or territory government authorities to ensure their documenting, record-keeping and reporting activities comply with local requirements and site-specific conditions. There may be specific regulations that apply to remediation and management activities relating to airports, mining and defence. Practitioners should refer to relevant Commonwealth, state or territory legislation as appropriate, for example, the Department of Infrastructure and Regional Development and the Airport (Environment Protection) Regulations 1997. This guideline aims to bring together relevant existing guidance about likely documentation, record-keeping and reporting requirements during the implementation of a remediation and management plan on a contaminated site. This synthesis of existing material includes information from a range of sources. In order to maintain relevance for practitioners, these sources are predominantly Australian in origin. Sources include guidelines published by government agencies—Commonwealth, state and territory—that have legislative or regulatory responsibility for work undertaken on contaminated sites. Information about relevant guidance modules that have been developed under the National Framework for Remediation and Management of Contaminated Sites is provided within the text of this guideline. Source details for those modules, as well as for additional available guidance for each topic, are provided at relevant places in this guideline.

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7 DOCUMENTATION, RECORD-KEEPING AND REPORTING ON CONTAMINATED SITES

7.1 Setting the context While specific processes relating to the remediation and management of contaminated sites vary across states and territories, and the names and functions of people involved in these processes also vary, the following generalisation of functions, processes and plans provides some context for the material contained in this guideline. The ‘practitioner’ addressed in this guideline is the person responsible for the coordination of remedial or management activities on a contaminated site. The practitioner is usually a professional who works as a contaminated site consultant. In a typical situation, a contaminated site consultant is engaged by a site owner or developer to conduct a site assessment, undertake any necessary remediation, and validate the work completed. Another professional—an accredited site auditor—may be required to independently review the work undertaken by the consultant and provide an opinion (in a site audit report) as to whether the consultant’s work complies with current regulations and guidelines, whether there is evidence to support decisions or actions relating to the land concerned, and/or whether the land is suitable for particular uses. In some jurisdictions, auditor involvement is only involved in specific situations, for example, where there is significant contamination, such as where off-site receptors are affected and ongoing regulation takes up significant resources of regulatory authorities. The relevant Commonwealth, state or territory government agency, which may be an environment protection authority or a planning and development control authority, considers the site audit report before making decisions about the future use of the site. The primary record relating to remediation and management activities is a plan that is usually developed by the practitioner when a site is first investigated for contamination. In different states and territories across Australia, this plan may be known by various names and may be structured in different ways, for example, as one ‘umbrella’ plan or as a series of smaller plans, depending on regulatory requirements and site-specific conditions. There is, however, consistency in the way such plans detail all procedures and processes that will be undertaken to reduce human health and/or environmental risks to acceptable levels for the proposed site use. Many of the practitioner’s documentation, record-keeping and reporting obligations arise from the content of this plan. The remediation and management plan usually incorporates reporting requirements that practitioners must fulfil prior to the start of remediation or management activities; that is, during the assessment stage. By the time the plan is implemented, practitioners will have already collected a great deal of information and will have record-keeping and reporting systems in place. An example of a remediation and management plan is provided as APPENDIX A. The example plan is a synthesis of information required of practitioners by various state and territory environment protection authorities. To reflect existing processes, the example plan includes information that will have been gathered or developed during the assessment stage and prior to the beginning of site works. Material in the example plan with particular relevance to this guideline is highlighted for easy reference. The documentation produced during the development and implementation of the plan is not only used for reporting purposes at that time; it is also used during and following remedial or management activities. Some of

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the information collected and reported upon when the site is first investigated and assessed, for example, site history, conditions, geology and hydrogeology, and risk assessment, is used again (usually in summary form) to fulfil reporting requirements during implementation of the plan. Practitioners and environment protection authorities are able to access all of the information needed for the purposes of validation and closure, long-term monitoring, auditing or other third party review, and to inform the setting of institutional controls for the site. Depending on requirements in a particular state or territory, the site auditor will review and may endorse all or some aspects of the plan before remediation work begins, they may complete an audit following remediation, or they may do both. The site auditor may provide third-party review on any/all contaminated sites, or may only be engaged when a ‘sensitive land use’ is proposed, for example, a child care centre, pre-school, primary school, or residence. As the site audit report is a critical review of the information gathered by consultants, it is sensible to involve a site auditor early in the assessment and remediation process. This makes it possible for the consultant and the auditor to communicate about the specific documentation that will need to be developed, maintained and made available to meet the requirements of the audit. It is usually stressed, however, that the involvement of the site auditor should be limited to the auditor providing advice on his/her information requirements and his/her criteria for determining the suitability of the site for use.

7.2 Documentation, record-keeping and reporting processes Establishing and maintaining an organised comprehensive record-keeping and documentation system will assist practitioners to:

• develop written plans and strategies that provide clarity for all people working on-site or affected by site activities

• provide an accurate and complete record of all remedial activities as well as any alterations to original plans

• measure the success of remediation and management activities against remediation objectives • provide written detail about site activities when required • meet post-remediation requirements, e.g. for the purposes of validation and closure, long-term

monitoring, auditing/third party review, and the setting of institutional controls regarding the site • present a legally defensible position regarding actions taken to remediate the site • defend those implementing remedial activities from regulatory, worker or public action concerning

potential exposure to contaminants • support possible legal action against potentially responsible parties who may have contributed to the

contamination of the site. Good documentation and record-keeping practices are crucial to the effective management of the activities that are undertaken on a contaminated site. Methods for documenting information include daily, weekly and monthly reports, training forms, sample logs, air monitoring logs, copies of permits, manifests and analytical reports. Training in records management is widely available from a variety of sources, including industry groups such as the Australian Contaminated Land Consultants Association (ACLCA), as well as government and private records management training service providers. Information about the development of records systems and the presentation of reports in relation to contaminated sites can also be found in the guidance listed below. Commonwealth, state or territory government authorities should always be consulted regarding record-keeping and reporting requirements particular to their jurisdiction.

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More detailed and/or further information: documentation, record-keeping and reporting processes National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, NEPC, Australia, available at <www.scew.gov.au>. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, Schedule B (2), Guideline on site characterisation, NEPC, Australia, available at <www.scew.gov.au>. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013,Schedule B (3), Guideline on laboratory analysis of potentially contaminated soils, NEPC, Australia, available at <www.scew.gov.au>. NSW Office of Environment and Heritage 2011, Contaminated sites: Guidelines for consultants reporting on contaminated sites, OEH, New South Wales, available at <www.epa.nsw.gov.au>. WA Department of Environmental Protection 2001, Reporting on site assessments, Contaminated sites management series, DEP, Western Australia, available at <www.der.wa.gov.au >. Sources of information for this section: Canadian Council of Ministers of the Environment 1997, Guidance document on the management of contaminated sites in Canada, PN1279, CCME, Canada. NSW Department of Environment and Conservation 2006, Contaminated sites: Guidelines for the NSW site auditor scheme (2nd edition), DEC, New South Wales. NSW Office of Environment and Heritage 2011, Contaminated sites: Guidelines for consultants reporting on contaminated sites, OEH, New South Wales. SA Environment Protection Authority 2010, Guidelines for the site contamination audit system, EPA, South Australia. VIC Environment Protection Authority 2007, Environmental auditor guidelines for conducting environmental audits, Publication 953.2, EPA, Victoria. WA Department of Environmental Protection 2001, Reporting on site assessments, Contaminated sites management series, DEP, Western Australia.

http://www.scew.gov.au/





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8 DOCUMENTATION, RECORD-KEEPING AND REPORTING DURING REMEDIATION AND MANAGEMENT OF A CONTAMINATED SITE

8.1 Remediation and management objectives and options The decisions made about management objectives and options for remediation and management of a contaminated site occur after careful consideration of all of the conditions on a specific site. It is important that practitioners document the decision-making process they use while considering their overall remediation and management strategy. This information may be required, often in summary form, in reports made to environment protection and other regulatory authorities during the implementation of the remediation and management plan. Practitioners should aim to provide clear justification for the setting of particular objectives and their choice of appropriate remedial and management options and technologies.

8.1.1 Remediation and management objectives The setting of site-specific remediation and management objectives follows the assessment of a site as being contaminated and in need of some level of remedial action or other management. The objectives are usually formulated through a risk management process, with the overall goal being to ensure that the remediated site will be suitable for the proposed use and will pose no unacceptable risk to human health or the environment. Carefully developed and clearly documented objectives are the foundation of remediation and management planning. As well as giving all people associated with a contaminated site a clear understanding about why particular activities are being undertaken, they also provide the practitioner with a basis from which to:

• identify remedial options and select the most appropriate option for a specific site • select the remedial technologies most suited to the options chosen • build an evidence base to justify particular activities or strategies used on the site • establish performance indicators with which to measure and validate the remedial or management

activities undertaken on the site. Factors that practitioners may consider when setting remediation or management objectives include:

• the requirements for minimising risk where there is significant uncertainty • protecting current and future groundwater use • the health of ecological systems • relevant environmental values • the distribution of the contamination • future use of the site • the capabilities of the available remediation technologies • the sustainability of the remediation or management objectives • legal and social considerations, incorporating community consultation.

The relevant guidance module for this topic under the Framework for Remediation and Management of Contaminated Sites is Site-specific remediation objectives (to be developed).

8.1.2 Remediation and management options and associated technologies

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The development and documentation of clear remediation or management objectives allows the consideration of the most appropriate remedial or management strategy for the site and provides a record of evidence to support decisions that are made. All states and territories in Australia agree on a preferred hierarchy of options for site remediation or management as follows:

• on-site treatment of the contamination so that it is destroyed or the associated risk is reduced to an acceptable level, and

• off-site treatment of excavated soil, so that the contamination is destroyed or the associated risk is reduced to an acceptable level, after which soil is returned to the site

OR, if the above are not practicable,

• consolidation and isolation of the soil on site by containment with a properly designed barrier, and • removal of contaminated material to an approved site or facility, followed, where necessary, by

replacement with appropriate material, OR,

• where the assessment indicates that remediation would have no net environmental benefit or would have a net adverse environmental effect, implementation of an appropriate management strategy.

Practitioners also consider specific remedial technologies available for each option. This may involve the use of treatability studies which evaluate the performance and cost-effectiveness of a remedial technology on a given contaminated matrix. They are carried out if available information is insufficient to detail a technology’s performance in a similar site situation. Treatability studies involve the treatment of samples of contaminated material in small-scale applications of a particular technology being considered for a site. In cases where no readily available or economically feasible method is available for remediation, it may be possible to adopt appropriate regulatory controls or develop other forms of management. When deciding which option to choose, practitioners consider the environmental, economic and social sustainability of each option, in terms of achieving an appropriate balance between the benefits and effects of undertaking the option. A cost-benefit analysis can help practitioners as they consider options and technologies, with the following questions establishing a framework for the analysis*:

• What events, actions or aspects will change as the result of the action? • What is the estimated value of the environmental and human health benefits that will come about as a

result of the action? • What are the estimated costs associated with and created by the action? • Given the estimated benefits and costs, is remedial action justified?

(*Framework as described in CCME’s Guidance document on the management of contaminated sites in Canada, April 1997)

Relevant guidance modules for this topic under the Framework for Remediation and Management of Contaminated Sites are:

• Identifying remedial options (to be developed) • Selection of remediation technologies (to be developed) • Treatability studies (to be developed) • Cost-benefit analysis (to be developed).

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Likely reporting requirements: remediation and management objectives and options Information that may be required for reporting purposes includes:

• Identification of remediation and/or management objectives for the site • Discussion of extent of remediation required • Discussion of possible remedial and management options and how risk can be reduced • Discussion of the community’s involvement in the selection of remediation or management options through a

planned community consultation process • Rationale for the selection of the recommended remedial option • Details about how the remedial technique will be carried out • Contingency planning for possible failure of remedial or management strategies • Justification of the chosen option against other available technologies or management options where the method

chosen is not consistent with the hierarchy of options for site remediation or management • Progress reporting regarding the achievement of remediation or management objectives

More detailed and/or further information: remediation and management objectives and options Environment protection authorities in the relevant state or territory should be consulted regarding the currency of information, as well as any specific recording and reporting requirements. This may involve referral to other relevant government regulatory agencies. CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Site-specific remediation objectives, (to be developed) CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Identifying remedial options, (to be developed) CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Selection of remediation technologies, (to be developed) CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Treatability studies, (to be developed) CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Cost-benefit analysis, (to be developed) National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, NEPC, Australia, available at <www.scew.gov.au>. VIC Environment Protection Authority 2011, Industrial Waste Resource Guidelines - Soil remediation technologies in Victoria, EPA, Victoria, available at <www.epa.vic.gov.au>. VIC Environment Protection Authority 2011, Thermal treatment technologies, Information bulletin, EPA, Victoria, available at <www.epa.vic.gov.au>. VIC Environment Protection Authority and WorkSafe Victoria 2005, Industry standard contaminated construction sites: construction and utilities, EPA and Worksafe Victoria, Victoria, available at <www.worksafe.vic.gov.au>.




http://www.worksafe.vic.gov.au/

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WA Department of Environment and Conservation 2006, The use of risk assessment in contaminated site assessment and management: guidance on the overall approach, Contaminated sites management series, DEC, Western Australia, available at <www.der.wa.gov.au>. Sources of information for this section: Canadian Council of Ministers of the Environment 1997, Guidance document on the management of contaminated sites in Canada, PN1279, CCME, Canada. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, NEPC, Australia. Sustainable Remediation Forum Australia, Cooperative Research Centre for Contamination Assessment and Remediation of the Environment, Australian Land and Groundwater Association 2009, A framework for assessing the sustainability of soil and groundwater remediation, SuRF Australia, CRC CARE, ALGA, Australia. WA Department of Environmental Protection 2001, Reporting on site assessments, Contaminated sites management series, DEP, Western Australia. WA Department of Environment and Conservation 2006, The use of risk assessment in contaminated site assessment and management: guidance on the overall approach, Contaminated sites management series, DEC, Western Australia.

8.2 Operational and site-specific plans Following the setting of remediation and management objectives, and the selection of remedial or management strategies, practitioners are able to plan the activities that will be undertaken on a contaminated site. All state and territory environment protection authorities require that practitioners keep accurate and comprehensive records during this planning process. Practitioners will be required to report on site activities at various stages through the assessment, remediation and management process. As discussed earlier in this guideline under Setting the context, the form and content of required records varies across jurisdictions—there may be a single plan or a series of plans—but there is usually an ‘umbrella’ document that details all of the procedures and plans that will be implemented during any remedial or management activity being undertaken on the site. The specific detail provided within these plans is obviously dependent on site-specific objectives and conditions, as well as the particular requirements of state and territory environment protection authorities. Operational and other site-specific planning will always involve careful consideration of the issues involved, but in some situations may require only limited documentation in order to document site activity and meet reporting requirements. At other times, comprehensive plans may need to be developed to guide and record what is occurring on the site, for example, where contamination scenarios and remedial techniques are complex and require significant stakeholder engagement. Along with specific guidance provided by state and territory environment protection authorities and other regulatory agencies (as detailed below), practitioners should consult the Framework for Remediation and Management of Contaminated Sites guidance module, Regulator submission requirements (to be developed). Other guidance modules under the Framework for Remediation and Management of Contaminated Sites which may assist practitioners in developing operational and site-specific plans are:


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• Health and safety (first guideline—Worker(on-site) health and safety—developed 2013, second guideline—Public (off-site) health and safety—to be developed)

• Stakeholder engagement-developed 2014 • Remediation validation and closure (to be developed) • Long-term monitoring (to be developed).

8.2.1 Site preparation and administration Regardless of the type of plan developed for a contaminated site, practitioners will be required to produce documentation relating to site preparation and administration. Likely reporting requirements: site preparation and administration Information that may be required for reporting purposes includes:

• Details of site preparation—fencing, erection of warning signs, stormwater diversion, onsite water usage • Demonstration of compliance with regulatory requirements such as licences and approvals • Remedial or management action schedule, including the expected life of the project • Staged progress reporting schedule • Hours of operation • Names and phone numbers of appropriate personnel to contact during remediation

8.2.2 Planning documentation, record-keeping and reporting—general guidance Practitioners can access specific guidance concerning individual plans (or sections of a single plan) that may be required during the remediation and management of a contaminated site (as described in the following sections of this guideline). There is, however, also a substantial body of general guidance to support practitioners as they prepare site plans and develop systems of record-keeping and documentation. Information about this guidance is provided below. More detailed and/or further information: planning, documentation and record-keeping (general) CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Regulator submission requirements (to be developed) NSW Department of Urban Affairs and Planning 1998, Managing land contamination: Planning guidelines, State Environmental Planning Policy (SEPP) No 55 – Remediation of land, NSW DUAP, New South Wales, available at <www.planning.nsw.gov.au>. NSW Department of Environment and Conservation 2006, Contaminated sites: Guidelines for the NSW site auditor scheme (2nd edition), DEC, New South Wales, available at <www.epa.nsw.gov.au>. NSW Office of Environment and Heritage 2011, Contaminated sites: Guidelines for consultants reporting on contaminated sites, OEH, New South Wales, available at <www.epa.nsw.gov.au>. NT Department of Natural Resources, Environment, The Arts and Sport 2010, Working guidelines for consultants reporting on environmental issues, NRETAS, Northern Territory, available at <www.ntepa.nt.gov.au>.

http://www.planning.nsw.gov.au/



http://www.ntepa.nt.gov.au/

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QLD Department of Environment Heritage and Protection 2012, Guideline for contaminated land professionals, DEHP, Queensland, available at <www.ehp.qld.gov.au>. SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia, available at <www.epa.sa.gov.au>. VIC Environment Protection Authority 2013, State Environmental Protection Policy (Prevention and Management of Contaminated Land), EPA, Victoria, available at <www.epa.vic.gov.au>. WA Department of Environmental Protection 2001, Reporting on site assessments, Contaminated sites management series, DEP, Western Australia, available at <www.der.wa.gov.au >.

8.2.3 Planning documentation, record-keeping and reporting—specific guidance The types of plans that may be required to guide remediation and management activities are listed below. Under each heading, a summary of likely reporting requirements arising from the implementation of the plans is provided. This is followed by information about available guidance that may assist practitioners to understand their documentation and record-keeping responsibilities as they develop and document their own site-specific plans. As a general rule, practitioners will need to demonstrate that they have clearly identified and considered issues likely to occur during the remediation and management project and how they will manage or mitigate those issues. This should include contingency planning, with details provided about what will be done if selected strategies or plans fail. Relevant Commonwealth, state or territory government authorities should be consulted regarding the currency of information, as well as any specific recording and reporting requirements regarding each type of plan. This may involve referral to other relevant government regulatory agencies. 8.2.3.1 Environmental management plan This plan provides detail about the way environmental issues will be addressed during remedial or management works. Likely reporting requirements: environmental management plan Topics that may be relevant include:

• Water management (including surface and groundwater quality, and leachate control) • Wastewater management • Soil management • Noise management (including noise and vibration) • Air management (including dust and odour control) • Waste management (including solid/liquid waste, and special waste (medical, radioactive, chemical) • Hazardous materials management (including scheduled wastes, resource storage, pest control, household

chemicals, compressed/liquid gas) • Flora and fauna





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• Heritage (including indigenous heritage) More detailed and/or further information: environmental management plan Water and wastewater management ACT Environment Protection Authority 2013, Environmental guidelines for preparation of an environment management plan, ACT EPA, Canberra, available at <www.environment.act.gov.au>. NSW Department of Environment and Conservation 2007, Contaminated sites: Guidelines for the assessment and management of groundwater contamination, DEC, New South Wales, available at <www.epa.nsw.gov.au>. SA Environment Protection Authority 2009, Site contamination: Guidelines for the assessment and remediation of groundwater contamination, EPA, South Australia, available at <www.epa.sa.gov.au>. SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia, available at <www.epa.sa.gov.au>. SA Environment Protection Authority 2007, Establishing environmental values and water quality objectives - applying the National Water Quality Management Strategy in South Australia, EPA, South Australia, available at <www.epa.sa.gov.au>. VIC Environment Protection Authority 2002, The clean up and management of polluted groundwater, Information bulletin, Publication 840, EPA, Victoria, available at <www.epa.vic.gov.au>. VIC Environment Protection Authority 2002, State Environmental Protection Policy (Groundwaters of Victoria), EPA, Victoria, available at <www.epa.vic.gov.au>. WA Department of Environment 2004, Use of monitored natural attenuation for groundwater remediation, Contaminated sites management series, D of E, Western Australia, available at <www.der.wa.gov.au >. Soil management ACT Environment Protection Authority 2013, Environmental guidelines for preparation of an environment management plan, ACT EPA, Canberra, available at <www.environment.act.gov.au>. SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia, available at <www.epa.sa.gov.au>. WA Department of Environment and Conservation 2010, Assessment levels for soil, sediment and water, Contaminated sites management series, DEC, Western Australia, available at <www.der.wa.gov.au >. Noise management ACT Environment Protection Authority 2013, Environmental guidelines for preparation of an environment management plan, ACT EPA, Canberra, available at <www.environment.act.gov.au>. SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia, available at <www.epa.sa.gov.au>.

http://www.environment.act.gov.au/home













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Air management (including dust and odour control) ACT Environment Protection Authority 2013, Environmental guidelines for preparation of an environment management plan, ACT EPA, Canberra, available at <www.environment.act.gov.au>. National Environment Protection Council 2003, National Environment Protection (Ambient Air Quality) Measure 2003, as varied, NEPC, Australia, available at <www.scew.gov.au>. SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia, available at <www.epa.sa.gov.au>. WA Department of Environment and Conservation 2011, A guideline for managing the impacts of dust and associated contaminants from land development sites, contaminated sites remediation and other related activities, DEC, Western Australia, available at <www.der.wa.gov.au >. Waste management ACT Environment Protection Authority 2013, Environmental guidelines for preparation of an environment management plan, ACT EPA, Canberra, available at <www.environment.act.gov.au>. QLD Department of Environment Heritage and Protection 2012, Guideline for contaminated land professionals, DEHP, Queensland. VIC Environment Protection Authority 2011, Industrial Waste Resource Guidelines, web resource, <www.epa.vic.gov.au>. WA Department of Environment and Conservation 2009, Landfill waste classification and waste definitions 1996 (as amended 2009), DEC, Western Australia, available at <http://www.wasteauthority.wa.gov.au>. Hazardous materials management ACT Environment Protection Authority 2013, Environmental guidelines for preparation of an environment management plan, ACT EPA, Canberra, available at <www.environment.act.gov.au>. SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia, available at <www.epa.sa.gov.au>. Flora and fauna SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia, available at <www.epa.sa.gov.au>. Heritage SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia, available at <www.epa.sa.gov.au>.







http://www.wasteauthority.wa.gov.au/





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8.2.3.2 Health and safety plans These plans provide details about the way the health and safety of workers, and the public, will be addressed during remedial or management works. Likely reporting requirements: health and safety plans Topics that might be covered in such a plan include:

• General site and project information • Safe systems of work • Induction, training and supervision • Preparing for emergencies • Reporting and record-keeping related to health and safety • Provision of health and safety information to workers and members of the public

More detailed and/or further information: health and safety plans CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Health and safety, (first guideline—Worker (on-site) health and safety—developed 2013, second guideline—Public (off-site)health and safety—to be developed)

VIC Environment Protection Authority and WorkSafe Victoria 2005, Industry standard contaminated construction sites: construction and utilities, EPA and Worksafe Victoria, Victoria, available at <www.worksafe.vic.gov.au>. WA Commission for Occupational Safety and Health 2005, Guidance note: Occupational safety and health management and contaminated sites work, COSH, Western Australia, available at <.http://www.commerce.wa.gov.au>.

8.2.3.3 Stakeholder engagement plan This plan provides details about communicating with stakeholders, including the local community, throughout the remediation and management process, including involvement in decision-making where appropriate. Likely reporting requirements: stakeholder engagement plan Topics that might be covered in such a plan include:

• Identification of relevant stakeholders for the project • Information that will be provided to and sought from stakeholders • How, when and where stakeholder consultation will take place • How input from stakeholders will be considered and incorporated into the decision-making process relating to the

management of the site More detailed and/or further information: stakeholder engagement plan

http://www.worksafe.vic.gov.au/

http://www.commerce.wa.gov.au/

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CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Stakeholder engagement-developed 2014, available at <www.crccare.com>. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, Schedule B (8), Guideline on community engagement and risk communication, NEPC, Australia, available at <www.scew.gov.au>. SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia, available at <www.epa.sa.gov.au>. WA Department of Environment 2003, Community involvement framework, D of E, Western Australia, available at <www.der.wa.gov.au >. WA Department of Environment and Conservation 2006, Community consultation guideline, Contaminated sites management series, DEC, Western Australia, available at <www.der.wa.gov.au >.

8.2.3.4 Other site-specific plans These plans may be required by environment protection authorities or other relevant government agencies when there are particular contamination issues present on the site, e.g. asbestos, or when particular remedial strategies are to be used, e.g. soil bioremediation. Likely reporting requirements: other site-specific plans The content of these plans will depend on site-specific conditions and the particular reporting requirements of state and territory environment protection authorities and other regulatory agencies. More detailed and/or further information: other site-specific plans Asbestos WA Department of Health 2009, Guidelines for the assessment, remediation and management of asbestos-contaminated sites in Western Australia, DOH, Western Australia, available at <www.der.wa.gov.au >. Bioremediation SA Environment Protection Authority 2005, Soil bioremediation, EPA, South Australia, available at <www.epa.sa.gov.au>. WA Department of Environment 2004, Bioremediation of hydrocarbon-contaminated soils in Western Australia, Contaminated sites management series, D of E, Western Australia, available at <www.der.wa.gov.au >. Underground petroleum storage systems (UPSS) NSW Department of Environment, Climate Change and Water 2010, UPSS Technical note: Decommissioning, abandonment and removal of UPSS, DECCW, New South Wales, available at <www.epa.nsw.gov.au>. TAS Environment Protection Authority 2010, Underground petroleum storage systems: decommissioning assessment report

http://www.crccare.com/









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requirements, Technical guideline, EPA, Tasmania, available at <www.epa.tas.gov.au>.

8.2.3.5 Validation plan and closure While remediation validation and closure actually occurs following the completion of remedial or management works on a site, a validation plan is usually developed prior to the start of remedial works. This plan provides a record of the process by which the practitioner intends to measure the outcome of works against the remediation and management objectives. Validation also helps to determine whether any further remediation work or restrictions on land use are required. Likely reporting requirements: validation and closure Likely content for a report arising from the validation plan include:

• Rationale and justification for the validation strategy including clean-up levels and statistically based decision-making methodology, validation sampling and analysis plan

• Details of a statistical analysis of validation results and evaluation against the clean-up levels • Assessment of reasons for any failure to meet targets and proposals for any additional work to be completed to

achieve original objectives • Documentation to confirm disposal of waste (landfill dockets) and certification of clean fill • Verification of compliance with regulatory requirements (licences, approvals and development consents) set by

environment protection authorities and other local and state regulatory agencies—in particular, documentary evidence is often required to confirm that any disposal of soil offsite has been done in accordance with relevant regulations

More detailed and/or further information: remediation validation and closure CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Remediation validation and closure, (to be developed) NSW Environment Protection Authority 1995, Contaminated sites: Sampling design guidelines, EPA, New South Wales, available at <www.epa.nsw.gov.au>. NSW Department of Urban Affairs and Planning 1998, Managing land contamination: Planning guidelines, State Environmental Planning Policy (SEPP) No 55 – Remediation of land, available at <www.planning.nsw.gov.au>. TAS Environment Protection Authority 2011, The site contamination sign-off process, Info Bulletin No 112, EPA, Tasmania, available at <www.epa.tas.gov.au>. WA Department of Environment Protection 2001, Development of sampling and analysis programs, Contaminated sites management series, DEP, Western Australia, available at <www.der.wa.gov.au >.

8.2.3.6 Monitoring and/or ongoing management plan Monitoring and/or ongoing site management plans provide details about the way chemical substances and/or the site will be managed in the long term. Remedial activities may or may not have taken place.

http://epa.tas.gov.au/


http://www.planning.nsw.gov.au/

http://epa.tas.gov.au/epa


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Likely reporting requirements—monitoring and/or ongoing management Sometimes, contaminants may be present on site, for example, in deep soils below the ground but, for the existing or proposed use, it may be more practical and present less environmental and/or health risk for the contaminants to be safely managed onsite. Ongoing management of the site will require documentation about:

• The nature and location of chemical substances remaining on the site • The objectives of long-term management of the site • How the site in general, and remaining chemical substances in particular, will be managed and monitored • Who will be responsible for implementation • Evidence of acceptance by the responsible party to implement the plan • Contingency plans in the case of unsuccessful management measures • Time frames for action and for reporting to relevant government regulatory agencies

In cases of low-risk contamination, an ongoing management plan may be simple one or two page document with minimal conditions relating to excavation and removal of the soil with a supporting plan describing the contamination. In cases involving more significant contamination, the plan may detail more complex conditions including the construction and maintenance of underground containment cells and the monitoring of groundwater. If a specific monitoring plan is required, it will detail the actions, responsibilities and timeframes for monitoring one or more processes, for example, stack emissions, wastewater discharges and groundwater. It will usually also include information on the history of the site, its surrounding environment (including geology and hydrogeology), field and laboratory sampling and analysis plans, as well as quality control and assurance strategies. An ongoing monitoring program should document the following:

• Timeframes, e.g. commencement and expected length of the program • Details about ongoing site monitoring requirements (soil, groundwater, surface water, air emissions), including

monitoring locations, parameters and frequency • Methodology of monitoring, including field and laboratory techniques • Results of monitoring analyses including relevant Quality Analysis/Quality Control reporting • Any pre-determined trigger levels for further action, i.e. to trigger active remediation • Details of party(s) responsible for the monitoring program • Details of reporting frequency • Details of what should be reported and to whom

More detailed and/or further information: monitoring CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Long-term monitoring, (to be developed) QLD Department of Environment Heritage and Protection 2012, Guideline for contaminated land professionals, DEHP, Queensland, available at <www.ehp.qld.gov.au>. SA Environment Protection Authority 2007, Regulatory monitoring and testing – reporting requirements, EPA, South Australia, available at <www.epa.sa.gov.au>. SA Environment Protection Authority 2013, Regulatory monitoring and testing – Monitoring plans requirements, EPA, South Australia, available at <www.epa.sa.gov.au>. WA Department of Environment 2004, Use of monitored natural attenuation for groundwater remediation, Contaminated sites management series, D of E, Western Australia, available at <www.der.wa.gov.au >.





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Sources of information for all sections related to operational and site-specific planning: NSW Department of Environment and Conservation 2006, Contaminated sites: Guidelines for the NSW site auditor scheme (2nd edition), DEC, New South Wales, available at <www.epa.nsw.gov.au>. NSW Office of Environment & Heritage 2011, Contaminated sites: Guidelines for consultants reporting on contaminated sites, OEH, New South Wales. NT Department of Natural Resources, Environment, The Arts and Sport 2010, Working guidelines for consultants reporting on environmental issues, NRETAS, Northern Territory. QLD Department of Environment Heritage and Protection 2012, Guideline for contaminated land professionals, DEHP, Queensland. SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia. WA Department of Environmental Protection 2001, Reporting on site assessments, Contaminated sites management series, DEP, Western Australia.

8.3 Auditing/third party review As described earlier in this guideline, some form of third party review is usually required of remedial or management decisions and works on a contaminated site. Sometimes, however, third party review is only required in situations where there is a change is land use to a more sensitive use or if the contamination at the site is particularly complex. While the form that review takes may vary according to the legislative and regulatory priorities of the relevant Commonwealth, state or territory government authority, the impact of third party review on the work of practitioners is similar across Australia. Practitioners are obliged to develop and make available clear and comprehensive information about all aspects of management of a contaminated site. The purpose of this is so that the third party reviewer (usually the site auditor) can evaluate the condition of the site and form an option as to whether the site is suitable for use. In order to fulfil the requirements of a site audit, the site auditor may be expected to:

• Review any assessment or clean-up work undertaken on the site • Review and evaluate the adequacy of the information provided regarding the condition of the site • Seek further information about the site as necessary.

The relevant guidance module for this topic under the Framework for Remediation and Management of Contaminated Sites is Auditing/third party review (to be developed). Likely requirements: auditing/third party review Third party review of a contaminated site culminates in a report being written by the site auditor for presentation to an environment protection authority or other regulatory agency. There are, therefore, no direct reporting responsibilities belonging to the practitioner in relation to an audit. However, as described above, the practitioner is required to make


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available all of the documentation and records that relate to remediation and management activity on the site. Comprehensive guidance is available for site auditors/third-party reviewers to enable them to fulfil their auditing responsibilities—this guidance is also of value to practitioners, enabling them to gain a solid understanding of the information they may be required to provide. The guidance is listed below. Environment protection authorities in the relevant state or territory should be consulted regarding the currency of information, as well as any specific recording requirements. This may involve referral to other relevant Commonwealth, state or territory government regulatory agencies. More detailed and/or further information: auditing/third party review CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Auditing/third party review, (to be developed) NSW Department of Environment and Conservation 2006, Contaminated sites: Guidelines for the NSW site auditor scheme (2nd edition), DEC, New South Wales, available at <www.epa.nsw.gov.au>. SA Environment Protection Authority 2010, Guidelines for the site contamination audit system, EPA, South Australia, available at <www.epa.sa.gov.au>. VIC Environment Protection Authority 2007, Environment auditor (contaminated land): Guidelines for issue of certificates and statements of environmental audit, EPA, Victoria, available at <www.epa.vic.gov.au>. VIC Environment Protection Authority 2007, Environmental auditor guidelines for conducting environmental audits, Publication 953.2, EPA, Victoria, available at <www.epa.vic.gov.au>. VIC Environment Protection Authority 2013, Preparation of environmental audit reports on risk to the environment, Publication 952.41, EPA, Victoria, available at <www.epa.vic.gov.au>. WA Department of Environment and Conservation 2009, Contaminated sites auditors: guidelines for accreditation, conduct and reporting, Contaminated sites management series, DEC, Western Australia, available at <www.der.wa.gov.au >. Sources of information for this section: NSW Office of Environment and Heritage 2011, Contaminated sites: Guidelines for consultants reporting on contaminated sites, OEH, New South Wales. VIC Environment Protection Authority 2007, Environmental auditor guidelines for conducting environmental audits, Publication 953.2, EPA, Victoria.

8.4 Institutional controls The placement of institutional controls over a particular contaminated site may occur following the completion of remedial works or in the absence of remedial works. While specific approaches vary across Australia’s states and territories, land-use planning processes such as development approvals are often used to apply controls to monitor or regulate activity on a site. Some of the controls currently used in Australia include:

• notations on land titles







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• the use of contaminated land registers and management plans to apply conditions to the use or development of sites or the activities undertaken on sites

• conditions on planning permits • agreements with planning authorities • pollution abatement notices • clean-up notices.

Accurate and comprehensive documentation and record-keeping by the practitioner during all remedial or management activities ensures that environment protection authorities are able to access the information required to make important and long-term decisions about the management of a contaminated site. The relevant guidance module for this topic under the Framework for Remediation and Management of Contaminated Sites is Institutional controls (to be developed). Likely requirements: institutional controls The placement of institutional controls is a responsibility of the relevant Commonwealth, state or territory agency. There are, therefore, no direct reporting responsibilities belonging to the practitioner in relation to institutional controls. However, as described above, the practitioner is required to make available all of the documentation and records that relate to remediation and management activity on the site. More detailed and/or further information: institutional controls CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Institutional controls, (to be developed) Cooperative Research Centre for Contamination Assessment and Remediation of the Environment 2011, Contaminated sites law and policy directory, CRC CARE, South Australia, <www.cslawpolicy.com>. Sources of information for this section: Cooperative Research Centre for Contamination Assessment and Remediation of the Environment 2011, Contaminated sites law and policy directory, CRC CARE, South Australia, <www.cslawpolicy.com>.

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9 REFERENCES

9.1 Framework for Remediation and Management of Contaminated Sites Materials

9.1.1 Development of remediation and management plan CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Site-specific remediation objectives, (to be developed). CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Identifying remedial options, (to be developed). CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Selection of remediation technologies, (to be developed). CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Treatability studies, (to be developed). CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Cost-benefit analysis, (to be developed). CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Regulator submission requirements, (to be developed).

9.1.2 Implementation of remediation and management plan CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Health and safety, (first guideline—Worker (on-site) health and safety—developed 2013, second guideline—Public (off-site) health and safety—to be developed) CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Stakeholder engagement-developed 2014

9.1.3 Post-remediation considerations CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Long-term monitoring, (to be developed). CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Auditing/third party review, (to be developed). CRC CARE, Framework for Remediation and Management of Contaminated Sites Module, Institutional controls, (to be developed).

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9.2 NEPM Materials National Environment Protection Council 2003, National Environment Protection (Ambient Air Quality) Measure 2003, as varied, NEPC, Australia. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, NEPC, Australia. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, Schedule B (1), Guideline on investigation levels for soil and groundwater, NEPC, Australia. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, Schedule B (2), Guideline on site characterisation, NEPC, Australia. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, Schedule B (3), Guideline on laboratory analysis of potentially contaminated soils, NEPC, Australia. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, Schedule B (8), Guideline on community engagement and risk communication, NEPC, Australia. National Environment Protection Council 1999, National Environment Protection (Assessment of Site Contamination) Measure, as varied 2013, Schedule B (9), Guideline on competencies and acceptance of environmental auditors and related professionals, NEPC, Australia.

9.3 Jurisdictional guidance

9.3.1 Australian Capital Territory ACT Environment Protection Authority 2013, Environmental guidelines for preparation of an environment management plan, ACT EPA, Canberra.

9.3.2 New South Wales NSW Department of Environment and Conservation 2007, Contaminated sites: Guidelines for the assessment and management of groundwater contamination, DEC, New South Wales.

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NSW Department of Environment and Conservation 2006, Contaminated sites: Guidelines for the NSW site auditor scheme (2nd edition), DEC, New South Wales. NSW Department of Environment, Climate Change and Water 2010, UPSS Technical note: Decommissioning, abandonment and removal of UPSS, DECCW, New South Wales. NSW Environment Protection Authority 1995, Contaminated sites: Sampling design guidelines, EPA, New South Wales. NSW Department of Urban Affairs and Planning 1998, Managing land contamination: Planning guidelines, State Environmental Planning Policy (SEPP) No 55 – Remediation of land, NSW DUAP, New South Wales. NSW Office of Environment and Heritage 2011, Contaminated sites: Guidelines for consultants reporting on contaminated sites, OEH, New South Wales.

9.3.3 Northern Territory NT Department of Natural Resources, Environment, The Arts and Sport 2010, Working guidelines for consultants reporting on environmental issues, NRETAS, Northern Territory.

9.3.4 Queensland QLD Department of Environment Heritage and Protection 2012, Guideline for contaminated land professionals, DEHP, Queensland.

9.3.5 South Australia SA Environment Protection Authority 2013, Regulatory monitoring and testing – Monitoring plans requirements, EPA, South Australia. SA Environment Protection Authority 2010, Guidelines for the site contamination audit system, EPA, South Australia. SA Environment Protection Authority 2009, Site contamination: Guidelines for the assessment and remediation of groundwater contamination, EPA, South Australia. SA Environment Protection Authority 2008, EPA Guidelines for environmental management of on-site remediation, EPA, South Australia. SA Environment Protection Authority 2007, Establishing environmental values and water quality objectives - applying the National Water Quality Management Strategy in South Australia, EPA, South Australia.

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SA Environment Protection Authority 2007, Regulatory monitoring and testing – reporting requirements, EPA, South Australia. SA Environment Protection Authority 2005, Soil bioremediation, EPA, South Australia.

9.3.6 Tasmania TAS Environment Protection Authority 2011, The site contamination sign-off process, Info Bulletin No 112, EPA, Tasmania. TAS Environment Protection Authority 2010, Underground petroleum storage systems: decommissioning assessment report requirements, Technical guideline, EPA, Tasmania.

9.3.7 Victoria VIC Environment Protection Authority 2013, Preparation of environmental audit reports on risk to the environment, Publication 952.41, EPA, Victoria. VIC Environment Protection Authority 2013, State Environmental Protection Policy (Prevention and Management of Contaminated Land), EPA, Victoria. VIC Environment Protection Authority 2011, Industrial Waste Resource Guidelines, web resource, <www.epa.vic.gov.au>. VIC Environment Protection Authority 2011, Industrial Waste Resource Guidelines - Soil Remediation technologies in Victoria, EPA, Victoria. VIC Environment Protection Authority 2011, Thermal treatment technologies, Information bulletin, EPA, Victoria. VIC Environment Protection Authority 2007, Environment auditor (contaminated land): Guidelines for issue of certificates and statements of environmental audit, EPA, Victoria. VIC Environment Protection Authority 2007, Environmental auditor guidelines for conducting environmental audits, Publication 953.2, EPA, Victoria. VIC Environment Protection Authority and WorkSafe Victoria 2005, Industry standard contaminated construction sites: construction and utilities, EPA and Worksafe Victoria, Victoria. VIC Environment Protection Authority 2002, State Environmental Protection Policy (Groundwaters of Victoria), EPA, Victoria. VIC Environment Protection Authority 2002, The clean up and management of polluted groundwater, Information bulletin, Publication 840, EPA, Victoria.

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9.3.8 Western Australia WA Commission for Occupational Safety and Health 2005, Guidance note: Occupational safety and health management and contaminated sites work, COSH, Western Australia. WA Department of Environment 2004, Bioremediation of hydrocarbon-contaminated soils in Western Australia, Contaminated sites management series, D of E, Western Australia. WA Department of Environment 2004, Use of monitored natural attenuation for groundwater remediation, Contaminated sites management series, D of E, Western Australia. WA Department of Environment 2003, Community involvement framework, D of E, Western Australia. WA Department of Environment and Conservation 2011, A guideline for managing the impacts of dust and associated contaminants from land development sites, contaminated sites remediation and other related activities, DEC, Western Australia. WA Department of Environment and Conservation 2010, Assessment levels for soil, sediment and water, Contaminated sites management series, DEC, Western Australia. WA Department of Environment and Conservation 2009, Contaminated sites auditors: guidelines for accreditation, conduct and reporting, Contaminated sites management series, DEC, Western Australia. WA Department of Environment and Conservation 2009, Landfill waste classification and waste definitions 1996 (as amended 2009), DEC, Western Australia, WA Department of Environment and Conservation 2006, The use of risk assessment in contaminated site assessment and management: guidance on the overall approach, Contaminated sites management series, DEC, Western Australia. WA Department of Environment and Conservation 2006, Community consultation guideline, Contaminated sites management series, DEC, Western Australia. WA Department of Environmental Protection 2001, Development of sampling and analysis programs, Contaminated sites management series, DEP, Western Australia. WA Department of Environmental Protection 2001, Reporting on site assessments, Contaminated sites management series, DEP, Western Australia. WA Department of Health 2009, Guidelines for the assessment, remediation and management of asbestos-contaminated sites in Western Australia, DOH, Western Australia.

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9.4 Other references Canadian Council of Ministers of the Environment 1997, Guidance document on the management of contaminated sites in Canada, PN1279, CCME, Canada. Cooperative Research Centre for Contamination Assessment and Remediation of the Environment 2011, Contaminated sites law and policy directory, CRC CARE, South Australia, <www.cslawpolicy.com>. Sustainable Remediation Forum Australia, Cooperative Research Centre for Contamination Assessment and Remediation of the Environment, Australian Land and Groundwater Association 2009, A framework for assessing the sustainability of soil and groundwater remediation, SuRF Australia, CRC CARE, ACLCA, Australia.

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APPENDIX A: EXAMPLE REMEDIATION AND MANAGEMENT PLAN This appendix provides an example of the content that may be covered in a remediation and management plan. It incorporates information that may need to be gathered, developed and reported at any stage during the assessment, remediation and management of a contaminated site. During the implementation of the remediation and management plan, reporting requirements usually allow for a summary of information to be provided where it has been reported in detail to the same regulatory agency on a previous occasion. Where relevant, this is noted on this example plan. Material particularly relevant to this guideline is listed under the heading, Remedial and/or management planning. Environment protection authorities and other appropriate government agencies in the relevant state or territory should always be consulted regarding any specific requirements. This may involve referral to other relevant Commonwealth, state or territory government regulatory agencies. The information in this example plan is based on guidance provided in NSW’s Guidelines for consultants reporting on contaminated sites, developed by the NSW Office of Environment & Heritage, and available at <www.epa.nsw.gov.au>. This example plan also incorporates material from the following guidance materials, some of which were adapted from the NSW guidelines (see Reference section for source details):

• NT Department of Natural Resources, Environment, The Arts and Sport 2010, Working guidelines for consultants reporting on environmental issues

• QLD Department of Environment Heritage and Protection 2012, Guideline for contaminated land professionals

• SA Environment Protection Authority 2010, Guidelines for the site contamination audit system • WA Department of Environmental Protection 2001, Reporting on site assessments • ACT Environment Protection Authority 2013, Environmental guidelines for preparation of an environment

management plan

EXAMPLE CONTENT OF A REMEDIATION AND MANAGEMENT PLAN

Executive summary Information in this section includes:

• background • objectives of remediation and management of the site • scope of works • summary of sampling results/previous investigations • summary of conclusions and recommendations


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Scope of work Information in this section includes a clear statement of the scope of work.

Site identification Information in this section includes:

• Property name, street number, street name and suburb • Land title details, e.g. mine lease northern references, lot number, land titles office plans, tenure type, parcel and

unit references • Geographic co-ordinates related to a nearby cadastral corner of a state survey control marker or recognised

reference mark (where the contamination is limited to a portion of a lot) • Locality map • Current site plan with scale bar, showing north, infrastructure, lot on plan boundaries, local water drainage and

other local environmentally significant features • Legal framework, including local government authority, decision-making authorities and involved agencies.

Site history (summary adequate if detailed information previously provided) Information in this section includes details about:

• Land owner—past and present • Zoning—previous, present and proposed (including chronological list of site uses, indicating information gaps and

unoccupied periods) • Land use—previous, present and proposed • Heritage (including Aboriginal heritage) • Surrounding land use and zoning—historical, present and proposed • Summary of council rezoning, relevant development and building approvals records • Review of aerial photographs—current and historical • Site photographs (with date and location indicated on site maps, direction photo was taken) • Inventory of chemicals, wastes and by-products associated with site use and their on-site storage location • Possible contaminant/pollutant sources and potential off-site effects • Site layout plans showing present and past industrial processes • Sewer and service plans • Description of manufacturing processes • Details and locations of current and former underground and above-ground storage tanks • Product spill and loss history • Discharges to land, water and air • Disposal locations • Filling history (where applicable) • Relevant complaint history • Discharges to land, water and air • Disposal locations • Local site knowledge of residents and staff—both present and former • Summary of local literature about the site, including newspaper articles • Details of building and related permits, licences, approvals and trade waste agreements • Local usage of ground/surface waters, and location of bores/pumps

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Site condition and surrounding environment (summary adequate if detailed information previously provided) A summary is adequate if detailed information was included in an available referenced previous report. Information in this section should include details about:

• Data quality assessment (assessment of the accuracy of information) • Topographical layout and contours, drainage patterns • Conditions at site boundary such as type and condition of fencing, soil stability and erosion • Visible signs of contamination such as discolouration or staining of soil, bare soil patches—both on-site and off-

site adjacent to site boundary • Visible signs of vegetation stress • Presence of drums, wastes and fill material • Odours • Condition of buildings and roads • Quality of surface water • The proportion of site sealed and unsealed, integrity of seal, e.g. whether the concrete hardstand is cracked • Flood potential • Type, location and distance to any human receptors in proximity to the site • Details of any relevant local sensitive environments, e.g. rivers, lakes, creeks, wetlands, local habitat areas,

endangered flora and fauna.

Geology and hydrogeology (summary adequate if detailed information previously provided) Information in this section includes details about:

• Soil stratigraphy using recognised classification methods, e.g. Australian Standard 1726, Unified Soil Classification Table

• Location and extent of imported and locally derived fill • Description of soil contamination, actual/potential contaminants (solubility, density, stability, persistence and

partitioning characteristics) • Site borehole logs or test pit logs showing stratigraphy • Detailed description of the location, design and construction of on-site wells • Description and location of springs and wells in the vicinity • Groundwater conditions (e.g. unconfined, confined, ephemeral and perched), known or expected depth to

groundwater table, direction and rate of flow and ambient groundwater quality • Presence of multi-layered aquifer • Direction and rate of groundwater flow • Permeability of strata on the site • Direction of surface water run-off • Groundwater discharge location • Ambient groundwater chemistry • Groundwater/surface water interaction • Beneficial use of groundwater in the vicinity such as public drinking water supply and source areas, domestic

irrigation, aquatic ecosystems, and the potential impacts on these uses • Background water quality • Preferential water courses/migratory pathways • Location of sensitive receptors/users • Summary of local meteorology • Assessment on storm surge impacts from inundation and wave motion.

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Basis for assessment criteria Information in this section includes:

• Table listing all selected assessment criteria/levels and references • Rationale for and appropriateness of the selection of assessment levels criteria • Assumptions, uncertainties and limitations of assessment levels criteria. • Adjustment of assessment criteria for composite sampling in jurisdictions where such sampling is accepted.

Results Information in this section includes:

• Summary of previous results, if appropriate • Summary of all results for all environmental media (surface waters, groundwaters, sediments, soil and air), in a

table that: - shows all essential details such as sample numbers and sampling features, e.g. depth and points - shows assessment criteria levels - highlights all results exceeding the assessment criteria levels

• Site plan showing all sample locations, sample identification numbers and sampling features, e.g. depths in soil and sediment, extent in groundwater plumes

• Site plan showing the extent of solid and groundwater contamination /pollutant exceeding selected assessment criteria levels for all media (with consideration of the sampling features, e.g. depth in soil and sediment, extent of groundwater plumes).

Site characterisation/risk assessment Information in this section includes details about:

• Assessment/characterisation of type of all environmental contamination/pollutants in all media, e.g. soil, soil gas and groundwater

• Assessment of extent of soil and groundwater contamination, including off-site effects • Assessment of the chemical degradation • Assessment of possible exposure routes and exposed populations, i.e. human and ecological/health risk

assessment • Assessment of receiving environment’s sensitivity/ecological risk assessment

Remedial and/or management planning Information in this section includes:

• Remediation and management objectives • Discussion of the extent of remediation required • Discussion of possible remediation and management options and how risk can be reduced • Discussion of community involvement in selection of remediation and management options • Rationale for the selection of recommended remedial options • Contingency planning as required for site incidents/failure of remedial or management strategies • Justification of the chosen option against other available technologies or management options where the method

chosen is not consistent with the hierarchy of options for site remediation or management. • Interim site management/preparation plan (prior to commencing remedial actions), including fencing, erection of

warning signs, stormwater diversion, onsite water usage

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• Demonstration of compliance with regulatory requirements such as licences and approvals • Remedial and management action schedule, including expected life of project • Hours of operation • Names and phone numbers of appropriate personnel to contact during remediation • Staged progress reporting • Operational and other site-specific plans that include details about managing and/or mitigating potential impacts,

incorporating the following components: - Environmental management, including:

Water management (including surface water and groundwater quality, and leachate control) Wastewater management Soil management Noise management (including noise and vibration) Air management (including dust and odour control) Waste management (including solid/liquid waste, and special waste (medical, radioactive,

chemical) Hazardous materials management (including scheduled wastes, resource storage, pest control,

household chemicals, compressed/liquid gas) Flora and fauna Heritage (including indigenous heritage)

- Health and safety plan—worker (on-site) - Health and safety plan—public (off-site) - Stakeholder engagement plan - Long-term site management plan - Other site-specific plans, e.g. bioremediation strategy, asbestos, underground petroleum storage systems - Validation plan - Monitoring plan

Conclusions and recommendations Information in this section should include:

• Brief summary of all findings • Assumptions used in reaching the conclusions • Extent of uncertainties in the results • Where remedial action has been taken, a list summarising the activities and physical changes to the site • Where relevant, a clear statement that the practitioner considers that there is a potential for off-site migration and

the main issues that need to be considered to address the off-site issues • Summary of engagement outcomes and agreements reached prior to remediation and management activities

taking place • A clear statement that the practitioner considers the subject site to be suitable for the proposed use, with a draft

site management plan included • A statement detailing all limitations and constraints on the use of the site • Recommendation for further work, if appropriate.

Remediation and management of contaminated …...During the remediation and management of...

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