Assessment & remediation
What is the process for assessing site contamination?
The assessment of site contamination is a process incorporating a set of formal methods used for determining the nature, extent and amount of existing chemical substances either on or off-site. Then the actual or potential risk to human health or the environment, resulting from those substances, can be determined, also using formal methods.
The National Environment Protection (Assessment of Site Contamination) Measure (NEPM) provides recommended methods for assessment and guidelines on the process (see below).
A review of site contamination guidance is being carried out by the EPA.
When should the assessment of site contamination be undertaken?
The assessment of site contamination should be undertaken whenever contamination has been identified at a site, or when there is a reasonable suspicion of site contamination arising from a current or previous activity or use of the site.
This provides a 'trigger' to initiate the recommended processes for assessment outlined in Schedule A of the site contamination NEPM.
Planning Advisory Notice 20 provides a list of potentially contaminating activities and land uses that should be used as a trigger by planning authorities and others to initiate the need for the assessment of site contamination.
Use of these triggers and following the assessment process should ensure that there is adequate protection of human health and the environment wherever site contamination has occurred.
Who can undertake the assessment of site contamination?
Site contamination assessment is a complex and specialised professional area involving a number of disciplines, and consequently should only be undertaken by environmental auditors and environmental consultants who have a range of competencies and relevant qualifications and experience.
Site contamination consultants are specifically defined in the Environment Protection Act 1993 as people who assess the existence or nature or extent of site contamination.
Site contamination auditors are also specifically defined in the Environment Protection Act 1993 as people who are accredited by the EPA. It is an offence to call yourself or another person a site contamination auditor if not accredited by the EPA.
There is a clear distinction between the roles of a site contamination auditor and a site contamination consultant or remediation consultant/contractor carrying out remediation:
- The integrity of the audit system depends on the independence and integrity of the auditor.
- In South Australia, the EPA advises the use of site contamination auditors accredited by the EPA under the Environment Protection Act 1993 to:
- undertake independent reviews of the assessment and remediation of sites generally undertaken by site contamination consultants, and
- assess the suitability of a site proposed for a 'sensitive land use'.
- A site contamination consultant or remediation consultant/contractor is engaged to:
- assess site contamination for a variety of reasons. Engagement of a consultant is undertaken in accordance with the terms and conditions of that company or, in some cases, to complete an agreed scope of works. The outcome of the engagement of an environmental consultant is the completion of the scope of work, or an agreed amended scope of work, and the issue of a report to the client.
How can I find an auditor?
For further details, click through to the site contamination audit system.
How can I find and select a consultant?
Environmental site assessment is a complex and specialised professional area involving a range of disciplines.
Site contamination consultants undertake site contamination assessments and should investigate both human health and environmental issues. They are required to possess a wide range of skills and knowledge.
Selecting a consultant should be undertaken with care, as the quality and results of the assessment undertaken is dependent on the competency of the consultant. Selection should be similar to the process used when acquiring any professional service.
The EPA recommends all of the following to assist in finding an appropriately experienced consultant:
- Contact a company that employs a site contamination auditor accredited by the EPA. For contact details of these companies, refer to the list of auditors.
- Contact the South Australian branch of the Australian Contaminated Land Consultants Association (ACLCA) for a list of current members on 0421 708 757.
- Select a consultant certified under the Site Contamination Practitioners Australia (SCP Australia) scheme.
- Seek advice from a trusted person who has previously engaged an environmental consultant and has demonstrated acceptable standards of competency and completed similar projects successfully.
For further details, click through to site contamination consultants.
How are auditors different from consultants?
There is a clear distinction between the roles of an auditor and a consultant:
- The integrity of the audit system depends on the independence and integrity of the auditor.
The EPA endorses and recommends the use of persons accredited by the EPA as site contamination auditors to:
- undertake independent reviews of the assessment and remediation of sites generally undertaken by environmental consultants and to assess the suitability of a site proposed for a 'sensitive use'.
- A consultant is engaged to assess site contamination for a variety of reasons. Engagement of a consultant is undertaken in accordance with the terms and conditions of that company or, in some cases, to complete an agreed scope of works.
The outcome of the engagement of an consultant is the completion of the scope of work, or an agreed amended scope of work, and the issue of a report to the client.
What happens after an auditor recommends a Groundwater Prohibition Area (GPA)?
At the conclusion of a site contamination audit, the auditor will prepare a report with recommendations for the EPA in relation to contaminated groundwater. These may include the establishment of a groundwater prohibition or restriction area. If a groundwater prohibition area is recommended the EPA may need to undertake its own investigations in order to implement a strategy that achieves the best outcomes for the community.
To establish a prohibition or restriction area, the EPA must be satisfied that
- there is site contamination that affects or threatens water, and
- action is necessary under this section to prevent actual or potential harm to human health or safety.
The EPA will engage with the local community to determine the best method for protecting users from groundwater contamination and also to minimise any unnecessary impact to their livelihoods.
I'm looking for information on a property – what information does the EPA provide?
In relation to site contamination, the EPA answers questions relating to 'Particulars Relating to Environment Protection' set out in Regulations under the Land and Business (Sale and Conveyancing) Act 1994 which identify whether the EPA holds a copy of a report on any environmental assessment of the land or part of the land:
- by or on behalf of the owner or occupier pursuant to certain sections of the Environment Protection Act 1993, or for the purposes of a notification under Section 83, or
- by the EPA (alone or jointly with another authority), or
- by an auditor.
In addition, the EPA has to answer questions in relation to the historical operation of waste depots, the production of certain wastes and the deposition of waste on land in relation to approvals or authorisations under specific former legislation and certain EPA authorisations.
This information is provided in the form of a Section 7 EPA response letter.
Any person can make an enquiry, called a Section 7 direct enquiry, to the EPA on payment of a fee. The EPA will then provide information about the issues described above where this information is retained by the EPA.
To make an enquiry contact the EPA Senior Administration officer, Section 7 on (08) 8204 2179. For further information, see the Information Sheet: Section 7, Land and Business (Sale and Conveyancing) Act 1994 and the role of the EPA.
In addition, the EPA provides information relating to the identification of potential or actual serious or material environmental harm which has been recorded on the Public Register.
For further information, read through the site contamination information.
These questions have been updated to reflect the additional information that will be held by the EPA as a result of the site contamination legislation.
Where can I get Planning Advisory Notice 20?
Planning Advisory Notice 20 has been issued by Planning SA and describes the roles and responsibilities of planning authorities in addressing site contamination through the Plan Amendment Report (PAR) process and when assessing development applications.
For further details on the planning advisory notice, see current planning processes.
A 'sensitive use', in relation to site contamination, means one involving a residential use (including all forms of residential use such as medium and high density developments and retirement villages), a pre-school (including a childcare centre) or a primary school.
What should be done about underground storage tanks?
Underground storage tanks (UST) or systems (USS) are a major source of soil and groundwater contamination.
The EPA recommends the removal of all USS that are no longer being used for the originally intended purpose (ie storage of petroleum products or other hazardous materials).
A suitably qualified and experienced site contamination consultant should be engaged to assess the site to determine whether there has been any impact to soil or groundwater.
An independent auditor may also be required to review the work completed by the consultant and ensure the site is suitable for its intended use, depending on the land use proposed and the nature and extent of site contamination issues.
For further details, including information on appropriate guidelines and the development of a South Australian code of practice, check out underground storage systems.
The National Environment Protection (Assessment of Site Contamination) Measure (NEPM) was made in December 1999.
The Site Contamination NEPM operates as an environment protection policy under the Environment Protection Act 1993.
The aim of the measure is to provide adequate protection of human health and the environment, where contamination has occurred, through the development of an efficient and effective national approach to environmental site assessment.
The Site Contamination NEPM contains schedules and a number of guidelines, which are available online from the Environment Protection and Heritage Council (EPHC).
Remediation is the treatment, containment, removal or management of chemical substances or wastes so that they no longer represent actual or potential risk to human health or the environment, taking into account the current or intended use of the site.
The majority of remediation methods involve activities on the site, even though the treatment and disposal of materials may occur elsewhere.
Remediation may also involve activities that occur off-site. Several methods may be used on a site, particularly where remediation of contaminated groundwater is necessary.
Poorly managed remediation may result in adverse impacts on human health, property and the environment.
Methods and processes used in remediation, which can range from relatively straightforward earthmoving operations to complex technological treatment processes, may also result in adverse impacts to the environment and adjoining land occupiers, if not properly managed.
The EPA has published Guidelines for environmental management of on-site remediation that explain the expectations of the EPA for those who undertake remediation.
The guidelines describe in detail the environmental aspects that must be considered, and planned for, before starting a remediation project. It is anticipated that careful planning prior to remediation will result in the control of both predictable and preventable environmental impacts.
Certain types of remediation may also require development approval and an authorisation (or licence) from the EPA.
Contact the EPA Site Contamination Branch for further information.
What is done about the impact of remediation works on neighbouring land?
A significant issue in remediation projects, particularly remediation that occurs on large areas of land or over an extended time period, is the potential impact this may have on adjoining and adjacent land uses. This becomes a critical issue where these are sensitive land uses (such as residential uses).
The EPA expects that such remediation projects will include well-designed and implemented communication and community consultation programs.
Where there is potential for adjacent land uses to be affected by the remediation project (for example by dust, noise or potential damage to property) it is necessary to ensure that the local community is informed of the nature and extent of the remediation prior to the commencement of the remediation as well as during the remediation. They must also be made aware of any issues of potential concern and measures put in place to address them.