Allenby Gardens - Flinders Park
The EPA established a groundwater prohibition area in the Allenby Gardens/Flinders Park area on 13 June 2013 by notice in the Government Gazette.
Groundwater from the first and second quaternary aquifers (0–30 m below the ground surface) is prohibited to be used for any purpose in the identified area now that the prohibition is in effect.
Under the Environment Protection Act 1993, it is now an offence to use groundwater from the first and second quaternary aquifers for any purpose in the prohibition area. A maximum penalty of $8,000 applies.
The groundwater contamination has resulted from the past excavation of clay material for brick making, and subsequent uncontrolled backfilling of the excavation with industrial waste material. Chemicals present in the backfilled waste materials have contaminated the groundwater.
The EPA will notify owners/occupiers within the groundwater prohibition area if there is a substantial change in the groundwater contamination and/or where a modification of the established area is warranted.
The establishment of a groundwater prohibition area remains the best approach to protect current and future residents from historic groundwater contamination within the Allenby Gardens/Flinders Park area.
The establishment of the groundwater prohibition area follows community consultation undertaken by the EPA in 2013. Residents were first advised by the EPA in February 2013 of the proposal to prohibit the taking of groundwater in the area.
Community consultation included a series of letters delivered to owners/occupiers of properties within the prohibition area and three open-house information sessions which were offered to provide residents and the community with an opportunity to discuss any concerns. Letters and information sheets provided by the EPA are available below.
For further information in relation to this matter, please contact the EPA on 1800 729 175 during weekdays between the hours of 8 am and 5 pm
- Media release, 14 June 2013
- Media release, 13 February 2013
- Letter to residents, 8 February 2013
- Letter to residents, 3 June 2013
- Map of water prohibition area
EPA response to questions asked at the February and April 2013 community meetings
I live at Flinders Park (outside the prohibition area) and use a bore (11 metres in depth) - will the plume extend?
The contaminant source that was within the pughole has been removed. The plume will not continue to extend past the water prohibition area - unless people inside the water prohibition area use groundwater. The plume is expected to shrink through natural processes but not until around 2050.
The EPA does not undertake testing for this purpose. The use of the upper 2 aquifers will be banned. If you think that your bore is constructed into a deeper aquifer (greater than 30 m), then you should confirm the depth through measurement. The EPA and Department for Health and Ageing recommend that all groundwater (where use is permitted) is tested prior to use.
Can the EPA provide an information pack re geological and hydrogeological issues? I would also like to access documents/reports from the Public Register.
I would like some information regarding the depth of roots as we grow grape vines and consume the fruit. I would also like to know the depth of olive tree roots.
The Department for Health and Ageing has advised the EPA:
Our assessment of the available literature indicates that the likelihood is low, of fruits and vegetables grown in soil near contaminated groundwater, containing TCE and related compounds at levels that might represent a risk to health. Typically SA Health advises that in areas impacted by TCE contaminated groundwater, home grown vegetables are safe and do not pose an appreciable risk to residents who consume them, provided they are not watered with contaminated groundwater.
Olive trees have a shallow root system and the active root zone for water uptake is generally limited to the upper 0.5 to 1 metre of soil. The groundwater is 7 to 10 metres below the ground surface and not utilised by the olive tree roots.
Can we have a copy of the aquifer picture?
The EPA would be happy to provide any drawings upon request. Please contact the EPA Site Contamination Branch on 1800 729 175 or email.
I would like to receive information regarding the water prohibition area and other contaminated sites around Adelaide.
Please see the site contamination pages.
I have a registered bore drilled in late 90s and I only use it to irrigate my garden, is this OK?
No, all use of bore water, in the upper two aquifers and within the designated area, is prohibited.
I have an unregistered bore and I only use the water to flush toilet, is this OK?
No, all use of bore water, in the upper 2 aquifers and within the designated area, is prohibited.
I have a registered bore and I am not sure whether it is in the Q2 or deeper. I would like the EPA to check depth and test the quality. I only use the water on my fruit trees?
Please see the response to Question 2 above.
I live at Woodville South. I have a bore and I have received a notification in the past of contamination. I filter the groundwater. I would like EPA to check his area regarding the use of this bore?
This area is currently not subject to prohibition. The EPA and Department for Health and Ageing recommend that all groundwater (where use is permitted) is tested prior to use.
I don't have a bore but I do have an orange tree - I would like to receive an update.
The use of your orange tree is not impacted by this prohibition. The root depths for orange trees vary from 1.2 to 3 metres depending on water availability. The groundwater is 7 to 10 metres below the ground surface and not utilised by the orange tree roots. Please also see the response to Question 4.
I have a bore that was tested in May 2005 and April 2008 and the results were all clear. Can I continue to use my bore?
If you are within the prohibition area you must not use your bore. Its continued use could draw the contaminated plume toward your property.
I have a grapevine - I would like to check if it is safe to eat the grapes?
Please see the response to Question 4.
Will there be further information given to the community - will it be conveyed via The Messenger? Will there be another meeting?
The EPA has held 3 community information sessions during February and April 2013. The third session in April was primarily intended for non-English speaking residents. No further sessions are planned. If the community would like to contact the EPA then please telephone the EPA Site Contamination Branch on 1800 729 175 or email.
Can I please have information about the consultants and auditor that were engaged for source site?
All reports are available on the EPA Public Register. The EPA Public Register can be accessed by calling 8204 2004 or 1800 623 445 or email.
My father owns a house on Frobisher Avenue which is on the boundary of prohibition area and has a bore approximately 15 metres in depth. Do we need to remove fruit trees? Does the bore need to be de-commissioned?
Please see the response to Question 4. The bore may remain in place but must not be used.
Is there a soil vapour issue like at Edwardstown and Clovelly Park?
For this area, the auditor concluded that:
The groundwater contamination at the site (and off-site) does not pose an unacceptable risk to human health via the volatile migration and air inhalation pathway. No groundwater remediation or site management measures are required to further reduce this [vapour inhalation] risk.
Will the prohibition area boundary change in the future?
The groundwater conditions change very slowly over time. The boundary may be reduced in the future with further monitoring. No changes would be expected for at least ten years.
Why can't this apply just to people with bores and everyone else is excluded?
The EPA does not have the powers to enter a domestic premises to determine who does or does not have a bore. Even if the EPA could legally do this, a person could illegally (intentionally or unintentionally) install and use a bore in the subsequent days, months or years. This subsequent action could then impact on many people and there would be no penalty for using the water (in the absence of the prohibition area). The Environment Protection Act 1993 provides powers for the EPA to prohibit the taking of contaminated water. The Act establishes a penalty for those who use the bore water within the prohibition area. This legislative mechanism provides a long-term way of trying to make sure that people don't use the contaminated groundwater.
Why can't the EPA concrete up all the registered and unregistered bores?
The Department of Water and Natural Resources has advised in reference to s145(2)(iii) of the Natural Management Resource Act, 2004 - if the power is utilised to direct a well to be plugged, backfilled or sealed, a notice would be served on the landowner or occupier of the land to undertake the works delineated in the notice at the owner/occupiers cost.
The groundwater prohibition area is likely to be in place until 2050. It is very important that all current and future owners do not access contaminated groundwater. It is important that the knowledge of the contamination and the need to not use the water is not lost and is passed on for decades to come.
The EPA will flag its interest in the certificates of title within the prohibition area with the Land Titles Office. Notice will then be given to any interested parties on the Form 1 statement (which forms part of the contract of sale) via Section 7 of the Land and Business (Sale and Conveyancing) Act 1994 where it is shown as a prescribed encumbrance.
Hence this declaration provides a legislative mechanism to inform all current and future owners of the declaration and establishes penalties for non-compliance.
Why does there have to be a fine? Why not educate and then people will do the right thing?
Unfortunately not all people comply with legislation or 'do the right thing'. Education on the risks of using potentially contaminated groundwater has occurred for the past 20 years and will continue to occur to maintain community knowledge from generation to generation. The fine, however, may act as a deterrent to encourage people to comply with the legislation.
Why can't I have an agreement with the EPA to not use the groundwater?
Such an agreement would not be enforceable - there would be no penalty for non-compliance. In addition such an agreement would have no obligation to be transferred at the time of sale. The EPA would have no way of knowing that the next owner will be made aware of the groundwater prohibition. In such cases, new owners could then legally access contaminated groundwater.
I am in the buffer zone so why can't I be excluded from the prohibition area?
The buffer zone is an important part of the prohibition area. It is designed to prevent the contamination plume from expanding due to groundwater extraction.
Why hasn't any groundwater monitoring occurred for the past 2 years?
The EPA has not required off-site monitoring as it is unclear who has liability for the offsite contamination. Statutory liability for historic contamination is complex and EPA is continuing to investigate this. Whether groundwater monitoring has or has not occurred, does not alter the necessity for a water prohibition area. The groundwater moves at a very slow rate and, as such, the current area is considered accurate.
Will the EPA collect data now to see if the plume size has changed?
The EPA is not planning any assessment at this time. The groundwater contaminant plume has been shown to be approaching a stable extent and further sampling is not justified.
Why does this have to be recorded on my Certificate of Title?
It is important that all current and future owners are made aware of the prohibition. The EPA cannot notate on the Certificate of Title the existence of the water prohibition area. Notice can only be given to potential purchasers of the land on the Form 1 via Section 7 of the Land and Business (Sales and Conveyancying) Act, 1994. The groundwater contaminant plume is unlikely to shrink before 2050, so the transfer of information from owner to owner must survive many decades and be very robust. For further information please read the Section 7 information sheet.
How will this information be made available to people interested in my land or potential purchasers of the land?
The EPA will flag its interest in the certificates of title within the WPA with the Land Titles Office. Notice will then be given to any interested parties on the Form 1 statement (which forms part of the contract of sale) via Section 7 of the Land and Business (Sale and Conveyancing) Act 1994 where it is shown as a prescribed encumbrance. For further information please read the Section 7 information sheet.
Will the EPA fine people if they use the water in the prohibition area?
The EPA will initially issue a warning letter for non-compliance. Should the person disregard the warning letter then the maximum penalty is $8,000.
How will tenants find out about the prohibition?
Land owners are responsible for informing their tenants of the prohibition. A person, whether a tenant or an owner, is subject to the same penalty for non-compliance with a groundwater prohibition notice.
Should testing of the groundwater of Nazareth College should be undertaken as a precautionary measure?
This area is currently not subject to the water prohibition. Properties south of Holbrooks Road and Beatty Street are not down stream of the groundwater flow direction. As such they are unlikely to be impacted by the contaminated groundwater plume arising from the former clay pit, Moorfield Tce, Allenby Gardens.
The Nazareth Catholic College has a deep Tertiary well that is also not likely to be affected by contamination arising from the Moorfield Tce site.
The EPA and Department for Health and Ageing recommend that all groundwater wells (where use is permitted) are tested prior to use and is shown to be safe for its intended use.
Can off-site testing to be undertaken as a matter of urgency to confirm the current concentrations of contamination and the confirmation of the location of the contaminated plume?
The contaminant plume is well understood. The EPA is not planning any further assessment at this time. The plume has been shown to be approaching a stable extent and further sampling is not justified.
Once available, can the results to be provided to the community, along with a comparison to previous results?
Historic and future information in relation to this matter is, where relevant, placed on the EPA Public Register.
Can the Minister for Sustainability, Environment and Conservation direct the relevant agency to remove/cap all bores in the area (as allowed for in the Natural Resources Management Act) to adequately protect the public health of residents and prevent the spread of the contamination?
The Department of Environment, Water and Natural Resources has advised in reference to s145(2)(iii) of the Natural Management Resource Act 2004 states that if the power is utilised to direct a well to be plugged, backfilled or sealed, a notice would be served on the landowner or occupier of the land to undertake the works delineated in the notice at the owner/occupiers cost.
The measures provided by the Environment Protection Act 1993 are considered sufficient to provide long term protection of public health and prevent the spread of the contamination that may result from the use of the aquifer.
Can the 'original polluters' of the groundwater be determined and appropriate action be taken for the ongoing monitoring, management and remediation of the contamination to the extent necessary based on current knowledge?
It is currently unclear who has liability for the off-site contamination. Statutory liability for historic contamination is complex. The EPA is continuing to investigate this aspect of the off-site contamination. If the person is able to be identified as responsible for off-site contamination, it will not impact the need to establish a prohibition area or its size.
Can the Ministers for Health and Environment undertake a review of the processes carried out by their respective agencies to determine why it has taken so long to inform residents of the outcomes of the site audit report and the delay in taking measures to adequately protect the public health of residents as well as the environment?
In November 2004, the then Department of Health advised the owners and occupiers in the vicinity of the source site at Allenby Gardens of groundwater contamination, the impacts of potential groundwater movement away from the source site and the potential risk to human health. In October of 2006, Channel 7 current affairs show, Today Tonight, featured a media segment on contaminated groundwater in Allenby Gardens.
On 1 July 2009 the EPA gained a range of powers to assist in the assessment and remediation of contaminated groundwater. Among these was the ability for the EPA to establish water prohibition areas. The EPA is now able to direct its resources towards establishing water prohibition areas in Adelaide. The information available to the EPA for this plume is robust and thorough. The plume is from a single source and well understood. This is a key reason why this plume was selected as the first to form part of a groundwater prohibition area.
Can the EPA review the area of the proposed prohibition area with a view to only include properties that are necessary for the adequate protection of health? In particular, the current boundary to simply extend the area to the end of a street or street junction needs to be reviewed particularly with respect to the southern boundary (given the contamination is known to be travelling in a northwesterly direction). If required, the boundary should be defined by a particular allotment as opposed to extending the area simply for administrative ease.
The boundaries have been determined using scientific data and hydrogeological modelling. A buffer zone is included as an important part of the prohibition area. The buffer zone is designed to prevent the contamination plume from expanding due to groundwater extraction. The buffer zone extends to the nearest street as the prohibition must apply to a whole property, not part of a property.
The EPA is confident that the boundary is such that it includes only those properties that need to be excluded from taking or accessing contaminated groundwater, or those whose access may draw contaminated groundwater toward other properties.
Have residents asked for annual monitoring to take place closer to Flinders Park Primary school to ensure the safety of children?
In October 2009, a groundwater monitoring bore was installed at the Flinders Park Primary School as part of a soil and groundwater investigation and site contamination audit. This was associated with the removal of a school building (former Building 12).
Subsequent groundwater testing of the groundwater monitoring bore in November 2009 identified minor concentrations of the chlorinated hydrocarbon, TCE. The concentrations were well below World Health Organisation criteria for drinking water. The site contamination auditor concluded that the TCE was likely to have arisen from the former clay pit, Moorfield Tce, Allenby Gardens.
The groundwater in this area moves at a very slow rate and, as such, conditions change very slowly over time. At this time the boundary has been validated. It may, however, be altered in the future with further monitoring. No changes would be expected for at least ten years and no further monitoring is currently planned.
The chlorinated hydrocarbons within the whole plume are not expected to be completely below drinking water guidelines until around 2050.
The EPA understands that the primary school did have a bore that accessed the first tertiary (T1) aquifer (approximate depth 140 metres below ground level) and this was potentially used by the school to water the school grounds.
The two aquifers known to be affected by the groundwater contamination are the top two shallow aquifers known as the Q1 and Q2 quaternary aquifers. It is unknown if the tertiary aquifer is affected by contamination. Given its depth, however, and the significant clay layer protecting it, this is very unlikely.
The groundwater prohibition will prevent access to the shallow aquifer (which has not been used in the past by the school). As such, the contaminated groundwater beneath the school is not expected to present a risk to the students of staff.
How is the ongoing management of groundwater contamination including ongoing monitoring to be addressed concurrently with the proposed groundwater and feel the community concerns need to be taken into account prior to this being agreed?
The EPA has listened very carefully to the community. This has taken place through 3 open-house sessions, meetings with individuals, meetings with groups and various forms of written and verbal conversations. The EPA has not identified any reasons for not prohibiting the taking of contaminated groundwater in the proposed area in Allenby Gardens and Flinders Park.
How did the EPA become aware of the contamination?
In September 2004 the EPA was provided a notification of contamination in shallow groundwater (borewater) under residential properties adjacent to a former local landfill site at Allenby Gardens. The information identified contamination of groundwater which was likely to affect domestic bore water users in the vicinity.
At that time, the Department of Health advised local residents to not use groundwater.
Site contamination is typically identified at a source site and investigated in stages until the nature and the extent of the contamination is fully understood. Site contamination was initially identified as a result of redevelopment for residential housing in Moorfield Terrace, Allenby Gardens. This development was being undertaken over a former waste filled clay excavation (pug hole). It became known as a site contamination source site, as it was a source of groundwater contamination.
An independent environmental auditor was engaged in 2006 to facilitate the soil clean-up (remediation) at the source site. The soil source site remediation and audit report was completed in June 2009.
Elevated concentrations of chlorinated hydrocarbons including by PCE (perchloroethene), TCE (trichloroethene), DCE (dichloroethene) and VC (vinyl chloride) are still present in the groundwater beneath the source site and in groundwater adjacent to the site.
What are PCE, TCE, DCE and VC?
PCE (perchloroethene) and TCE (trichloroethene) are common industrial solvents and were used widely as degreasers and metal cleaners. DCE (dichloroethene) and VC (vinyl chloride) are generally present as the result of the degradation and breakdown of TCE.
For more information on the chemicals of concern, please refer to the fact sheet, Chlorinated solvents in groundwater, from SA Health.
How long has the contamination been present?
The source site was historically excavated of clay material for brick making purposes, leaving a large hole at the conclusion of mining (pug hole). The pug hole was subsequently filled with commercial and industrial wastes, including oils and solvents, from the mid 1960s until 1990.
The contamination is historical in nature and arose from practices that were considered acceptable at the time. It is likely that the contamination was caused progressively from leaching of chemicals buried on site. These practices have been phased out over time with the improvement of environmental processes and standards.
Has the community been told about groundwater contamination at Allenby Gardens in the past?
On 26 November 2004, the Department of Health advised (through a letter to local residents and a broader media alert) of groundwater contamination at a site in Allenby Gardens. The Department advised that owners of groundwater bores in Allenby Gardens should not use groundwater for any purpose unless it is tested and deemed safe for intended use.
In October of 2006, Channel 7 current affairs show, Today Tonight, featured a media segment on contaminated groundwater in Allenby Gardens.
What is a water prohibition area?
A water prohibition area is established under section 103S of the Environment Protection Act 1993 (the Act). This section of the Act allows the EPA to prohibit or restrict the taking and using of groundwater if it is contaminated (ie if site contamination exists). This action is needed because the groundwater, if used domestically, may be harmful to human health or safety.
The community then has the responsibility not to use the groundwater for their own health and safety.
Why is this happening now?
On 1 July 2009 the government amended the Environmental Protection Act 1993 to include measures to deal with site contamination. Among these measures was the ability for the EPA to establish water prohibition areas. Until now the EPA’s site contamination resources have been directed towards high priority work – of which some has been reported in the media. The EPA is working through the areas of historic groundwater contamination and where there is sufficient information, and where it is appropriate, is establishing water prohibition areas.
The EPA is continuing to monitor the offsite migration of chemical substances through periodic groundwater assessments.
Can I use the bore water for any use?
The bore water within the water prohibition area cannot be used for any purpose.
If your property is outside the water prohibition area, you should still have your bore water tested.
Chlorinated and petroleum hydrocarbons are a widespread contaminant of groundwater around the world. SA Health consistently advises all South Australians not to use bore water unless they have had the water adequately and frequently tested and it is shown to be safe for its intended use.
Even if these bores are not affected by industrial pollutants, bore water can be contaminated by other sources such as historical agricultural and horticultural activities, and fuel storage. It is also possible for bore water to be unsuitable for use because of the presence of naturally occurring chemicals.
How can contact with these chemical substances occur if they are in groundwater (bore water)?
Exposure to contaminated groundwater can occur through using the groundwater for drinking, cooking, toilet water (vapour), showers, swimming pools and irrigating gardens. Exposure can occur via ingestion, inhalation or through the skin. Exposure will not occur if you do not use the groundwater.
Where can I get my bore water tested?
If your property is outside the water prohibition area, there are several testing organisations that can undertake bore water testing. The only commercial facility in Adelaide is the Australian Water Quality Centre. There are many interstate analytical laboratories that can do this testing. Please ensure the facility you choose has NATA accreditation. The cost of water sampling does vary however; it starts from approximately $250 (including GST) per sample bottle.
How many bores are present in the water prohibition area?
There are 31 registered bores present in the water prohibition area. As the requirement for registration was only introduced in 1990, and given the high groundwater quality and shallow depth in the area, it is likely that a number of unregistered bores are also present.
Is the council and primary school bore water safe to use?
The contamination had been found in relatively shallow groundwater within the Allenby Gardens/Flinders Park area. The bore water available for the council and the Flinders Park Primary School is sourced from a much deeper aquifer.
How did these chemical substances get into the air, soil and groundwater in the residential area?
PCE, TCE and its breakdown products (DCE and VC) are liquid chlorinated hydrocarbon chemicals that readily flow and evaporate when released to the environment. When the waste containing these chemicals were added to the soil, and the geology of the underlying sediments (soil and rock), it is likely that they migrated down through the pores in the soil and dissolved in the groundwater. They then started flowing with the groundwater, down gradient, or in the case of Allenby Gardens and Flinders Park, towards the ocean.
Liquid chlorinated hydrocarbons like TCE and PCE are heavier than water, and they will sink down through water until they reach an impermeable barrier. The chlorinated hydrocarbons will then flow along preferential pathways via gravity or pool in confined areas. The chlorinated hydrocarbon that is dissolved in water will migrate with the groundwater in the general direction of groundwater flow.
What happens when TCE enters the human body or the environment?
For information regarding the TCE or chlorinated hydrocarbons entering the human body, please refer to the Department of Health and Aging fact sheets.
In the environment, TCE breaks down rapidly in air and surface water but much slower in soil and groundwater. TCE breaks down into dichloroethene (DCE) and then vinyl chloride (VC) which can then degrade to other products.
How can TCE and its breakdown products affect human health?
For information regarding the chlorinated hydrocarbons entering the human body, please refer to the Department of Health and Aging fact sheets.
Are we exposed to TCE, PCE and the other related chemicals in the community?
Exposures to these chemicals may occur in the general community, for example, vinyl chloride (VC) is found in tobacco smoke while TCE can be found in some household products such as typewriter correction fluid and paint or spot removers.
DCE exposure can result from use of perfumes, lacquers and some plastics (eg thermoplastics). These types of exposures are referred to as ‘background exposures’. As exposures to chemicals occur from many sources in our everyday life, it is important that when there is a chance of exposure occurring that can be reduced or eliminated, action is taken.
It needs to be recognised that exposure to any one chemical often occurs from many sources to varying degrees and it is important to reduce total exposures to the lowest amount possible. This is to ensure total exposure levels are below those that may produce effects on health.
Can I eat my fruit and vegetables if I am currently watering with bore water?
If you have been watering your fruit and vegetables with bore water, the health advice is that you should not eat them.
If you are not within the Allenby Gardens/Flinders Park water prohibition area, SA Health still advises that bore water should never be used for drinking, cooking, watering edible plants or filling up swimming pools, unless it has been tested by a specialist laboratory. Specific advice is available from the Using bore water safely factsheet.
Will the prohibition affect my property value?
The presence of a water prohibition area will mean that bore water will not be able to be used from shallow aquifers at properties in the designated area. The EPA’s experience in managing other similar incidents of contamination is that property values were not affected.
The particulars of a water prohibition area will be recorded against the Certificate of Titles of the properties in the Allenby Gardens/Flinders Park water prohibition area, to ensure that future purchasers of the property are aware of the prohibition on using the ground water.