Ad iAdrian WbbW ebber Site Contamination Auditoraclca.org.au/docs/aclca-presentation-background-240811.pdf · making determinations or assessments in relation to site contamination

Background Concentrations ‐ Natural vs. Ambient

Towards developing a collective knowledge of Background Concentrations in South Australiag

Ad i W bbAdrian Webber

Site Contamination Auditor

ACLCA (SA)24 August 201124 August 2011

ACLCA (SA) presentation24 August 2011

OverviewOverview

1. Regulatory Framework & Definitions (20 mins)

2. Competition – win a prize! (20 mins)

3. Concept and Forum (20 mins)


Part 1 ‐ Regulatory Framework & Definitions

Under the Environment Protection Act, 1993:Under the Environment Protection Act, 1993:

5B—Site contamination

(1) For the purposes of this Act, site contamination exists at a site if—

a) chemical substances are present on or below the surface of the site in concentrations above the background concentrations (if any); and

b) the chemical substances have, at least in part, come to be present there as a result of an activity at the site or elsewhere; and

c) the presence of the chemical substances in those concentrations has resulted in—

i. actual or potential harm to the health or safety of human beings that is not trivial, taking into account current or proposed land uses; or

ii. actual or potential harm to water that is not trivial; orii. actual or potential harm to water that is not trivial; or

iii. other actual or potential environmental harm that is not trivial, taking into account current or proposed land uses.


R l t F k & D fi itiRegulatory Framework & DefinitionsUnder the Environment Protection Act, 1993:Under the Environment Protection Act, 1993:

Background concentrations, in relation to chemical substances on a site or below its surface, means results obtained from carrying out assessments of the presence of the substances in the vicinity of the site in accordance with guidelines from time to time issued by the Authority;

83A—Notification of site contamination of underground water

This section applies to—

(a) an owner or occupier of a site; or

(b) a site contamination auditor or a site contamination consultant engaged for the purposes of making determinations or assessments in relation to site contamination on or below the surface of a site.

(2) A person to whom this section applies must notify the Authority in writing as soon as reasonably practicable after becoming aware of the existence of site contamination at thereasonably practicable after becoming aware of the existence of site contamination at the site or in the vicinity of the site (whether arising before or after the commencement of this section) that affects or threatens water occurring naturally under the ground or introduced to an aquifer or other area under the ground.


EPA GuidelinesEPA Guidelines

1. Site contamination —Determination of background concentrations (“Background guideline”)

2 Site contamination Notification of site contamination that affects or2. Site contamination— Notification of site contamination that affects or threatens underground water pursuant to section 83A of the Environment Protection Act 1993 (“Notification guideline”)

3. Site contamination —How to determine actual or potential harm to water that is not trivial resulting from site contamination (“Harm guideline”)

All issued in December 2008 and to be revised – pending EPA internal review


EPA Definitions

d f f k d d lEPA definition from Background guideline:

• Natural: this is the amount of naturally occurring chemical substances derived/originating from natural processes in the environment as close as / g g ppossible to natural conditions, exclusive of specific anthropogenic activities or sources:

erosion and dissolution of mineral deposits– erosion and dissolution of mineral deposits.

– influenced by topography, geology, geography and the physical, biological and chemical properties of the soil and groundwater.

• Ambient: the concentration of chemical substances in the environment that are representative of the area surrounding the site not attributable to a single identifiable source These are typically from historic activitiesto a single identifiable source. These are typically from historic activities, widespread diffuse impacts:

– e.g. fallout from motor vehicles.


From Background guideline:From Background guideline:


Often overlooked points:Often overlooked points:

• The EPA considers that the background concentration of chemical substances that do not occur naturally in the environment (e g TCE dioxin) is the laboratory limit ofenvironment (e.g. TCE, dioxin) is the laboratory limit of reporting, using a laboratory analytical method approved by the EPA.

• If an assessor does not establish the background concentration and consider that the background concentration for the chemical substance is zero, this is acceptable to the EPA – important as provides incentive to

tif b k d t tiquantify background concentrations.


Current reporting systemCurrent reporting system

EPA P bli R i t t i i f ti f• EPA Public Register, contains information from:

– Section 83, 83A and 109 notifications

– SCARSCAR

– SCAO, SCRO

– EPO, Clean up orders, licences etc

• Website – 83A database:

h bl b b b– searchable by suburb

– more info from public register, including above sources of information to be included in the future

– may include ability to search by chemical substances


Part 2Competition win a prize!Competition – win a prize!


#1#1

• What piece of legislation defines background concentrations?


#2#2

• Name the two types of background concentrations as defined by EPAy


#3#3

• Case study #1:– TCE in western suburbs of Adelaide (Beverley, ( y,Woodville etc) – multiple point sources, pugholes, dry cleaners etc.y

– Are these background concentrations as defined by EPA?by EPA?

– Ambient or natural?

A bi ff i i i f– Ambient or off‐site contamination from an unknown source?


#4#4

• Case study #2:– Nitrate – Adelaide Plains (Virginia ‐ glasshouses)( g g )

– Are these background concentrations as defined by EPA?by EPA?

– Ambient or natural?

bi ff i i i f– Ambient or off‐site contamination from an unknown source?


#5#5

• Case study #3:– Nitrate – Adelaide Plains (Virginia ‐ broad acre ( gagricultural application of fertilizers)

– Are these background concentrations as definedAre these background concentrations as defined by EPA?

Ambient or natural?– Ambient or natural?

– Ambient or off‐site contamination from an k ?unknown source?


#6 – Bonus Round#6 – Bonus Round

• How do you tell the difference?


Key message:Key message:

• There is a important difference between ambient• There is a important difference between ambient background concentrations and off‐site contamination from an unknown sourcecontamination from an unknown source

• The challenge for consultants is to design fassessment programs that will allow for a

determination to be made to better inform S83A fnotifications

• The challenge for regulators is to shape policy and guidance to encourage consultants and industry to adopt this as standard practice


#7#7


#8#8


#9#9


#10#10


#11#11


#12ACLCA (SA) presentation24 August 2011

#12

#13ACLCA (SA) presentation24 August 2011

#13

Part 3Concept and Forum

• ACLCA sponsored ‘dating service’ – introductions only

• Intellectual Property to be managed on a case by case basis p y g yby consultants

• Requires goodwill and buy in from consultants

• Only ACLCA members and those who have posted known background issues will be allowed to search database – user name and password system


DiscussDiscuss…

Chemical Substance Suburb Geological Unit / Aquifer Contact Name Contact Number Contact email

Nitrate Virginia Q1 Adrian Webber

Arsenic Mannum Mannum Formation Adrian Hall

Arsenic Murray Bridge Murray Group Limestone Andrew Howes

PASS Osborne St Kilda Formation Steve Kirsanovs

Boron Mile End Q1 Larissa Willoughby

Selenium Kensington Q1 Ruth Keogh


ReferencesReferences• EPA public register [email protected]

• EPA website www.epa.sa.gov.au/what_we_do/public_register_directory/site_contamination_groundwater_notifications_index

• SA Health e.g. basis for NEPM EILs (Interim Urban):– Trace Element Concentrations in Soils from Rural and Urban Areas of

Australia, Contaminated Sites Monograph Series No.4 1995 http://www.publications.health.sa.gov.au

• CSIRO 1946!‐2011 M.J. McLaughlin et al www.clw.csiro.au/publications

• Peers and colleagues

• ACLCA database?


Thankyou


Documents

Ad iAdrian WbbW ebber Site Contamination Auditoraclca.org.au/docs/aclca-presentation-background-240811.pdf · making determinations or assessments in relation to site contamination