Key points covered by NSW EPA at this meeting were:
- Kate Herring identified that there are proposed changes to the CLM Act and CLM Regulation to promote better consistency and provide process for tracking Management Plans.
- Anthea White provided an alert that Draft Auditor Guidelines released and identified notable proposed changes:
- Requirement for Auditor to Notify EPA immediately of suspected false and misleading information, inaccurate waste classification, waste that has been taken to a facility that cannot lawfully receive the waste
- Auditors are required to attach a Remediation Action Plan or Environmental Management Plan to the Site Audit Statement
- Auditor’s are able to collect verification samples
- Helen Prifti alerted all to new waste guidance for PFAS
- Andrew Hawkins confirmed that Chemical Control Orders are currently being reviewed. Patricia Fabiano foreshadowed some likely changes with respect to pesticides.
The EPA has issued an Addendum to the Waste Classification Guidelines (2014) – Part 1: classifying waste in response to the classification of per- and poly- fluoroalkyl substances (PFAS) as emerging contaminants. The addendum contains interim test values developed by the EPA for specific contaminant concentration (SCC) and leachable concentration using the toxicity characteristics leaching procedure (TCLP) for the most common PFAS compounds. The addendum is available on the EPA’s website at: http://www.epa.nsw.gov.au/wasteregulation/classify-waste.htm
The NSW EPA is implementing a state wide strategy to identify facilities in NSW where the past use of per- and poly-fluorinated alkyl substances (PFAS) may have resulted in site contamination.
This strategy includes an initial screening of sites, particularly focusing on whether the chemicals are present in soil or water. A decision tree has been developed to assist in the evaluation of the preliminary results for site prioritisation. This includes the use of trigger points to assist in the screening of data. Detailed investigations, if warranted, will be undertaken in accordance with appropriate contaminated land guidelines.
The decision tree will be reviewed following the release of national guidance on PFAS.
This document is now available on the EPA webpage and can be accessed here: http://www.epa.nsw.gov.au/clm/decision-tree-pfas-contamination.htm
The NSW EPA has just released The Contaminated Land Management – Draft guidelines for the NSW Site Auditor Scheme (3rd edition) (the draft guidelines) for public consultation.
A copy of the draft guidelines and information on how comments can be submitted can be found at http://www.epa.nsw.gov.au/clm/revision-of-guidelines-site-auditor-scheme.htm
Comments due 5pm 9 November 2016.
Rebeka Hall attended a recent ALGA presentation about emerging contaminants and reports that:
- It occurs in detergents, personal care products, stabilising agent for 111 TCA, Dioxane will always be present when TCA or DCE present.
- Highly soluble in water, does not readily bind to soils (v low sorption (Log kow)), and readily leaches to groundwater, low vapour pressure, Likely a carcinogenic
- Currently no standard in Australia, US EPA criteria for groundwater <1ug/L but there is an analytical challenge in getting down to that reporting limit. EPA method 8260 and 8270
- Treatment technologies exist for exsitu and insitu
- Conclusion – still emerging, need Aust regulators to act, need to adopt lower water quality standards, and advance lab methods.
Residues from former clandestine drug laboratories
- Residues are a result of illegal drugs using readily available chemicals by the reduction method cause public health concerns from exposure to toxic gases during ‘cooking’, as well as risk of explosions, fire, burns etc and dumping wastes – down drains or burn pits (in back yards)
- Real risk for unsuspecting public occupying a house (with former clan lab) with oily residues on walls, benches, floors, air conditioning units as this will cause asthma attacks and other respiratory issues and behavioural and sleep pattern issues.
- Australian Crime Commission (ACC 2011) has developed guidelines and criteria for surface area is 0.5ug/100cm2
- NSW health has developed a ‘Clan Lab bust guidelines’
- PFASs – man made chemical since the 1950s with key uses – Aqueous fire fighting foams (manufactured by 3M contains about 0.6% PFOS), stain resistant coatings, Teflon cookware, chrome plating
- It is stable, persistent, bio accumulative, acute toxicity there are THOUSANDS of these compounds, most common are PFOS, PFOA and PFHxS (hexan sulfonate)
- PFOS soluble, PFOA is even more soluble with a half life PFOS in water 41 yrs, PFOA in water 92 years
- Drinking water criteria: USEPA (19 May 2016) drinking water guidelines for PFOS and PFOA is 0.07ug/L where as Aust Enhealth guideline is 0.5ug/L for PFOS and 5ug/L for PFOA
- Soil criteria USEPA Region 4 PFOA 16mg/kg, PFOS 6mg/kg
- WA DER (Feb 2016) released an interim guideline on assessment and management of PFAS and in QLD DEHP (2016) has prepared a Policy doc for Environmental Management of Fire Fighting Foam