You are on page 1of 63

CONTAMINATED SITES

Gudelnes for the Assessment and Management of Groundwater Contamnaton

Lmtatons
These gudelnes should be used n conjuncton wth other relevant gudelnes made or approved by the Department of Envronment and Conservaton NSW under secton 105 of the Contaminated Land Management Act 1997 when assessng and managng groundwater contamnaton. The References secton lsts other relevant and useful documents. These gudelnes do not nclude occupatonal health and safety procedures. The NSW WorkCover Authorty should be consulted on these. Approprate acton must be taken to manage any potental hazard and adequately protect the health of any workers on, or occupers of, the ste.

Dsclamer
The Department of Envronment and Conservaton NSW has prepared ths document n good fath, exercsng all due care and attenton, but no representaton or warranty, express or mpled, s made as to the relevance, completeness or fitness of t for any other purpose n respect of a partcular users crcumstances. Users of ths document should satsfy themselves about ts applcaton to ther stuaton and, where necessary, seek expert advce. The Department of Envronment and Conservaton s pleased to allow ths materal to be reproduced n whole or n part, provded the meanng s unchanged and ts source, publsher and authorshp are acknowledged.

Publshed by: Department of Envronment and Conservaton NSW 5961 Goulburn Street PO Box A290 Sydney South 1232 Ph: (02) 9995 5000 (swtchboard) Ph: 131 555 (envronment nformaton and publcatons requests) Ph: 1300 361 967 (natonal parks nformaton and publcatons requests) Fax: (02) 9995 5999 TTY: (02) 9211 4723 Emal: nfo@envronment.nsw.gov.au Webste: www.envronment.nsw.gov.au DEC 2007/144 ISBN 978 1 74122 366 8 March 2007 Prnted on recycled paper

Preface
Background
Groundwater contamnaton can arse from ether pont sources or dffuse sources. Common examples of pont sources that could contamnate groundwater are leakng underground storage tanks, nadequately-managed waste dsposal stes and accdental chemcal splls. An example of a dffuse source s pestcdes and nutrents appled to broad-acre agrcultural land that nfiltrate through sols to groundwater. These gudelnes focus on groundwater polluton arsng from pont source contamnaton rather than on broad-scale groundwater ssues arsng from dffuse sources. Contamnated groundwater can be unsutable for use and may also adversely affect the qualty of surface water and sedments. It may then harm human and ecologcal health. Contamnated groundwater may also affect the types of land uses that may safely be carred out above a contamnant plume. The legacy of groundwater contamnaton can be a major burden on the communty because once groundwater s contamnated t s generally dfficult and costly to remedate. Therefore, preventng groundwater contamnaton s the most practcal way of protectng groundwater qualty. Where contamnaton of groundwater s dentfied, acute rsks, such as the possble accumulaton of explosve vapours n subsurface utltes, must be mmedately managed. The source of contamnaton must be removed to ensure the protecton of human health and the envronment. The followng actons should also be taken whenever practcable: the envronmental values of the groundwater must be restored groundwater qualty must be restored to ts natural background concentraton.

These Guidelines for the assessment and management of groundwater contamination (the gudelnes) outlne a best-practce framework for assessng and managng contamnated groundwater n NSW. The Department of Envronment and Conservaton NSW (DEC) must be notfied about certan groundwater contamnaton under the Contaminated Land Management Act 1997 and the Protection of the

Environment Operations Act 1997. Followng notficaton, DEC may decde that the contamnaton warrants regulatory nterventon. These gudelnes should help consultants and ndustry to devse groundwater assessment and management strateges that are consstent wth DECs expectatons. The gudelnes are not ntended to be a text book for groundwater contamnaton nor to provde detaled techncal advce on the assessment and management of contamnated groundwater. Informaton about groundwater fundamentals s presented n other publcatons, ncludng those presented under Suggested further readng on page 39. In all cases, groundwater contamnaton assessments and remedaton must be conducted by competent professonals who already have relevant qualficatons and experence. Where techncal gudance materal may be useful to readers, t s referred to n the relevant secton of the gudelnes or under References. Reference to these documents, however, does not mean DEC endorses them. Polcy documents endorsed by DEC are publshed every sx months under the Freedom of Informaton Act. Contact DECs Envronment Lne on 131 555 for further nformaton. Varous other gudelnes that may be updated from tme to tme are referred to throughout ths document. Where a referenced gudelne whch s endorsed by the NSW Government or DEC s updated, the relevant reference(s) n ths document should be read as f they were to the endorsed updated verson. For all other gudelnes, references should be read as f they were to the updated references as soon as updated versons have been released.

Table of contents
1 Introduction, 1 1.1 About the gudelnes, 1 1.2 Scope of the gudelnes, 1 1.3 Polcy, legslatve framework and exstng gudance, 2 1.3.1 Key polcy prncples from NSW groundwater polces, 2 1.3.2 Framework for groundwater management n NSW, 3 1.3.3 Exstng gudance on groundwater, 6 1.4 Importance of groundwater, 7 1.5 Definton of groundwater contamnaton, 7 2 Assessing groundwater contamination, 9 2.1 Introducton, 9 2.2 Prelmnary assessment, 10 2.2.1 Determnng natural background groundwater qualty, 12 2.2.2 Comparng contamnant concentratons aganst GILs, 12 2.3 Detaled assessment, 13 2.3.1 Protectng the groundwaters envronmental values, 14 2.3.2 Ste-specfic rsk assessment, 15 2.3.3 Contamnant fate and transport modellng, 16 2.3.4 Addtonal aspects to consder, 18 3 Managing groundwater contamination, 21 3.1 Introducton, 21 3.2 Management responses to contamnaton, 22 3.3 Controllng short-term threats, 22 3.4 Restrctng groundwater use, 23 3.5 Source control, 24 3.5.1 Non-aqueous phase lquds, 25 3.6 Plume contanment, 26 3.7 Clean-up of contamnated groundwater, 26 4 Cleaning up contaminated groundwater, 27 4.1 Clean up so natural background water qualty s restored, 27 4.1.1 Montored natural attenuaton, 27 4.2 Clean up to protect the relevant envronmental values of groundwater, and human and ecologcal health, 28

4.3 Clean up to the extent practcable, 29 4.3.1 Demonstratng restorng envronmental values s mpractcable, 29 4.4 Clean-up mpacts, 31 4.5 Clean-up tmeframe, 31 4.6 Degraded local groundwater qualty, 32 4.7 Envronmental montorng, 33 4.8 Groundwater management plans, 33 4.8.1 Regulatory controls for ongong management of groundwater contamnaton, 34 5 Regulation, 35 5.1 Regulaton under the CLM Act, 35 5.2 Regulaton under the POEO Act, 35 5.3 Requrements under SEPP 55, 36 6 References, 37 Relevant Acts of Parlament and polces, 39 Suggested further readng, 39 Appendices, 43 Appendx 1 Glossary, 43 Appendx 2 Identfyng envronmental values, 44 2.1 Major aqufers of drnkng water qualty, 50 Appendx 3 Montored natural attenuaton, 51 Appendx 4 Contactng NSW government departments for advce on groundwater contamnaton, 57

1 Introduction
1.1 About the guidelines
These Guidelines for the assessment and management of groundwater contamination (the gudelnes) outlne a best-practce framework for assessng and managng contamnated groundwater n NSW. Whle the gudelnes do not artculate legslatve requrements, they are made under secton 105 of the Contaminated Land Management Act 1997 (CLM Act), so the Department of Envronment and Conservaton (DEC) must take them nto account whenever they are relevant. DEC exercises certain statutory functions and powers (including those set out in the Protection of the Environment Operations Act 1997 (POEO Act) and CLM Act) in the name of the Environment Protection Authority. Ste audtors accredted under the CLM Act must also consder these gudelnes when finalsng ste audts. The gudelnes wll also be useful for envronmental consultants, local councls, ndustry organsatons, water regulators, water users and other members of the communty. These gudelnes should help consultants and ndustry to devse groundwater assessment and management strateges that are consstent wth DECs expectatons.

1.2

Scope of the guidelines


The gudelnes are set out as follows: Section 2 Assessng groundwater contamnaton outlnes ways of dentfyng whether groundwater s contamnated and descrbes how to conduct prelmnary and detaled assessments. Section 3 Managng groundwater contamnaton outlnes ways of controllng groundwater contamnaton and dentfyng what remedaton s needed to resolve t. Section 4 Cleanng up contamnated groundwater descrbes a clean-up herarchy ncludng when t s essental to clean up so natural background water qualty s restored and when clean-up to the extent practcable s acceptable. Section 5 Regulaton explans DECs regulatory nvolvement n managng groundwater contamnaton. Section 6 References contans references, relevant Acts and polces, and a suggested further readng lst.

Appendix 1 contans a glossary of terms used throughout these gudelnes. Appendix 2 contans nformaton about how to dentfy envronmental values, and a lst of major aqufers of drnkng water qualty dentfied by the NSW Department of Natural Resources (DNR). Appendix 3 contans more detaled nformaton about montored natural attenuaton. Appendix 4 contans contact detals for relevant NSW Government departments.

1.3 Policy, legislative framework and existing guidance


1.3.1 Key polcy prncples from NSW groundwater polces
Legslaton and publshed polces n NSW have artculated key prncples for assessng and managng groundwater contamnaton. These nclude the prncples of ecologcally sustanable development, whch requre the effectve ntegraton of economc, socal and envronmental consderatons n decson-makng. Ths can be acheved by mplementng: the precautonary prncple ntergeneratonal equty conservaton of bologcal dversty and ecologcal ntegrty mproved valuaton, prcng and ncentve mechansms for envronmental factors (ncludng the concept of polluter pays) see secton 10 of the CLM Act.

The groundwater polces set out n 1.3.3 encourage ecologcally sustanable development to: slow and halt, or reverse, any degradaton of groundwater resources ensure long-term sustanablty of the ecologcal support characterstcs of groundwater systems mantan the full range of benefical uses of these systems maxmse economc benefit to the regon, state and naton.

The polces set out basc prncples that should gude the management of groundwater n NSW. In relaton to groundwater contamnaton, these nclude:
2

preventng groundwater polluton so future remedaton s not requred managng all groundwater systems so ther most senstve dentfied benefical use (or envronmental value) s mantaned, recognsng the cumulatve mpacts of human actvtes on groundwater qualty replacng processes and practces that degrade groundwater systems, ether drectly or ndrectly, wth ecologcally sustanable alternatves requrng developments to mnmse adverse mpacts on the envronment by preventng polluton of, or changes n, groundwater qualty applyng the precautonary prncple to protect groundwaterdependent ecosystems where scentfic knowledge s lackng affordng town water supples specal protecton aganst contamnaton rehabltatng degraded groundwater systems, where practcal, to mnmse the mpacts of contamnaton on groundwaterdependent ecosystems, and to restore the ecosystem support characterstcs of groundwater systems.

DEC wll consder the above prncples of ecologcally sustanable development when exercsng functons under the CLM Act, and others managng contamnated groundwater must also mplement these prncples. These gudelnes establsh a decson-makng framework for addressng groundwater contamnaton that s consstent wth these prncples.

1.3.2 Framework for groundwater management n NSW


Varous government departments n NSW, ncludng the Department of Natural Resources (DNR), Department of Envronment and Conservaton NSW (DEC), and the Department of Plannng, along wth local councls, share groundwater management responsbltes. Department of Natural Resources The Mnster for Natural Resources and DNR regulate the use of groundwater through a lcensng framework under the Water Management Act 2000 (WM Act). The WM Act recognses that landholders overlyng an aqufer can access groundwater for
3

domestc consumpton and stock waterng purposes wthout requrng an access lcence or water use approval. However, landholders exercsng ths basc rght requre approval to construct a water bore, and the nstallaton of any groundwater bore n NSW requres a lcence from DNR. Under the WM Act, envronmental water rules for all planned envronmental water sources n NSW (ncludng groundwater) must be mplemented as soon as possble. Envronmental water rules are provsons for dentfyng, establshng and mantanng planned envronmental water, whch s water reserved through management plans for fundamental ecosystem health or other specfied envronmental purposes. The WM Act also requres all water sources, ncludng groundwater, to be protected and restored, and ther water qualty to be protected, and wherever possble, enhanced. At the tme of wrtng, not all the provsons of the WM Act have commenced. Macro water sharng plans are beng prepared for water sources, ncludng groundwater sources, that have not been ncluded n any water sharng plans n force under the WM Act. The macro plans wll provde generc water sharng rules for four dstnct aqufer types: coastal sands, unconsoldated sedments, porous rocks, and fractured rocks. In the context of groundwater resource management, DNR s also the key agency for desgnatng approprate uses of groundwater n NSW, ncludng potental uses. DNR helps make decsons about what rsks may be present as a result of groundwater contamnaton and what degree of clean-up s requred. Department of Environment and Conservation The key peces of legslaton for preventng and regulatng groundwater contamnaton n NSW are the Protection of the Environment Operations Act 1997 (POEO Act) and the Contaminated Land Management Act 1997 (CLM Act), whch are both admnstered by DEC. The POEO Act governs the protecton of the envronment from polluton. Under ths Act t s an offence to pollute waters, ncludng groundwater. The Act also gves powers to the approprate regulatory authorty, generally DEC or local councls, to ssue cleanup notces, whch are one way of regulatng the clean-up and ongong management of groundwater contamnaton. The POEO Act also establshes a duty to notfy the approprate regulatory authorty of polluton ncdents that are causng or threatenng materal harm to the envronment.
4

The CLM Act sets out a framework for assessng and managng contamnated land, whch ncludes groundwater. It also places a duty on polluters and landowners to notfy DEC of certan types of contamnaton. Minister for Planning/Department of Planning/local councils The Department of Plannng and local councls have several responsbltes for groundwater and groundwater contamnaton. Under Parts 4 and 5 of the Environmental Planning and Assessment Act 1979 (EP&A Act), consent authortes and determnng authortes must consder the lkely mpacts of proposed development and other actvtes on the envronment, ncludng groundwater. Under Part 3A of the EP&A Act (whch apples to certan major nfrastructure and other projects), the Mnster for Plannng, when decdng whether to approve a project, s requred to consder the report by the Drector General of the Department of Plannng. The Drector Generals report s requred to nclude, among other thngs, a copy of the proponents envronmental assessment report and any envronmental assessment undertaken by the Drector General. Under State environmental planning policy no. 55 Remediation of land (SEPP 55) (NSW DUAP and NSW EPA 1998), plannng authortes must consder land contamnaton ssues when assessng certan rezonng applcatons. Consent authortes must also consder whether the land s contamnated when assessng development applcatons. If the land has been contamnated, the plannng or consent authorty must be satsfied that t s sutable n ts contamnated state, or wll be sutable after remedaton, for the purposes for whch the land s to be rezoned or for whch the development s proposed to be carred out. In some nstances groundwater contamnaton can make the land unsutable for a partcular use and, therefore, management of the contamnaton may be necessary before the development or rezonng applcaton s approved. Local councls also have powers under the POEO Act to ssue cleanup notces to deal wth polluton at stes for whch they are the approprate regulatory authorty. In addton, the Local Government Act 1993 specfies that a charter of councls n NSW s to: properly manage, develop, protect, restore, enhance and conserve the envronment of the area for whch t s responsble n a manner that s consstent wth, and promotes, the prncples of ecologcally sustanable development.
5

NSW Health Under the Public Health Act 1991, NSW Health has powers to close any water supply, ncludng a groundwater source, f a drnkng water source becomes unfit for human consumpton or f the water consttutes, or s lkely to consttute, a rsk to publc health.

1.3.3 Exstng gudance on groundwater


There are several gudelnes that relate to groundwater protecton and assessment n NSW. The key overarchng polcy, The NSW state groundwater policy framework document (NSW Government 1997), outlnes the roles of the key NSW authortes n relaton to groundwater, whch are summarsed n 1.3.2. The frameworks subordnate polcy documents, ncludng The NSW state groundwater dependent ecosystems policy (NSW Government 2002) and The NSW groundwater quality protection policy (NSW Government 1998) are also relevant. The National environment protection (assessment of site contamination) measure (NEPC1999) (the ste contamnaton measure) s a broad framework-settng statutory nstrument that reflects agreed natonal objectves and contans gudelnes for assessng groundwater contamnaton. The ste contamnaton measure s mplemented n NSW n the form of gudelnes approved under the CLM Act. Schedule B(6) of the ste contamnaton measure provdes a framework for a rsk-based assessment of groundwater contamnaton, ncludng gudance on applyng the Natonal Water Qualty Management Strategy (NWQMS) crtera to groundwater. Other documents belongng to the NWQMS are: the National water quality management strategy implementation guidelines (ARMCANZ & ANZECC 1998), whch nclude prncples outlnng the need to develop a strong, growng and dverse economy, that can enhance the capacty for envronment protecton the Australian and New Zealand guidelines for fresh and marine water quality (ANZECC & ARMCANZ 2000a), whch dentfy generc water qualty crtera that protect envronmental values from a wde range of potental contamnants, as well as artculatng a process for undertakng ste-specfic assessments of water qualty to determne whether the water can sustan aquatc ecosystems.

The ANZECC & ARMCANZ (2000a) gudelnes also nclude a chapter on drnkng water, whch refers to the Australian drinking water guidelines (NHMRC & NRMMC 2004) for relevant gudelne values. The Guidelines for groundwater protection in Australia (ANZECC & ARMCANZ 1995) provde a framework for protectng groundwater from contamnaton. The document also defines benefical uses of, and values for, groundwater.

1.4 Importance of groundwater


Groundwater s mportant for the health, and n some areas the economc wellbeng, of NSWs communty. It s used: as a source of domestc, recreatonal, rural and ndustral water, and, n some parts of NSW, as drnkng water to rrgate gardens, parks, and playng fields n urban envronments, especally n recent tmes by the agrcultural and ndustral sectors to support food producton and other actvtes to help sustan lfe n streams and rvers to support fragle ecosystems such as wetlands n dry perods (note that groundwater tself can be a valuable ecosystem).

Groundwater s also mportant because humans can be ndrectly exposed to groundwater contamnants. For example, the consumpton of vegetable crops rrgated wth contamnated groundwater or products from anmals whch drank contamnated groundwater can consttute a human health rsk. Also, volatle contamnants n groundwater may accumulate n enclosed spaces above a contamnant plume and then pose rsks from nhalaton or exploson dependng, for nstance, on the type of the contamnants and the severty of the contamnaton.

1.5 Definition of groundwater contamination


Contamnaton of land, whch ncludes groundwater, s defined n the CLM Act and the EP&A Act as: the presence n, on or under the land of a substance at a concentraton above the concentraton at whch the substance s normally present n, on or under (respectvely) land n the same localty, beng a presence that presents rsk of harm to human health or any other aspect of the envronment.
7

In practce, however, groundwater s consdered to be contamnated where any substance or waste has been added at above natural background concentraton, and represents, or potentally represents, an adverse health or envronmental mpact. For the purpose of these gudelnes, any undesrable change n groundwater qualty consttutes an adverse envronmental mpact. In relaton to the POEO Act, these gudelnes also refer to the term polluton. The dctonary of the POEO Act defines polluton of waters to nclude: placng n or on, or otherwse ntroducng nto or onto waters (whether through an act or omsson) any matter whether sold, lqud or gaseous, so that the physcal, chemcal or bologcal condton of the waters s changed.

2 Assessing groundwater contamination


2.1 Introduction
Assessng groundwater contamnaton nvolves dentfyng rsks to human and ecologcal health, and provdng the necessary nformaton to manage these rsks. Generally, the rsks are unacceptable f groundwater qualty has deterorated to the extent that t can no longer support relevant envronmental values ncludng current and realstc future use and non-use values. Whle the rsk from groundwater contamnaton may be unacceptable due to adverse effects of the contamnaton on the groundwaters envronmental values, the level of rsk to human and ecologcal health wll vary dependng on ste-specfic condtons. More detaled assessments of the rsks posed by the groundwater contamnaton may then be requred to dentfy an approprate management response and evaluate the urgency of that response. Such a response may requre addtonal groundwater nvestgatons amed at evaluatng and selectng remedal technologes. Such nvestgatons are not covered by these gudelnes, and relevant gudance should be obtaned from documents dealng wth remedal technologes. The followng presents a framework for assessng rsks from groundwater contamnaton, takng nto account the envronmental values of the groundwater. It recognses exstng, natonally developed approaches, polces and water qualty crtera developed to protect water under the Natonal Water Qualty Management Strategy (NWQMS) and the numercal gudelne crtera for the protecton of envronmental values that have been presented n NWQMS documents. For the purpose of these gudelnes, the NWQMS crtera are hereafter referred to as exstng generc groundwater nvestgaton levels (GILs). Note, however, that n addton to the exstng generc crtera, GILs may also be derved on a ste-specfic bass. These gudelnes adopt a tered approach for the assessment of groundwater contamnaton. They advse conductng both a prelmnary assessment (see 2.2) and a detaled assessment (see 2.3). DEC may consder nformaton obtaned from these groundwater assessments n decdng whether to regulate the management of the contamnaton. Detals about DEC regulaton are presented n Secton 5.
9

Assessments of groundwater contamnaton requre: careful plannng a detaled samplng and analyss plan the establshment of data qualty objectves approprate data qualty assurance and qualty control procedures.

The data should be collected only by approprately-traned personnel and nterpreted by competent professonals wth qualficatons and experence relevant to assessng the presence, extent and behavour of contamnants n groundwater. A good understandng of data uncertanty and temporal and spatal data varablty s mportant as may be knowledge about remedal technologes. For detaled quanttatve assessments, assessors should have tranng n the rsk-based assessment of groundwater contamnaton and n modellng the transport of contamnants n groundwater. Whle relevant sources of toxcty data are lsted n the ste contamnaton measure and ecotoxcologcal nformaton s provded n ANZECC & ARMCANZ 2000a, specalsed toxcologcal advce may also be requred. These gudelnes do not provde detaled techncal advce on assessng groundwater contamnaton. Such gudance s avalable from other sources ncludng gudelnes n the References secton.

2.2

Preliminary assessment
The potental for groundwater contamnaton due to, for nstance, current or prevous actvtes at a ste, or the confirmed presence of contamnants n sol, should prompt a prelmnary assessment of groundwater contamnaton. The prelmnary assessment should am to dentfy groundwater contamnaton and evaluate whether t may pose a threat to human and ecologcal health. If a potental threat s dentfied, the results of the prelmnary assessment should assst n plannng a more detaled groundwater contamnaton assessment (see 2.3) The prelmnary assessment of groundwater contamnaton begns wth nvestgatng readly avalable nformaton through a desktop study, ncludng: apprasng the ste hstory and dentfyng all past and present contamnatng actvtes and assocated potental contamnants

10

findng out avalable nformaton about the local and regonal geology and hydrogeology, ncludng dentfyng water-bearng zones whch may, for nstance, nclude perched groundwater near the surface, unconfined groundwater at shallow depth, and semconfined or confined groundwater at greater depth dentfyng aqufers and confinng layers, and at least conductng a basc assessment of expected hydraulc conductvtes and porostes nvestgatng the groundwater flow doman, ncludng the expected elevaton of the water table and any potentometrc surfaces, lateral and vertcal hydraulc gradents, lkely flow drecton and flow velocty, sources of recharge, possble dscharge ponts and other hydraulc boundares dentfyng potental receptors, ncludng current and realstc future water users, surface water bodes, groundwater-dependent ecosystems and groundwater ecosystems, and vapour flux receptors dentfyng the natural hydrogeochemstry of the groundwater system, such as pH, redox potental, total dssolved solds, and major anon and caton concentratons. relevant nformaton on DECs publc record of declaratons and orders under the CLM Act, and n the publc regster under the POEO Act, as well as nformaton from local councls and DNR (e.g. n relaton to known bore locatons and benefical uses) should be obtaned the NSW Natural Resource Atlas (vst www.nratlas.nsw.gov.au) should be consulted, whch ncludes relevant nformaton such as the locatons of regstered bores.

For the desktop study:

In addton to the desktop study, the prelmnary assessment ncludes ntrusve nvestgatons to dentfy the presence of contamnants and enable lkely maxmum contamnant concentratons n groundwater beneath a ste to be compared wth exstng generc GILs (see 2.2.2). Contamnaton s present f there s an undesrable change n the natural background qualty of the groundwater. Whle the prelmnary assessment may not reveal all the above nformaton, the nformaton obtaned must be sufficent to gan a prelmnary conceptual understandng of the hydrogeologcal
11

regme and the rsks assocated wth any potental contamnaton. The prelmnary assessment should also dentfy mportant data gaps.

2.2.1 Determnng natural background groundwater qualty


If potental ste contamnants, such as metal compounds and nonmetallc norgancs, are substances that mght occur naturally at the ste, an evaluaton of natural background groundwater qualty may be requred to dstngush naturally occurrng concentratons of substances from anthropogenc contamnaton. Where contamnaton has been dentfied, DNR should be nformed about all water qualty data obtaned durng the nvestgaton. Whle t s not essental to determne natural background concentratons, f the nvestgaton does not uncover nformaton about natural background concentratons, t must be assumed, for the purpose of the prelmnary assessment that the detected substances are not naturally occurrng and consttute contamnaton.

2.2.2 Comparng contamnant concentratons aganst GILs


Followng the dentficaton of contamnaton and lkely maxmum contamnant concentratons n groundwater at a ste, these concentratons must be compared aganst exstng generc GILs, f avalable, whch protect the followng envronmental values: drnkng water (see NHMRC & NRMMC 2004) aquatc ecosystems (see ANZECC & ARMCANZ 2000a).

For the protecton of aquatc ecosystems, the GIL for 95% protecton should be used. If the concentraton n groundwater exceeds a GIL for any contamnant and there could be current or future exposure to the contamnant (e.g. f the contamnaton may mgrate offste or there are on-ste potental human or ecologcal receptors for the contamnant), the contamnaton may pose a threat to human or ecologcal health and a more detaled assessment of the groundwater contamnaton, as outlned n 2.3, wll be requred. Because of the longevty of the contamnaton, a more detaled assessment s always requred f non-aqueous phase lquds such as fuel are present n or on groundwater. Regardng protecton of aquatc ecosystems: where the exstng generc GIL s below the naturally occurrng background concentraton of a partcular contamnant, the background concentraton becomes the default GIL

12

where the exstng generc GIL for a partcular contamnant s below the practcal lmt of reportng or below the detecton lmt, the quanttatve lmt of reportng or the detecton lmt should be used nstead of the exstng generc GIL.

Where a generc GIL does not exst for a partcular contamnant, DEC should be contacted for advce. DEC should also be contacted f the exstng generc GILs for drnkng water and aquatc ecosystem protecton are not consdered strngent enough to protect ecologcal and human health, gven the potental exposure routes (e.g. dermal contact n relaton to some contamnants).

2.3 Detailed assessment


Contamnaton that may pose a threat to ecologcal or human health requres more detaled assessment. The detaled assessment conssts of developng, and progressvely mprovng, a conceptual ste model on the bass of the relatonshp between: sources of the contamnaton and release mechansms the nature and extent of the contamnaton the domnant fate and transport characterstcs of contamnants, a detaled apprasal may mean usng analytcal or numercal solute fate and transport models see 2.3.3 potental receptors and exposure pathways.

In assessng potental receptors and exposure pathways, all relevant envronmental values, ncludng those assocated wth current and realstc future benefical uses of the groundwater, need to be accounted for (see 2.3.1). Informaton on developng conceptual ste models for contamnated stes can be found n Amercan Socety for Testng and Materals 2003. Durng the detaled assessment, uncertantes should be addressed va further nvestgatons. New findngs should then be used to valdate and mprove the conceptual ste model n relaton to, for nstance, an mproved understandng of the extent of the contamnaton, the fate of the contamnants, or the nature of the water bearng zones and any potental receptors. The assessment must provde enough nformaton about the nature and severty of the rsks assocated wth the contamnaton to develop meanngful conclusons about the need for, and the urgency
13

of, management responses. The findngs of the detaled assessment should assst n dentfyng a management response that, at a mnmum, ensures that groundwater qualty when groundwater comes to the surface from natural seepages or exstng or potental future bores does not compromse relevant envronmental values. An excepton to ths s the protecton of organsms n groundwater, f applcable. Further nformaton about the protecton of such organsms s ncluded n Appendx 2. Where the detaled assessment ncludes predctons of future contamnant concentratons and concludes that these wll not compromse envronmental values, approprate groundwater montorng needs to be mplemented to verfy the predcted concentratons. Also, contngency measures ncludng trggers for mplementng these measures should be developed as the groundwater montorng may show that the predcton s nvald.

2.3.1 Protectng the groundwaters envronmental values


Envronmental values are defined n ANZECC & ARMCANZ 2000a as: partcular values or uses of the envronment that are mportant for a healthy ecosystem or for publc benefit, welfare, safety or health whch requre protecton from the effects of polluton, waste dscharges and deposts. To protect the groundwaters envronmental values, the current and projected contamnant concentratons at the ponts of exstng and realstc future use may need to be estmated. If analytcal or numercal fate and transport models are used to estmate contamnant concentratons over tme at these ponts, the models must be based on a vald conceptual ste model. The current and projected contamnant concentratons should then be compared aganst GILs to determne f the relevant envronmental values may be adversely affected. The prncple for determnng the approprate GILs for the relevant envronmental values s artculated n The NSW groundwater quality protection policy (NSW Government 1998), whch states that: water qualty objectves should always protect the groundwater qualty to a level that meets the most senstve end users requrements. All relevant envronmental values should be consdered, ncludng current and potental uses of the groundwater and ecosystems.
14

The concept of envronmental values recognses that the nearest receptor of the groundwater may change as a result of development occurrng between the ste and the receptor, .e. there may be future uses for the groundwater. Schedule B(6) of the ste contamnaton measure (NEPC 1999) provdes a methodology for usng GILs to assess contamnated groundwater. The followng sx envronmental values are presented: aquatc ecosystems aquaculture and human consumers of food agrcultural water recreaton and aesthetcs drnkng water ndustral water.

Detals about how to dentfy envronmental values are provded n Appendx 2. For each envronmental value, a set of generc GILs s provded that defines acceptable water qualty at the pont of use. For some envronmental values, the exstng generc GILs are an adequate gude to the water qualty requred to protect envronmental values, such as drnkng water crtera at the pont where the groundwater s used for drnkng. For other envronmental values or for a pont of groundwater extracton where groundwater s not used, exceedng GILs may trgger further nvestgaton. As GILs protect relevant envronmental values, groundwater qualty that meets the GILs does not generally pose unacceptable rsks. If the groundwater qualty does not meet the relevant GILs, the groundwater may not be safe for the envronmental values and acton would have to be undertaken to more accurately determne whether the groundwater s safe or to resolve the problem.

2.3.2 Ste-specfic rsk assessment


Generc GILs do not exst for all contamnants or exposure scenaros (e.g. the protecton of human health from the nhalaton of volatle contamnants). If there s no generc GIL, relevant crtera from overseas or GILs developed from a ste-specfic rsk assessment may be used. Such GILs may also be used f contamnant concentratons exceed an exstng generc GIL at a pont where groundwater s not used and s not lkely to be used n the future.
15

Any detaled (e.g. quanttatve) assessment of rsks posed by groundwater contamnaton requres a thorough understandng of all relevant aspects. Of partcular mportance are aspects relatng to samplng methods, the fate and transport of contamnants n groundwater, spatal and temporal data varablty, and data uncertanty. Partcularly where groundwater contamnaton may already affect a receptor such as an aquatc ecosystem, other specalst advce, for nstance, ecotoxcologcal advce, may be needed. Any ste-specfic assessment of rsks must follow the rsk-assessment gudance n the ste contamnaton measure (NEPC 1999). In a stespecfic rsk-based assessment, the followng may also need to be consdered as they present addtonal nformaton: for assessng human health rsks, Department of Health and Agng & EnHealth 2002 for assessng rsks to aquatc ecosystems, ANZECC & ARMCANZ 2000a.

Whenever crtera from overseas or ste-specfic rsk-based crtera are used, agreement from DEC should be obtaned. The study results plus the accompanyng analyss should be provded to DEC for revew and, f approprate, endorsement of the crtera for use at the ste n queston. In the context of ste-specfic rsk assessment, rsk percepton may nfluence the type or level of rsk consdered acceptable. The percepton of rsk may not be the same as the level of rsk assumed by those undertakng the study. Also, where there s sgnficant uncertanty about the rsks assocated wth exposure to groundwater contamnaton, measures to prevent exposure should be mplemented before resolvng complex aspects of rsk.

2.3.3 Contamnant fate and transport modellng


Contamnaton assessment commonly ncorporates contamnant fate and transport predctons, ncludng analytcal and numercal mathematcal modellng. Such modellng can be used to: assst n valdatng the conceptual ste model and dentfyng mportant data gaps predct the travel tmes of contamnants from the pont of groundwater extracton to a pont of groundwater use

16

predct contamnant concentratons, mass fluxes, and exposure doses assess the mpact of assumptons and uncertanty n parameter values on the predctons assst n selectng a management strategy and demonstratng ts effectveness assst n remedal desgn.

Contamnant fate and transport modellng wll often be necessary to assess the lkely effectveness of natural attenuaton n achevng remedal goals and demonstratng remedal progress and success. Where fate and transport modellng s undertaken for predctve purposes (e.g. for a rsk assessment), the model must be based on a vald conceptual ste model and the nformaton obtaned from the modellng study must adequately assst n makng decsons about the acton needed to address groundwater contamnaton. Modellng the fate and transport of groundwater contamnants s a complex task. In all cases: modellng should only be undertaken by approprately qualfied professonals experenced n groundwater contamnaton the model used must reflect best ndustry practce, and the proponent must clearly demonstrate the applcablty and adequacy of the model for a specfic ste and modellng objectve model assumptons and parameter values must be approprately conservatve and the assocated report must clearly explan the valdty of all assumptons made and all nput parameter values selected.

The degree of conservatsm requred n the model wll depend on varous factors. Generally, the level of conservatsm can be reduced by mproved ste charactersaton, adequate model calbraton and senstvty analyses. Whle contamnant mgraton n groundwater occurs n three dmensons, not all dmensons need to be ncorporated nto the mathematcal model, dependng on the objectve of the modellng study and the degree of conservatsm that s employed. Some gudance on fate and transport modellng s provded n Schedule B(2) of the ste contamnaton measure (NEPC 1999).

17

2.3.4 Addtonal aspects to consder


Although a wde range of analytcal and numercal modellng tools and vsualsaton ads s now avalable to assst n the assessment of groundwater contamnaton, professonals usng these tools must have consderable knowledge of relevant processes combned wth analytcal sklls and professonal judgement. Among other aspects, the followng ssues should be taken nto account n plannng nvestgatons nto groundwater contamnaton: Approprately qualfied and experenced groundwater professonals must plan and mplement a sutable groundwater nvestgaton. Schedule B(2) of the ste contamnaton measure (NEPC 1999) and the Australian guidelines for water quality monitoring and reporting (ANZECC & ARMCANZ 2000b) should be consdered. Data qualty objectves, for nstance as per the Guidelines for the NSW site auditor scheme (second edton) (DEC 2006), should be defined before the nvestgaton. The exstence of groundwater has to be acknowledged at every potentally contamnated ste. If there s the potental for groundwater contamnaton, ntrusve groundwater nvestgatons should generally be carred out unless groundwater s present at greater depth (e.g. more than 15 m below the ground surface), n whch case the rsks to potental receptors should be consdered n assessng the need for ntrusve nvestgatons. Intrusve nvestgatons at greater depth may not be requred where the natural background qualty of the groundwater s poor and the groundwater yeld s low. In any case, advce from relevant agences should be obtaned f ntrusve nvestgatons are consdered unwarranted. Groundwater nvestgatons at a source ste requre careful plannng and executon to avod groundwater contamnaton as a result of bore constructon. Under certan crcumstances (e.g. contamnaton wth dense non-aqueous phase lqud (DNAPL)), observaton bores may need to be nstalled away from suspected source areas. The complexty of the groundwater system, whch may nclude perched groundwater near the surface, an unconfined aqufer at shallow depth and sem-confined or confined aqufers at greater depths, needs to be consdered.

18

Dfferent water-bearng zones at a ste may have dfferent attrbutes, such as permeablty and yeld, and dfferent envronmental values. Properly constructed groundwater montorng wells are essental. Aqufer nterconnecton and cross-contamnaton must be avoded. Gudance on constructon and use of montorng wells s provded n Minimum construction requirements for water bores in Australia (LWBC 2003) and n Groundwater sampling guidelines (EPA Vctora 2000). Many methods are avalable for obtanng groundwater samples from montorng wells. Dependng on the condtons (e.g. chemcals of concern, geology), some gve more relable results than others. It s mportant to select the most approprate samplng technque for a partcular well and contamnant sute, takng account of modern samplng methods. In ths context, the Groundwater sampling guidelines (EPA Vctora 2000) should be consdered. The collecton of groundwater samples from pts s subject to potental nterference, ncludng gas exchange and mxng durng pt excavaton and hgh suspended sold loads. Although useful qualtatve ndcatons may often be obtaned from such samples, they should not be ncluded n the same data set as samples from montorng wells. The Australan Standard AS2368 (Standards Australa 1990) Test pumping of water wells should be consdered n the context of assessng hydraulc propertes of aqufers. Approprate lcences/consent for groundwater bores must be obtaned from DNR. Extracted groundwater must be dsposed of n accordance wth the POEO Act and the trade wastes agreement wth the approprate water authorty. Off-ste dsposal must consder the Environmental guidelines: assessment, classification and management of liquid and non-liquid wastes (NSW EPA 1999). Groundwater nvestgatons must consder that groundwater flow and contamnant transport occur n three dmensons. Generally, observaton wells should be desgned to sample dscrete, relatvely short, vertcal ntervals targetng a depth of samplng based on expected concentraton profiles and relevant exposure scenaros.
19

Geophyscal technques that may contrbute to valuable nformaton about the contamnant plume should be consdered. Both natural and emplaced ground materals are heterogeneous. The potental presence of preferred pathways should always be consdered when desgnng a groundwater montorng well network. Off-ste groundwater nvestgatons wll generally be requred to delneate a contamnant plume. Such nvestgatons may also be mportant to gan evdence that the ste under nvestgaton s not the source ste. The effect of groundwater recharge on the depth of contamnant plumes must be consdered n decdng on samplng depths. Informaton n the Groundwater management handbook (Sydney Coastal Councls Group 2006) should be consdered as the handbook contans relevant detals on, for nstance, decommssonng bores.

20

3 Managing groundwater contamination


3.1 Introduction
In these gudelnes, the term management covers all measures taken to address groundwater contamnaton, ncludng measures to mtgate rsks from the contamnaton. Measures may nclude, but are not lmted to: notfyng DEC, DNR, NSW Health, local councls, affected property owners, groundwater users, owners of subsurface utltes and others, as approprate, of the presence of groundwater contamnaton plume contanment actve or passve clean-up of contamnated groundwater ongong montorng of groundwater, and contngency plans mplementng groundwater management plans to mtgate rsks restrctng groundwater use n, and down-gradent of, the contamnant plume.

Managng groundwater contamnaton, for nstance, to protect town water supply wells may also nclude mplementng strateges such as wellhead protecton plans to prevent groundwater n areas that supply water to a publc well from becomng contamnated. More detals about wellhead protecton plans can be found n The NSW groundwater quality protection policy (NSW Government 1998). The most approprate management strategy for a partcular ste where groundwater s contamnated wll depend on a range of factors ncludng the nature and extent of contamnaton, the severty of the contamnaton, the avalablty of practcal remedal optons, and communty expectatons. Publc nvolvement s mportant n dentfyng approprate management responses. In ths context, the Guidelines for groundwater protection in Australia (ANZECC & ARMCANZ 1995) and Schedule B(8) of the ste contamnaton measure (NEPC 1999) should be consdered. The followng sectons dscuss ways of determnng an approprate management strategy. Note that the ssues dscussed n these sectons are relevant to the management of contamnated groundwater rrespectve of whether the contamnaton s managed under the CLM Act.
21

3.2 Management responses to contamination


Whle preventon of groundwater contamnaton s a key prncple, contamnaton of groundwater s n many cases a legacy of past practces. Where contamnaton s dentfied, the management objectves are to protect human and ecologcal health and to ultmately restore the groundwater to ts natural background qualty. To acheve these objectves, the followng management responses must be consdered: control short-term threats arsng from the contamnaton (see 3.3) restrct groundwater use (see 3.4) prevent or mnmse further mgraton of contamnants from source materals to groundwater (see 3.5) prevent or mnmse further mgraton of the contamnant plume (see 3.6) clean up groundwater to protect human and ecologcal health, restore the capacty of the groundwater to support the relevant envronmental values and, as far as practcable, return groundwater qualty to ts natural background qualty (see Secton 4).

As a mnmum, management of contamnated groundwater should contnue untl human and ecologcal health s protected and the capacty of the groundwater to support relevant envronmental values s restored. Management responses to groundwater contamnaton should focus on the greatest threats first, and the benefits of groundwater cleanup must outwegh any ncdental negatve mpacts that could arse.

3.3 Controlling short-term threats


Immedate acton s requred where short-term threats, that s, acute rsks, are dentfied. Such rsks nclude the accumulaton of explosve vapours n underground utltes, or unacceptable rsks to human or ecologcal health from short-term exposures to contamnaton. As an example of the type of management response that may be requred, DNR may mpose a ban on the extracton of groundwater from bores to prevent exposure to contamnants. In certan crcumstances, NSW Health also has powers to restrct the use of groundwater n NSW.
22

3.4 Restricting groundwater use


In some crcumstances, the use of contamnated groundwater both on- and off-ste may need to be restrcted. DNR s the lead agency for managng groundwater use n NSW. DNR also determnes whether use restrctons are necessary where contamnaton precludes the safe use of groundwater. Lason wth DNR s essental f groundwater use restrctons are consdered necessary. In specfic cases, DNR may restrct groundwater use near a contamnated ste to prevent exposure whle groundwater remedaton occurs. Ths type of nsttutonal control may be necessary, for example, where a ste s mplementng a long-term groundwater remedy. In general, use restrcton, other than as an emergency response to reduce rsks, would only be supported where: the sources of contamnaton have been controlled the exstng boundares of the contamnant plume have been dentfied the groundwater contamnaton s beng cleaned up or has been cleaned up consstent wth DECs requrements there s an acknowledgement from the party responsble for the remedaton of ts oblgatons to protect human and ecologcal health, and a commtment that groundwater management actons wll contnue untl the groundwater qualty protects relevant envronmental values the groundwater management plan, ncludng provsons for the regular reportng of ongong groundwater qualty, has been documented and provded to DNR.

Restrctng access to groundwater wll not be consdered an approprate management strategy n solaton unless there are no other remedaton optons avalable. Where groundwater use s restrcted because of contamnaton, DEC or DNR may requre the party responsble for the contamnaton to undertake some actons to support the use restrctons. These could nclude, for nstance, the development and mplementaton of a communcaton strategy to nform the communty about groundwater contamnaton or ongong bore samplng n the area of the contamnant plume.
23

In any case, the fact that the use of groundwater s restrcted should not be be used to argue the case for lower clean-up standards, although the tmeframe to acheve the clean-up may be affected.

3.5 Source control


The elmnaton or control of all known and suspected sources of groundwater contamnaton s mportant. A source s any materal that acts as a reservor for the contnued contamnaton of groundwater. Sources of ongong groundwater contamnaton nclude prmary sources, such as leakng chemcal storage tanks, and secondary sources, such as separate phase lquds n groundwater and overlyng sols. Source control refers to a range of actons, ncludng removal, treatment n place, and contanment, whch are desgned to mnmse mgraton of contamnants nto groundwater. Source control s mportant because mnmsng further contamnant releases to the envronment s often requred for the successful management of a contamnant plume. Sources of groundwater contamnaton also need to be addressed because t s an offence under the POEO Act to pollute groundwater. Source control actons should be undertaken early n the assessment and management process. In partcular: Leakng underground tanks must be repared or replaced n accordance wth approprate standards such as The design, installation and operation of underground petroleum storage systems (Australan Insttute of Petroleum 2002) as soon as a leak s confirmed, and further nvestgatons must determne the extent, f any, of contamnaton of sols and groundwater. Non-aqueous phase lquds must be cleaned up to the extent practcable see 3.5.1. Contamnated sols need remedatng so they no longer pose a potental rsk to groundwater qualty. Ths may requre the development of sol crtera that take nto account the leachng potental of contamnants from sol nto groundwater. Note that the health-based sol nvestgaton levels adopted n Guidelines for the site auditor scheme (DEC 2006) and the ste contamnaton measure (NEPC 1999) do not take groundwater protecton nto account.

24

Where complete source removal or treatment s not possble: the remanng source should be contaned for the entre tme that t s present n the groundwater any source contanment wll generally need to be supported by ongong groundwater qualty montorng.

Source contanment as part of a long-term management response wll generally only be approprate where there are sgnficant dfficultes n removng or treatng the contamnaton, for nstance where: treatment technologes are not avalable or treatment s not techncally feasble the volume of materals or complexty of the ste make source removal or treatment mpractcable removng or treatng the source would have unavodable severe adverse effects on other aspects of the envronment.

3.5.1 Non-aqueous phase lquds


Non-aqueous phase lquds (NAPLs) n the subsurface provde an ongong source of contamnaton. NAPLs that are n contact wth groundwater consttute groundwater contamnaton. Where lght NAPLs (LNAPLs) or dense NAPLs (DNAPLs) are present n the subsurface, they must be removed or treated as much as practcable. Partcular care, however, s requred n the assessment and clean-up of DNAPL contamnaton to prevent moblsaton or an ncreased rate of dssoluton. Where complete removal or treatment of the NAPL s mpractcable, as may be the case wth some DNAPLs n complex geologcal meda, ongong montorng and management of the contamnaton s requred as a mnmum for as long as necessary, to ensure the protecton of human and ecologcal health. Sources and plumes wll need to be contaned to the maxmum extent practcable, and remedaton to address the dssolved-phase contamnants may also be requred. A strategy for controllng NAPL contamnaton should have the followng objectves: to ensure the protecton of human and ecologcal health to control further mgraton of contamnants from subsurface NAPLs to the surroundng groundwater (source control)
25

to reduce NAPL mass to the extent practcable (source removal or treatment).

It s recognsed that clean-up of NAPL contamnaton can be dfficult. For nstance, there can be hgh costs and uncertan benefits n aggressve source zone treatment of some NAPLs. Therefore, the remedal objectve for some stes wth recalctrant sources of NAPL may be to contan the source materal and prevent or mnmse further contamnant mgraton. Nonetheless, presumptons about the practcablty of source zone remedaton must keep pace wth emergent technology; t should not automatcally be assumed that source zone remedaton s not feasble. Any assessment that source removal of NAPL contamnants s mpractcable should be clearly documented.

3.6 Plume containment


In respondng to groundwater contamnaton, one goal s to contan the extent of the contamnant plume, that s, to prevent or mnmse further plume mgraton whle other management actons are takng place. Plume contanment, as the sole long-term response to groundwater contamnaton, s generally only acceptable when cleanng up contamnated groundwater s not practcable. Proponents of long-term contanment must demonstrate they have adequately consdered all rsks posed by the groundwater contamnaton. Systems must be developed to montor the effectveness of the contanment n the long term, and contngency plans must be developed f montorng data shows that the contanment s not effectve. In ths context, the responsbltes for, and resourcng of, long-term management and contngency plans need to be addressed.

3.7 Clean-up of contaminated groundwater


Clean-up s an mportant part of managng groundwater contamnaton. Secton 4 provdes n-depth nformaton on objectves and procedures for cleanng up contamnated groundwater, and should be read n conjuncton wth ths secton.

26

4 Cleaning up contaminated groundwater


Ths secton should be read n conjuncton wth Secton 3 as clean-up s an mportant part of managng contamnated groundwater, and materal n Secton 3 wll also be relevant for ths secton. Dscusson of clean-up has been separated from Secton 3 for ease of readablty. Clean-up objectves for contamnated groundwater should be establshed n the followng preferental order: 1 Clean up so natural background water qualty s restored. 2 Clean up to protect the relevant envronmental values of groundwater, and human and ecologcal health. 3 Clean up to the extent practcable. Ths herarchy s dscussed below.

4.1 Clean up so natural background water quality is restored


Ideally, contamnated groundwater should be restored as much as practcable to ts natural background qualty. Ths s partcularly mportant for prstne or near-prstne groundwater systems of hgh yeld. In practce, cleanng up so natural background concentratons are restored can be techncally dfficult and extremely costly. Therefore, where t s not practcable to restore background qualty, an nterm clean-up goal can be based on protectng envronmental values and preventng potental rsks to human and ecologcal health. Even where t s not practcable n the short term, restorng water qualty to ts natural background state should reman the long-term remedal objectve for contamnated groundwater. In ths context, the use of montored natural attenuaton should be consdered.

4.1.1 Montored natural attenuaton


Natural attenuaton of contamnants n groundwater may be defined as the: effect of naturally occurrng physcal, chemcal and bologcal processes to reduce the load, concentraton, flux or toxcty of pollutng substances n groundwater (UK Envronment Agency 2000).

27

These processes nclude bodegradaton, dsperson, dffuson, sorpton, volatlsaton, and chemcal or bologcal stablsaton, transformaton or destructon. Montored natural attenuaton (MNA) can also be part of a strategy for managng rsks from contamnated groundwater. However, a detaled evaluaton of the contamnaton, the aqufer characterstcs and potental rsks s necessary to confirm that MNA should be part of the management strategy. A proposal for MNA must nclude clear evdence demonstratng that: sgnficant attenuaton of contamnants s occurrng remedal goals can be met n an adequate tmeframe the proposed montorng program s sutable.

For DEC to accept MNA as a sutable approach at a ste, natural attenuaton processes that reduce the mass of dssolved contamnants (e.g. bodegradaton) wll generally need to be clearly demonstrated. Appendx 3 presents more detaled gudance on the approprate evaluaton and mplementaton of MNA for use n NSW.

4.2 Clean up to protect the relevant environmental values of groundwater, and human and ecological health
Where the clean-up goal s to protect the envronmental values of groundwater, and human and ecologcal health, numercal cleanup crtera may need to be used to measure the success of remedal actons. Clean-up crtera at the pont of use must employ relevant exstng generc GILs or GILs derved on a ste-specfic bass. At the pont of extracton, ste-specfic clean-up crtera may be derved that protect the applcable envronmental values, and human and ecologcal health, at the pont of use. Where numercal clean-up crtera for ether the pont of use or the pont of extracton are proposed, based on a ste-specfic assessment of rsks, the crtera must be derved through comprehensve evaluaton of all actual and potental exposure pathways. The ste-specfic use of clean-up crtera must take nto account schedules B(4) and B(5) of the ste contamnaton measure (NEPC 1999). Clean-up crtera derved for the pont of use whch are
28

consdered to be protectve of aquatc ecosystems may also need to consder the process outlned n ANZECC & ARMCANZ 2000a. DEC should be consulted f ste-specfic rsk-based crtera are used.

4.3

Clean up to the extent practicable


Where DEC has decded to regulate the management of contamnated groundwater under Part 3 of the CLM Act, DEC must be satsfied wth any remedaton plan or proposal for a voluntary remedaton agreement. In ths context, DEC wll consder what s practcable and may seek ndependent expert verficaton of any supportng clams. In some cases, t may not be practcable to contnue cleanng up the groundwater to the pont where all ts envronmental values are restored. In such nstances, when regulatng the remedaton, DEC may consder proposed nterm clean-up goals n consultaton wth stakeholders.

4.3.1 Demonstratng restorng envronmental values s mpractcable


If a proponent consders that clean-up to restore the protecton of envronmental values s mpractcable n the future, ths must be clearly demonstrated to DEC. The evaluaton of practcablty should be documented aganst each factor lsted below: techncal capablty to acheve the clean-up clean-up costs the value of the groundwater resource threats the contamnaton poses to human or ecologcal health.

Proposed clean-up measures should correlate wth the value of the groundwater resource and the severty of the contamnaton. Further, any proposal for the clean-up that argues mpractcablty must nclude an acknowledgement that the long-term objectve s to restore the protecton of all relevant envronmental values, and ultmately acheve natural background qualty. In such cases, ongong management and montorng of the groundwater may be requred to ensure the protecton of human and ecologcal health. In consderng the nature of the remedaton requred for a ste, DEC may consder what actons are practcable. If t s mpractcable to clean up groundwater to a concentraton needed to restore the protecton of envronmental values, DEC may accept that clean-up to the extent practcable has occurred and that, subject to approprate ongong management of exposures to the contamnants and perodc revew, further clean-up s not requred. However, acute rsks
29

from the contamnaton, such as rsks from short-term exposure or a rsk of exploson from the accumulaton of vapours, must be resolved wthout delay. In all cases where clean-up to restore envronmental values cannot be acheved: t s stll necessary to clean up to the extent practcable, to mnmse the mpact on envronmental values human and ecologcal health must be protected plume contanment should be mplemented to prevent the plume from spreadng ongong groundwater montorng may be requred the possblty of cleanng up the groundwater contamnaton should be perodcally reassessed to account for emergng technologes provsons are requred for long-term resourcng and responsblty for any ongong management strategy nformaton must be recorded and dssemnated.

In consderng the practcablty of cleanng up the groundwater contamnaton, DEC wll take nto account techncal, logstcal and financal consderatons. Before DEC agrees to the proposal, t may seek nput from DNR on the current and realstc future uses of the groundwater and the mplcatons that resdual contamnaton may have for groundwater resource management. DNR would consder the nformaton provded n a groundwater management plan where long-term restrctons on groundwater use are requred. Where DEC agrees that clean-up to the extent practcable has occurred, ths does not remove the proponents responsblty for ongong management of the resdual contamnaton. The remedaton proposal should be accompaned by: a commtment to ongong montorng and re-evaluaton of the practcablty of clean-up. A satsfactory montorng and reportng program must be mplemented to contnually evaluate the contamnaton. a groundwater management plan (GMP) that specfies measures whch wll be mplemented to mtgate rsks to human and ecologcal health (see 5.3.2).

30

acknowledgement that future management ncludng cleanup acton may be requred by the government to ensure the protecton of human and ecologcal health. provson for long-term resourcng and responsblty for any ongong management strategy.

Any ongong management actons may be enforceable through statutory means such as a regulatory nstrument ssued under the CLM or POEO Act.

4.4 Clean-up impacts


The benefits from undertakng groundwater clean-up must outwegh any ncdental negatve mpacts to human health or the envronment that could arse from the clean-up. Groundwater remedaton technologes that nvolve dscharge to surface water, land or ar must not pollute the recevng envronment. Remedaton ncorporatng dscharge to groundwater must not cause unacceptable contamnaton, such as an adverse mpact on envronmental values, from the uncontrolled presence of treatment products or compounds derved from contamnant degradaton. Where t s proposed to add any substance to groundwater for treatment purposes, such as chemcal or bologcal agents to help the contamnants degrade, the proponent must ensure that all necessary approvals and lcences have been obtaned.

4.5 Clean-up timeframe


The clean-up of groundwater contamnaton should occur n a tmeframe that s commensurate wth techncal dfficultes and potental rsks. Where remedaton s beng managed under the CLM Act, DEC wll set approprate clean-up tmeframes. Unacceptable exposures to contamnants must be addressed as a prorty. If receptors are already beng exposed to potentally unacceptable concentratons of contamnants n groundwater, drectly or ndrectly (e.g. contamnants emtted from groundwater to ndoor ar), acton must be taken as soon as possble to prevent these exposures. Examples of factors that should be taken nto account when developng clean-up tmeframes for a specfic ste nclude:
31

the rsks from exposure to contamnaton the relevant envronmental values whch may be affected the source, nature and extent of contamnaton hydrogeologcal condtons the relablty of nterm exposure controls the avalablty and effectveness of sutable clean-up technologes and dsposal optons communty preferences the financal resources of the party responsble for clean-up ntergeneratonal equty.

When evaluatng remedal optons, those that acheve the desred clean-up goals n the shortest tmeframe should be preferred. Uncertantes assocated wth cleanng up groundwater may make t dfficult to exactly specfy when a remedal strategy wll acheve the clean-up goals. It s not always possble to predct how long t wll take to return groundwater qualty to a state that protects the relevant envronmental values because of complextes assocated wth, for example, specfic contamnant types and contamnant nteractons, hydrogeologcal characterstcs and technology lmtatons. Nonetheless, predctng clean-up tmeframes s valuable n evaluatng and selectng the preferred remedaton optons. Longer tmeframes for cleanng up groundwater contamnaton may be acceptable when there are adequate montorng and relable controls to protect human and ecologcal health, and the plume has been approprately contaned.

4.6 Degraded local groundwater quality


In some cases, the extent to whch the groundwater can be cleaned up may be lmted by the presence of contamnaton from other sources, such as contamnant releases from other stes that are hydraulcally up-gradent of the subject ste. Where elevated concentratons of contamnants n groundwater are dentfied enterng a ste, DEC should be contacted to dscuss what mplcatons these may have for clean-up strateges. The local groundwater may also be degraded due to naturally occurrng substances. The local councl and DNR may need to be

32

nformed n such cases because unacceptable human health and ecologcal rsks may be assocated wth these substances. Polluton preventon remans of paramount mportance. Where less strngent clean-up s justfied n the nterm to deal wth degraded local groundwater qualty, ths does not dmnsh the need to prevent further contamnaton.

4.7 Environmental monitoring


Envronmental montorng and reportng are often needed to assess whether management actons at a partcular ste are achevng, or movng towards, the clean-up goals. Envronmental montorng s a key component of any remedaton strategy, and s also mplemented through an ongong management strategy f resdual contamnaton remans at a ste after remedal works have ceased. Montorng groundwater s not a management response n solaton but s needed to supplement other management actons. Montorng strateges should artculate: approprate montorng locatons and depths wthn and downgradent of the contamnant plume the relevant assessment crtera to be used n evaluatng montorng results the frequency of montorng and reportng the process for revewng montorng data and ways n whch the data wll feed nto decsons about the contamnaton and management strategy the length of tme for whch montorng s expected to contnue (generally, montorng should contnue whle there s resdual groundwater contamnaton) the regulatory authortes nvolved (ncludng state and local government) and the management nputs requred from each.

4.8 Groundwater management plans


A groundwater management plan (GMP) provdes a mechansm for managng rsks from potental exposure to contamnants n groundwater. For nstance, where skn contact wth contamnated groundwater s possble, a GMP can outlne procedures that protect people who could come nto contact wth groundwater, such as workers undertakng excavatons below the water table. GMPs
33

should be ted to a regulatory framework to ensure that they are approprately mplemented and enforced. A GMP should nclude a contngency plan whch wll need to state clearly what the objectves of the plan are, what crcumstances wll trgger clean-up actons, and who wll be responsble for ts mplementaton.

4.8.1 Regulatory controls for ongong management of groundwater contamnaton


Where ongong management of groundwater contamnaton s proposed at a regulated ste: The management plan should be reasonably enforceable (e.g. va a regulatory nstrument ssued under the CLM Act or development consent condtons ssued by the relevant plannng authorty). The management plan should nclude well-defined reportng arrangements to local or state authortes as applcable. There should be approprate publc notficaton of the restrctons applyng to the land to ensure that potental purchasers or other nterested partes are aware of the restrctons, for example, approprate notatons on a plannng certficate ssued under secton 149(2) of the Environmental Planning and Assessment Act 1979 or a covenant regstered on the ttle to land under secton 88B of the Conveyancing Act 1919. There should be a clear delneaton of montorng and reportng responsbltes. The party responsble for the contamnaton (.e. the polluter or current owner or other partes as per the CLM Act) would normally be responsble for mplementng and mantanng all necessary ongong management.

34

5 Regulation 5.1 Regulation under the CLM Act


Owners of contamnated stes and partes who caused contamnaton must notfy DEC under the CLM Act. Once DEC s notfied of contamnaton, t wll revew relevant nformaton to determne whether the assessment and management of the contamnaton warrants regulatory control under the CLM Act. At the tme of wrtng, the CLM Act s under revew and amendments to the Act, ncludng amendments to the notficaton requrements, have been proposed. On the bass of ths nformaton, DEC may requre further nvestgaton, clean-up, or another approprate management response. If there s no acceptable voluntary proposal to carry out the requred works, DEC may requre the approprate person (as defined n the CLM Act), or a publc authorty that s not an approprate person, to carry out the works n accordance wth the CLM Act. The cost of nvestgaton or remedaton carred out under the CLM Act can be recovered n court from the people who were responsble for the contamnaton. Management under the CLM Act also ensures that the assessment and management process s transparent so the affected or nterested communty s kept nformed. Involvement by DEC can be ntated at any stage durng the assessment or management of contamnated groundwater. The possblty of future nvolvement by DEC does not prevent a party from undertakng the nvestgatons outlned n Secton 2. When contamnated groundwater s beng managed under the CLM Act, DEC may requre a person responsble for managng the contamnaton, such as the polluter or ste owner, to notfy DNR of the contamnaton. DNR may use and make ths nformaton avalable as t sees fit for groundwater resource management, whch may nclude mplementng necessary use restrctons. The approprate persons may also be requred to notfy other affected partes ncludng the local communty where, for nstance, groundwater uses are precluded by contamnaton.

5.2 Regulation under the POEO Act


Preventon of groundwater polluton s a key factor. Polluton of groundwater s an offence under the POEO Act and prosecuton for offences aganst the provsons of the Act can result n sgnficant
35

fines. If an approprate regulatory authorty reasonably suspects that a polluton ncdent has occurred or s occurrng, they can also drect the occuper of a premses or person causng the polluton to take clean-up acton. DEC wll be the approprate regulatory authorty for actvtes lcensed under the POEO Act.

5.3 Requirements under SEPP 55


State environmental planning policy no. 55 Remediation of land (SEPP 55) contans requrements for remedatng contamnaton, ncludng groundwater contamnaton. In summary, SEPP 55: requres plannng authortes to consder, when consderng a rezonng applcaton, whether the land s contamnated. If the land s contamnated, the plannng authorty must be satsfied that t s sutable n ts contamnated state, or wll be sutable after remedaton, for the purposes for whch the land wll be rezoned. If the land requres remedaton before use for a partcular purpose, the plannng authorty must be satsfied the land wll be so remedated before beng used for that partcular purpose. provdes that a consent authorty must not agree to the carryng out of any development unless t has consdered whether the land s contamnated. If the land s contamnated, the consent authorty must be satsfied that t s sutable n ts contamnated state, or wll be sutable after remedaton, for the purposes for whch the development s proposed to be carred out. If the land requres remedaton before use for a partcular purpose, the consent authorty must be satsfied t wll be so remedated before beng used for that partcular purpose. provdes that, before determnng an applcaton for rezonng or development consent for certan classes of land, a plannng authorty/consent authorty must consder a report on the findngs of a prelmnary nvestgaton carred out n accordance wth contamnated land management gudelnes. makes remedaton permssble across NSW despte any provson of an envronmental plannng nstrument to the contrary, although n some cases only wth consent. requres all remedaton to comply wth certan standards and gudelnes ncludng gudelnes n force under the CLM Act.

36

6 References
Amercan Socety for Testng and Materals 2003, Guide for developing conceptual site models for contaminated sites, ASTM E1689-95e1 ANZECC & ARMCANZ 2000a, Australian and New Zealand guidelines for fresh and marine water quality, Natonal Water Qualty Management Strategy, Paper No. 4, Commonwealth of Australa, www.mncos.gov.au/pub_anzwq.html ANZECC & ARMCANZ 2000b, Australian guidelines for water quality monitoring and reporting, Natonal Water Qualty Management Strategy, Paper No. 7, Commonwealth of Australa, www.mncos.gov. au/pub_agwq.html ARMCANZ & ANZECC 1998, National water quality management strategy implementation guidelines, Natonal Water Qualty Management Strategy, Commonwealth of Australa, www.mncos. gov.au/pdf/nwqms/mplementatongudelnes.pdf ANZECC & ARMCANZ 1995, Guidelines for groundwater protection in Australia, Natonal Water Qualty Management Strategy, Commonwealth of Australa, www.mncos.gov.au/pdf/nwqms/ gudelnes-for-groundwater-protecton.pdf Australan Insttute of Petroleum 2002, The design, installation and operation of underground petroleum storage systems Danelopol DL, Grebler C, Gunatlaka A & Notenboom J 2003, Present state and prospects for groundwater ecosystems, n Environmental Conservation 30, pp 104130 DEC 2006, Guidelines for the NSW site auditor scheme, 2nd edton, Department of Envronment and Conservaton NSW, www. envronment.nsw.gov.au/resources/audtorglnes06121.pdf Department of Health and Ageng & EnHealth 2002, Environmental health risk assessment: Guidelines for assessing human health risks from environmental hazards, Commonwealth of Australa, www.health.gov. au/nternet/wcms/Publshng.nsf/Content/health-pubhlth-publcatdocument-metadata-env_hra.htm/$FILE/env_hra.pdf EPA Vctora 2000, Groundwater sampling guidelines, Publcaton 669, http://epanote2.epa. vc.gov.au/EPA/ publcatons.nsf/2f1c2625731746aa4a256ce90001cbb5/ 6bc0feabe895bc044a25670f00215055

37

Hancock PJ, Boulton AJ and Humphreys WF 2005, Aqufers and hyporhec zones: Towards an ecologcal understandng of groundwater, Hydrogeology 13, pp 98111 LWBC 2003, Minimum construction requirements for water bores in Australia, Edton 2, revsed September 2003, Land and Water Bodversty Commttee, Commonwealth of Australa, www.nrme.qld. gov.au/water/pdf/bore_aust/mcrwba.pdf NEPC 1999, National environment protection (assessment of site contamination) measure 1999, (ste contamnaton measure), Natonal Envronment Protecton Councl, www.ephc.gov.au/nepms/cs/con_ stes.html NHMRC & NRMMC 2004, Australian drinking water guidelines, www. nhmrc.gov.au/publcatons/_files/awgfull.pdf NSW DUAP & NSW EPA 1998, Managing land contamination: Planning guidelines, SEPP 55 remediation of land, NSW Department of Urban Affars and Plannng and NSW Envronment Protecton Authorty, www.epa.nsw.gov.au/resources/gu_contam.pdf NSW EPA 1999, Environmental guidelines: assessment, classification and management of liquid and non-liquid wastes, NSW Envronment Protecton Authorty, www.envronment.nsw.gov.au/resources/ waste_gude.pdf NSW Government 2006, Environmental objectives for water quality and river flow, www.envronment.nsw.gov.au/eo NSW Government 2002, The NSW state groundwater dependent ecosystems policy, NSW Department of Land and Water Conservaton, www.dlwc.nsw.gov.au/care/water/wr/pdfs/ polcy_180602.pdf NSW Government 1998, The NSW groundwater quality protection policy, NSW Department of Land and Water Conservaton, www.dlwc. nsw.gov.au/care/water/wr/pdfs/qualty_polcy.pdf NSW Government 1997, The NSW state groundwater policy framework document, NSW Department of Land and Water Conservaton, www. dlwc.nsw.gov.au/care/water/wr/pdfs/gfrmpol.pdf Standards Australa 1990, Test pumping of water wells, AS2368 (1990) www.standards.com.au/select/Scrpt/Detals. asp?DocN=stds000000718 Sydney Coastal Councls Group Inc 2006, Groundwater management handbook, www.sydneycoastalcouncls.com.au
38

UK Envronment Agency 2000, Guidance on the assessment and monitoring of natural attenuation of contaminants in groundwater, Envronment Agency, Brstol, http://publcatons.envronmentagency.gov.uk/pdf/SR-DPUB95-e-e.pdf

Relevant Acts of Parliament and policies


Contaminated Land Management Act 1997 www.epa.nsw.gov.au/ legal/envacts.htm Conveyancing Act 1919 www.austl.edu.au/au/legs/nsw/consol_act/ ca1919141/ Environmental Planning and Assessment Act 1979 www.legslaton.nsw. gov.au/vewtop/ nforce/act+203+1979+first+0+N Local Government Act 1993 www.austl.edu.au/au/legs/nsw/consol_ act/lga1993182/ NSW Public Health Act 1991 www.austl.edu.au/au/legs/nsw/consol_ act/pha1991126/ NSW Water Sharing Plans www.naturalresources.nsw.gov.au/water/ nd_sharng_plans.shtml Protection of the Environment Operations Act 1997 www.epa.nsw.gov. au/legal/envacts.htm Water Act 1912 www.austl.edu.au/au/legs/nsw/consol_act/ wa191283/ Water Management Act 2000 www.dlwc.nsw.gov.au/care/water/wml/ pdfs/wmact2000-92.pdf

Suggested further reading


Amercan Petroleum Insttute 2000, Non-aqueous phase liquid (NAPL) mobility limits in soil Amercan Petroleum Insttute 1998, Evaluation of sampling and analytical methods for measuring indicators of intrinsic bioremediation Amercan Socety for Testng and Materals 2004, Standard guide for remediation of groundwater by natural attenuation at petroleum release sites, ASTM E1943-98 Amercan Socety for Testng and Materals 1992, Standard practice for evaluating mathematical models for the environmental fate of chemicals, ASTM E978
39

Bedent PB, Rfa HS and Newell CJ 1999, Groundwater contamination: transport and remediation, Prentce Hall & Sons Brtsh Geologcal Survey 2003, Groundwater and its susceptibility to degradation: a global assessment of the problem and options for management, report on behalf of the Unted Natons Envronment Programmes Dvson of Early Warnng and Assessment BP Ol Internatonal 2001, RISC-integrated software for clean-ups, users manual, Sunbury, UK Buldng Research Establshment 2001, Concrete in aggressive ground, Special Digest No.1, Part 1: Assessing the aggressive chemical environment, UK Department of Trade and Industry, BRE Centre for Concrete Constructon, BRE Centre for Ground Engneerng and Remedaton, London, UK Davs GB, Trefry MG, and Patterson BM 2004, Petroleum and solvent vapours: quantifying their behaviour, assessment, and exposure, a CSIRO Land and Water Report to the Western Australan Department of Envronment Department of Envronmental Protecton (Western Australa) 2004, Use of monitored natural attenuation for groundwater remediation Department of Envronmental Protecton (Western Australa) 2001, Potentially contaminating activities, industries and land uses EPA Vctora 2006, Hydrogeological assessment (groundwater quality) guidelines, Envronment Protecton Authorty Vctora, Publcaton 668. EPA Vctora 2002, The clean up and management of polluted groundwater, Envronment Protecton Authorty Vctora, Informaton Bulletn, Publcaton 840 Fetter CW 2000, Applied hydrogeology, Prentce Hall Inc, Englewood Clffs, NJ, USA Fetter CW 1998, Contaminant hydrogeology, Prentce Hall Inc, Englewood Clffs, NJ, USA Freeze RA & Cherry JF 1979, Groundwater, Prentce Hall Inc, Englewood Clffs, NJ, USA Interstate Technology and Regulatory Cooperaton Work Group 2001, Technical and regulatory guidance for in-situ chemical oxidation of contaminated soil and groundwater
40

Interstate Technology and Regulatory Cooperaton Work Group 2000, Dense non-aqueous phase liquids (DNAPLs): review of emerging characterization and remediation technologies Murray-Darlng Basn Commsson 2000, Groundwater flow modelling guideline Nelsen DM 2005, Practical handbook of environmental site characterization and ground water monitoring, Taylor & Francs, CRC Press NSW EPA 1999, Guidelines on significant risk of harm from contaminated land and the duty to report, NSW Envronment Protecton Authorty Pankow JF & Cherry JA 1996, Dense chlorinated solvents and other DNAPLs in groundwater: history, behaviour and remediation, Waterloo Press, Portland, Oregon, USA PASCALIS 2002, Sampling manual for the assessment of regional groundwater biodiversity, F Malard (chef edtor), European Project: Protocols for the Assessment and Conservaton of Aquatc Lfe n the Subsurface Schwartz FW and Zhang H 2002, Fundamentals of ground water, John Wley & Sons Standards Australa 1996, Alkali aggregate reaction Guidelines on minimising the risk of damage to concrete structures in Australia, document reference number HB-79 1996 State of Calforna 1998, Guidelines for groundwater investigation reports, Board for Geologsts and Geophyscsts, Sacramento, Calforna Todd, DK and Mays, LW 2004, Groundwater hydrology, John Wley & Sons. UK Envronment Agency 2002, Guidance on the use of permeable reactive barriers for remediating contaminated groundwater UK Envronment Agency 2001, Benchmarking and guidance on the comparison of selected groundwater risk-assessment models, NGWCLC Report NC/00/14 UK Envronment Agency 2001, Guidance to good practice for the development of conceptual models and the selection and application of mathematical models of contaminant transport processes in the subsurface, NGWCLC Report NC/99/38/2

41

US Army Corps of Engneers 1997, In-situ air sparging USEPA 2004, Users guide for evaluating subsurface vapor intrusion into buildings USEPA 2002, Handbook on groundwater protection and clean up policies for RCRA corrective action, EPA/530/R-01/015 USEPA 2002, Draft guidance for evaluating the vapor intrusion to indoor air pathway from groundwater and soils (subsurface vapor intrusion guidance) USEPA 2002. Handbook of groundwater protection and cleanup policies for RCRA corrective action, EPA/530/R-01/015 USEPA 2002, Groundwater sampling guidelines for Superfund and RCRA project managers, EPA 543-S-02-001 USEPA 2001, The state of the practice of characterization and remediation of contaminated groundwater at fractured rock sites, EPA 542-R-01-010 USEPA 1998, Technical protocol for evaluating natural attenuation of chlorinated solvents in ground water, EPA/600/R098/128 USEPA 1997, Design guidelines for conventional pump and treat systems, EPA/540/S-97/504 USEPA 1996, Low-flow (minimal drawdown) ground-water sampling procedures, EPA/540/S-95/504 USEPA 1996, Hydrogeologic characterization of fractured rock formations: a guide for groundwater remediators, EPA/600/S-96/001 USEPA 1996, Pump and treat groundwater remediation A guide for decision makers and practitioners, EPA/625/R-95/005 USEPA 1995, Light nonaqueous phase liquids, EPA/540/S-95/500 USEPA 1993, Suggested operating procedures for aquifer pumping tests, EPA/540/S-93/503 USEPA 1992, General methods for remedial operation performance evaluations, EPA/600/R-92//002 USEPA 1992, Statistical analysis of groundwater monitoring data at RCRA facilities addendum to interim final guidance USEPA 1992, Fundamentals of groundwater modelling, EPA/540/92/005 USEPA 1991, Dense nonaqueous phase liquids, EPA/540-4-91-002

42

USEPA 1989, Statistical analysis of groundwater monitoring data at RCRA facilities interim final guidance Water Technology Internatonal Corp 1997, Site remediation technologies: a reference manual, Contamnated Stes Management Workng Group, Burlngton, Ontaro, USA Wedemeer TH, Rfa HS, Newell CJ and Wlson JT 1999, Natural attenuation of fuels and chlorinated solvents in the subsurface, John Wley & Sons Inc

Appendices
Appendix I: Glossary
Aquifer: a geologcal unt capable of storng and transmttng useful quanttes of groundwater. Contamination of groundwater: defined n 1.5 of these gudelnes. Ecological health: the ablty of an ecosystem to support and mantan key ecologcal processes and organsms so ther speces compostons, dversty and functonal organsatons are as smlar as possble to those occurrng n natural habtats wthn a regon. Ecosystem: a communty of organsms plus the physcal and chemcal envronment n whch they lve and nterrelate. Environmental health: aspects of human health and dsease that are determned by factors n the envronment. Environmental values: partcular values or uses of the envronment that are mportant for a healthy ecosystem or for publc benefit, welfare, safety or health, whch requre protecton from the effects of polluton, waste dscharges and deposts. Exposure: contact of a physcal, chemcal, or bologcal agent wth the outer boundary of an organsm, e.g. through nhalaton, ngeston, or dermal contact. Exposure pathway: physcal course a chemcal or pollutant takes from ts source to the exposed organsm. Groundwater: all waters occurrng below the land surface. Groundwater investigation level (GIL): the concentraton of a groundwater parameter at whch further nvestgaton (pont of extracton) or response (pont of use) s requred. Includes both
43

ANZECC & ARMCANZ 2000a and NHMRC & NRMMC 2004 crtera, and ste-specfic crtera. Harm: n relaton to contamnated land, harm to human health or the envronment (ncludng any drect or ndrect alteraton of the envronment that degrades the envronment), whether n, on or under the land or elsewhere. Hazard: the capacty of an agent to produce a partcular type of adverse health or envronmental effect. Hyporheic ecosystem: ecosystems that exst n alluval sedments, commonly lnked to the base flows of rvers and streams. Natural background concentration: the naturally occurrng ambent concentraton of a substance n groundwater n the local area of a ste. Plume: a volume of groundwater contanng dssolved-phase contamnants, extendng from the source of contamnaton. Point source: a source of contamnaton whch comes from a contamnatng actvty at a partcular ste. Receptor: the entty that may be adversely affected by a contamnant. Remediation: all measures taken to mtgate rsks from contamnaton. Risk: the probablty n a certan tmeframe that an adverse outcome wll occur n a person, a group, or an ecologcal system that s exposed to a partcular dose or concentraton of a hazardous agent.

Appendix 2: Identifying environmental values


For assessng potental rsks from groundwater contamnaton, all envronmental values of the groundwater need to be dentfied. The prncple of basng decsons about water qualty on envronmental values s outlned n the Environmental objectives for water quality and river flow (NSW Government 2006), whch have been developed for 31 surface water catchments across the state. Note that the term envronmental values ncludes consderaton of human as well as ecologcal health, and ncorporates values assocated wth what are commonly termed the benefical uses of groundwater. Typcally, groundwater qualty at a partcular ste may protect some or all of the followng envronmental values, dependng on the locaton of the contamnated ste:
44

Aquatic ecosystems: these nclude surface water ecosystems and groundwater ecosystems. Human uses: these nclude but are not lmted to potable water supply, agrcultural water supply (rrgaton and stock waterng), ndustral water use, aquaculture and human consumpton of aquatc foods, recreatonal use (prmary and secondary contact wth surface waters) and vsual amenty of surface waters. Human health in non-use scenarios: ths ncludes consderaton of health rsks that may arse wthout drect contact between humans and the groundwater, for example, exposure to volatle contamnants above groundwater contamnant plumes. Buildings and structures: ths ncludes protecton from groundwater contamnants that can degrade buldng materals through contact, for example, the weakenng of buldng footngs resultng from chemcally aggressve groundwater.

Cultural and sprtual values that are assocated wth the envronment, ncludng groundwater, should also be protected. Cultural and sprtual values may nclude sprtual relatonshps, sacred stes, customary uses, the plants and anmals assocated wth the water, drnkng water supples and recreatonal actvtes. In managng groundwater contamnaton, t s generally consdered that cultural and sprtual values wll be protected where groundwater qualty protects all other relevant envronmental values on a ste. In dentfyng applcable envronmental values for groundwater on a partcular ste, the followng matters must be consdered. Water sharing plans for groundwater resources Water sharng plans (WSPs) and macro plans for groundwater resources are beng developed for aqufers across NSW. These plans are statutory nstruments created under the Water Management Act 2000 wth the prmary am of establshng management rules for the extracton of groundwater and provson of envronmental water. Although focused manly on groundwater extracton, water sharng plans and macro plans also provde an addtonal source of nformaton to dentfy benefical uses or envronmental values of groundwater. These plans are avalable at www.naturalresources. nsw.gov.au/water/plans.shtml. Note that DEC regards aquatc ecosystems and drnkng water as default envronmental values n all

45

prelmnary assessments of groundwater contamnaton, ncludng where these values are not dentfied n water sharng plans. Protecting aquatic ecosystems Many aquatc ecosystems are partally or wholly dependent on nteractons wth groundwater to sustan ecologcal structure and functon. Aquatc ecosystems nclude, but are not lmted to, sprngs, wetlands, karst and cave systems, and rvers and estuares wth a strong base flow component, especally n the dry season. Also, groundwater, whle t supples water for rvers, wetlands and other ecosystems, may tself form part of a crtcal aquatc ecosystem. It has become ncreasngly obvous that organsms n groundwater contrbute sgnficantly to bodversty, and are also mportant for the self-purficaton processes n groundwater. General background nformaton about groundwater ecosystems s avalable n the References secton, for example, Danelopol et al 2003 and Hancock et al 2005. In NSW, lttle s known about groundwater organsms and ther senstvty to pollutants. Hyporhec systems (those present n groundwater wthn alluval sedments lnked to the base flow of streams) are better known, and research suggests they play a key role n cyclng organc matter and processng pollutants. Where organsms n groundwater that requre protecton have been dentfied, for nstance, by DNR n the process of dentfyng prorty groundwater dependent ecosystems (GDEs), management of the contamnaton should am to restore groundwater qualty as much as practcable to ts natural background state n the shortest tme practcable, and prevent further groundwater polluton. The local DNR office should be contacted for nformaton about GDEs. Whle t s vtal to protect all known GDEs, ecosystems that have not been specfically dentfied by DNR also requre protecton from contamnaton. Therefore, n the prelmnary assessment of groundwater contamnaton, t must be assumed that aquatc ecosystem protecton s an applcable envronmental value of groundwater. A subsequent, more detaled assessment of groundwater contamnaton may, however, demonstrate that ths envronmental value does not apply. Determining whether groundwater is a potential drinking water supply Because of basc landholder use rghts, the prelmnary assessment of groundwater contamnaton must assume that drnkng water s
46

an applcable envronmental value of the groundwater, although subsequent more detaled assessment may show that ths value does not apply at the ste. For the detaled assessment, there are three key steps n determnng whether drnkng water supply s a relevant envronmental value at a ste: checkng DNRs lst of major aqufers of drnkng water qualty dentfyng actual groundwater users n the ste vcnty referrng to total dssolved solds (TDS) as an ndcator parameter.

DNR has developed a lst of major aqufers of drnkng water qualty, whch s ncluded n Appendx 2.1. DNR has ndcated that these major NSW aqufers must be protected for drnkng water supply at the tme of these gudelnes beng publshed. Ths lst may be updated. DNR should be consulted durng an assessment of groundwater contamnaton about an aqufer that does not appear on ths lst. Ths lst and updated versons of t should also be consulted as part of the groundwater assessment to determne whether drnkng water use has already been specfied by DNR for a partcular aqufer. The lst s a useful screenng tool to find out whether drnkng water s a relevant envronmental value, although t s not an exhaustve lst of all groundwaters n NSW whch requre protecton to that level. If the groundwater under consderaton s not lsted, the ste nvestgator needs to determne whether t should be consdered as a drnkng water supply. Ths determnaton would need to take nto account the current uses of groundwater n the local area. If n the process of ste nvestgatons, the ste nvestgator obtans addtonal water qualty nformaton at a specfic locaton that may supersede DNR nformaton, DNR should be contacted for confirmaton. If nether of the first two steps dentfies groundwater as a potental drnkng water supply, the ste nvestgator should use an ndcator parameter, namely total dssolved solds (TDS), to reach a concluson. To do ths, the ste nvestgator should first determne the TDS concentraton of groundwater samples obtaned at the ste. Groundwater wth TDS concentratons below 2000 mg/L s sutable for potental drnkng water supply, and hence should be afforded ths level of protecton from contamnaton unless other stespecfic factors, such as low yeld, render such use unlkely. A TDS concentraton of 2000 mg/L has been selected as the level above
47

whch groundwater s unlkely to be acceptable as drnkng water because of taste. Whle t s acknowledged that, based on the Australan drnkng water gudelnes (NHMRC & NRMMC 2004), the TDS content n drnkng water should not exceed 500 mg/L because of taste consderatons, the World Health Organsaton (WHO) states that there s an enormous varaton n the taste that s regarded as acceptable by dfferent ndvduals and communtes. In addton, there s sgnficant varaton between ndvduals n ther ablty to detect tastes n drnkng water. WHO ndcates that TDS concentratons above 1000 mg/L may gve rse to consumer complants. Ths suggests that some ndvduals wll accept water wth a TDS hgher than 1000 mg/L for drnkng. Further, n some cases hgher TDS water may be dluted before drnkng. Therefore, a filter TDS concentraton of 2000 mg/L should be used n NSW to confidently rule out the use of groundwater as a lkely drnkng water supply. If aqufers wth a TDS concentraton of less than 2000 mg/L are or could be affected by contamnaton (e.g. due to contamnaton n perched groundwater n low permeablty sedments overlyng a hgher permeablty aqufer), relevant nformaton should be provded to DNR and DEC pror to dscountng drnkng water as an applcable envronmental value. TDS s not an approprate filter for consderng the relevance of envronmental values other than drnkng water supply. Determining the relevance of other environmental values People use groundwater for a varety of purposes. The relevance of these envronmental values needs to be consdered on a ste-specfic bass. Informaton on current or proposed extracton of groundwater, such as for agrcultural or ndustral use, may be obtaned by searchng for lcensed groundwater extractors n the area, and seekng other advce from DNR. The potental presence of yet undentfied extractors also needs to be consdered. Basc landholder use rghts need to be consdered when dentfyng the envronmental values that requre protecton from contamnaton. These rghts mean that n NSW water, ncludng groundwater, may be able to be used for domestc consumpton (ncludng drnkng water) and stock water purposes as well as for uses consstent wth natve ttle rghts wthout requrng the approval of DNR. Note, however, that lcensng requrements apply to the
48

constructon of groundwater bores rrespectve of the requrements to approve groundwater use. It should always be assumed that groundwater s dschargng to dentfied surface water bodes and, therefore, all envronmental values of the surface water such as recreatonal uses, vsual amenty and aquaculture operatons, requre consderaton unless the local hydrogeology has been fully charactersed and groundwater dscharge s unlkely to occur. Allowance should be made n such cases for any possble alteraton to groundwater flow (e.g. due to dfferng clmatc condtons). Where groundwater dscharges to surface waters, the communty n 31 catchments across NSW has agreed to envronmental values for surface waters known as water qualty objectves (WQOs). These have been endorsed by the NSW government and are avalable on www.envronment.nsw.gov.au/eo. The ANZECC & ARMCANZ 2000a gudelnes are used to establsh the numercal default crtera (trgger values) supportng the envronmental values establshed by the WQOs. In dentfyng envronmental values, t must be recognsed that nformaton about aqufer yeld, groundwater qualty and benefical uses whch s vald regonally may not necessarly be vald locally. For nstance, whle a rock formaton may have generally low yeld whch may not sustan certan benefical uses, locally the yeld may be sufficent to sustan these uses. Groundwater uses consstent wth basc landholder rghts do not requre sgnficant yeld. Moreover, the lack of a sufficent yeld n the context of specfic uses s not enough to dsregard such uses n groundwater or surface water systems, ncludng wetlands, rvers, or creeks, that are hydraulcally connected to the groundwater that s beng assessed. For nstance, contamnated groundwater n a low yeldng formaton may leak nto an underlyng aqufer that s extracted for human use, or may dscharge to surface water that supports aquatc and benthc lfe, recreaton or a drnkng water supply. The concept of envronmental values of groundwater extends to consderng the potental mpact of contamnaton on meda other than water and sedments. It s, therefore, mportant that all relevant exposure pathways are carefully consdered n determnng the relevant envronmental values of groundwater. Also, concrete structures, such as buldng footngs, may need to be consdered as these can be susceptble n some crcumstances to corroson by
49

partcular types of groundwater contamnaton, partcularly sulphur compounds and acdty. Secton 6 lsts several publcatons that may be useful n assessng rsks to buldng materals under Further readng. Indoor ar qualty s another mportant envronmental value of groundwater qualty whch can be affected when groundwater s contamnated wth volatle chemcals, for nstance, beneath or near a buldng. Rsks from nhalng volatle contamnants from groundwater have receved sgnficant attenton over recent years, partcularly n the USA where techncal gudelnes have been developed by state and federal agences. Assessng nhalaton rsks assocated wth contamnated groundwater s complex, and a relevant techncal dscusson s beyond the scope of ths document. In general, however, a weght of evdence approach should be used takng nto account relevant nformaton, whch may nclude geology, sol mosture, depth to groundwater, water table fluctuatons, buldng detals, solgas measurements, flux hood measurements, ndoor ar qualty, spatal and temporal varatons n contamnant mass flux estmates and other factors. Secton 6 lsts some documents assessng rsks from volatle contamnants from contamnated groundwater under Suggested further readng.

2.1 Major aqufers of drnkng water qualty


DNR has deemed the aqufers below to be actual or potental drnkng water supples and to requre protecton of groundwater to ths level:
50

Araluen alluvum and weathered grante Clarence-Morton Basn (except the Grafton Formaton) coastal alluvum (part only) Cudgegong Valley alluvum Great Artesan Basn ntake beds Hunter alluvum and trbutares Lachlan Fold Belt Provnce (part only, e.g. lmestones) Lower Gwydr alluvum Lower Lachlan alluvum Lower Macquare alluvum Lower Murrumbdgee alluvum Lower Murray alluvum

Lower Namo alluvum Mangrove Mountan sandstone Maroota tertary sands md Murrumbdgee alluvum and trbutares mscellaneous coastal sand beds mscellaneous trbutares of Namo (alluvum) New England fold belt provnce (part only e.g. grantes and basalts) Orange basalt Oxley Basn Peel Rver alluvum Tomago/Stockton/Tomaree sand beds Trassc sandstones n the Sydney Basn Upper Lachlan alluvum and trbutares Upper Macquare alluvum and trbutares Upper Murray alluvum Upper Namo alluvum Young grante.

Where a groundwater contamnant plume s dentfied wthn one of these aqufers the remedaton target should at least meet the water qualty crtera n the Australian drinking water guidelines (NHMRC & NRMMC 2004). If t s consdered that the desgnaton as drnkng water supply s not approprate at a partcular ste above one of these aqufers, t s possble to seek confirmaton of ths concluson from DNRs regonal hydrogeologst. The proponent should make avalable to DNR sufficent evdence of the groundwater qualty to support ther concluson.

Apppendix 3: Monitored natural attenuation


Natural attenuaton of contamnated groundwater s defined as: The effect of naturally occurrng physcal, chemcal and bologcal processes to reduce the load, concentraton, flux or toxcty of pollutng substances n groundwater (UK Envronment Agency 2000).
51

These processes nclude bodegradaton, dsperson, dffuson, sorpton, volatlsaton, and chemcal or bologcal stablsaton, transformaton or destructon. Although natural attenuaton s sometmes referred to as ntrnsc boremedaton, non-bologcal processes may also be mportant. The term montored natural attenuaton or MNA refers to relance on natural attenuaton processes as part of a planned, controlled and montored remedal approach to acheve ste-specfic remedaton objectves wthn a tmeframe that s reasonable compared to that offered by other more actve methods. It emphasses that montorng to demonstrate and document the progress of MNA must be an ntegral part of a natural attenuaton strategy for any ste. Natural attenuaton may reduce the potental rsk posed by ste contamnants, for nstance through: reducng toxcty due to transformaton of contamnant(s) through destructve processes such as bodegradaton or abotc chemcal transformatons. Note that contamnant transformaton wll not always reduce the rsk. Some contamnants, for example, some chlornated organc compounds, may transform to more toxc contamnants as they degrade n the envronment. A proposal for MNA must therefore evaluate the mpacts of all degradaton pathways and ther effect on the sutablty of MNA at a ste. reducng contamnant moblty and boavalablty through sorpton nto the sol or rock matrx reducng dssolved contamnant concentratons and subsequently reducng potental exposure concentratons.

Note that dluton wthn a receptor, such as a surface water body or groundwater abstracton system, s not consdered to be natural attenuaton. Research over the last 20 years has resulted n a sound techncal understandng of natural attenuaton processes for many groundwater contamnants and knowledge of the specfic condtons under whch contamnants may be degraded. On ths bass, MNA s accepted as one remedal strategy that should be consdered when evaluatng clean-up optons for stes where groundwater s contamnated. MNA may be partcularly useful n areas of a plume where contamnant concentratons are low. Based on ths, MNA may often be appled where more aggressve clean-up has already reduced contamnant concentratons n the core of the plume.

52

Advantages of MNA Used alone or n combnaton wth other strateges, such as secondary source removal, MNA may be a non-ntrusve, safe and cost-effectve strategy to remedate groundwater contamnaton. In some crcumstances, t may be the only practcable strategy that can be used. Disadvantages of MNA There may not be the necessary envronmental condtons for effectve natural attenuaton of a partcular contamnant at the locaton of concern. Natural processes may work slowly n the subsurface envronment, where reacton rates may be restrcted by low temperatures and lmted avalablty of the necessary mcroorgansms, electron acceptors or electron donors, cometaboltes and nutrents. Natural attenuaton may not acheve remedaton goals wthn adequate tmeframes n those cases. Sometmes nterventon or enhancement may change the condtons to allow natural processes to work more effectvely, but n other cases ths wll not be possble, and MNA must be dscounted as an opton. Also, sometmes the concentraton of a contamnant s so great, or the rsks to human or ecologcal health so severe, that other strateges wth a shorter effectve tmeframe must be used. Demonstrating whether MNA is applicable To decde whether remedaton by montored natural attenuaton s approprate for a partcular ste (relatve to ste-specfic remedal goals), professonals should: characterse the ste assess potental rsks ensure there s prmary and secondary source removal or control evaluate potental effectveness.

Remedaton by natural attenuaton requres demonstratng progress towards attanng the remedal goals. Ths s acheved by usng convergng lnes of evdence, whch are obtaned through montorng and evaluatng the resultng data. Montorng should contnue untl the remedal goals have been met. Prmary evdence that remedaton by natural attenuaton s workng s seen when there s a reducton n the lateral and vertcal extent of the plume, and reductons n concentratons of the contamnants of concern wthn the plume.
53

Secondary evdence s provded by geochemcal ndcators of naturally occurrng degradaton and estmates of attenuaton rates. Addtonal optonal lnes of evdence can be provded by mcrobologcal nformaton, ncludng field and laboratory mcrocosm studes, where ths nformaton drectly demonstrates the occurrence of a partcular bodegradaton process at a ste. Further analyss of prmary and secondary lnes of evdence may also be requred usng, for example, solute transport modellng or estmates of assmlatve capacty. Any applcaton of MNA at a ste requres extensve hydrogeologcal and geochemcal ste charactersaton, whch may often need to be supported by approprate modellng. It s not sufficent to smply ndcate that, for example, groundwater condtons beneath the ste are beng reduced, and therefore reductve dechlornaton of chlornated alphatc hydrocarbons wll occur. When is MNA appropriate? Generally, montored natural attenuaton should only be consdered as a remedaton methodology where the followng condtons are met: the source of the contamnaton, ncludng contamnaton hot spots, have been removed as much as practcable the three-dmensonal extent of the contamnaton has been defined the ste and hydrogeology have been adequately charactersed and there s clear evdence that attenuaton rates are sufficent to acheve the remedal goals wthn an adequate tmeframe the natural attenuaton processes nclude those whch reduce the mass of dssolved contamnants the effects of degradaton have been consdered.

As wth other remedal approaches, t s expected that where montored natural attenuaton s proposed as part of a remedal strategy for a ste, ts feasblty and approprateness would be demonstrated n a remedal acton plan (RAP). The RAP should draw on ste charactersaton and rsk assessment data acqured durng prevous nvestgaton of the ste. Wthn the RAP, the proponent should: demonstrate an understandng of the partcular attenuaton processes relevant to the contamnant(s) of concern under the condtons at that ste

54

define remedal goals and set out the scope, frequency and expected duraton of the montorng requred to demonstrate that natural attenuaton has been effectve and the goals have been met define montorng frequency, whch should be sufficent to allow the progress of natural attenuaton to be tracked, and to provde early warnng f expectatons are not beng met, or f adverse mpacts on senstve receptors become possble address the ntegraton of MNA wth other remedal technologes that may be proposed for source removal or reducton, and any potental nteractons or nterferences.

The long-term sustanablty of MNA durng and followng any proposed redevelopment of the ste must be consdered. Where reference s made to experence from other stes, an understandng of the potental mpacts of dfferences n, for nstance, hydrogeologcal condtons between the stes must be demonstrated. The RAP and ongong montorng and valdaton reports should set out the lnes of evdence for the progress and success of natural attenuaton. Unless the prmary lne of evdence s conclusve, t wll be necessary to evaluate secondary and addtonal lnes of evdence. A checklst has been provded on the next page to assst n undertakng a revew of the sutablty of MNA at a partcular ste. Considering the effect of contaminant degradation on toxicity and mobility Some contamnants degrade and become more toxc. Vnyl chlorde, from the reductve dechlornaton of trchloroethene (TCE), s a well-known example. Therefore, the potental effects of degradaton products on the toxcty and moblty of the contamnaton need to be carefully consdered when evaluatng the approprateness of MNA. In some cases, and n the rght hydrogeologcal condtons, the more toxc degradaton products may break down further to form less toxc compounds. In such nstances, MNA may be deemed acceptable f t can be demonstrated that the more toxc compounds wll not represent a threat to human or ecologcal health.

55

Checklist for assessing the applicability of monitored natural attenuation

q q

Has the ste been adequately charactersed n relaton to stratgraphy, lthology, structure, water-bearng zones, groundwater flows, solute transport, lateral and vertcal hydraulc gradents, hydraulc conductvtes and porostes? Has the ste been adequately charactersed n relaton to geochemcal condtons, ncludng salnty, temperature, pH, redox potental, organc carbon sources, nutrent avalablty, sorpton capacty and the avalablty of electron donors and acceptors? Have all contamnants of potental concern been dentfied? Has the toxcty of the contamnants of concern been adequately assessed? Has the plume been fully delneated for all contamnants of concern? Have all potental receptors been dentfied? Have all potental benefical uses and envronmental values of the groundwater been dentfied? Are proposals to remove or control prmary sources (e.g. leakng nfrastructure) and secondary sources (e.g. resdual NAPL, adsorbed phase) adequate and feasble? Is the proposed attenuaton mechansm feasble for all the contamnants of concern under the condtons prevalng at the ste? Do the natural attenuaton processes nclude processes that reduce the dssolved mass of the contamnants of concern? Are there condton conflcts among multple contamnants of concern? Have the toxcty and fate of all potental degradaton products been consdered? Wll attenuaton to acceptable concentratons be acheved well before potental human or ecologcal receptors could be mpacted on? Have all feasble alternatve remedal optons been consdered?

q q q q q q q q q q q q
56

q q q q

Wll the remedaton goals be reached wthn a tmeframe that s reasonable compared wth other remedal optons, and communty expectatons? Is montored natural attenuaton sustanable, consderng proposed source control measures and redevelopment of the ste and surroundng area? Are there financal mechansms n place to ensure that montorng can be contnued for the requred perod? Have adequate contngency measures been proposed?

Appendix 4: Contacting NSW government departments for advice on groundwater contamination


These gudelnes refer to the need to contact one or more government departments throughout the course of groundwater contamnaton assessment and management. The proponent wll need to collate and present a varety of nformaton to the relevant department to assst t n provdng advce or reachng agreement on proposed management strateges. The contact detals are summarsed below. Department of Envronment and Conservaton (DEC) Manager Contamnated Stes 5961 Goulburn Street, Sydney NSW 2000 PO Box A290, Sydney South 1232 Telephone: (02) 9995 5000 (swtchboard) Telephone: 131 555 (NSW only) www.envronment.nsw.gov.au Department of Natural Resources (DNR) For advce on benefical uses of groundwater, contact the regonal hydrogeologst. For hydrogeologcal nformaton, vst www.nratlas.nsw.gov.au. Contact detals for DNRs regonal offices are avalable at: www.DNR.nsw.gov.au/aboutus/contactus.shtml. NSW Health Area Health Servce Publc Health Unt Contact detals for regonal Publc Health Unts are avalable at: www.health.nsw.gov.au/publc-health/phus/phus.html or n the Busness Secton of the Whte Pages.

57

You might also like