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COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 2015 21 October 2015 The National Remediation Framework – towards harmonisation

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Page 1: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT

Kerry Scott

CRC CARE

ACLCA 2015 21 October 2015

The National Remediation Framework– towards harmonisation

Page 2: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

Presentation outline

• Drivers for remediation and management guidelines

• Harmonisation

• National Remediation Framework

• NRF construction, consultation and adoption

Page 3: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

DriversSustainable development and remediation

Urban infill development/urban renewal/urbanisation– cities

• population pressures• 60-80% of contaminated sites

– legacy sites• petroleum / manufacturing / landfill / railway

– economic, social and environmental benefits

De-industrialisation – future sites– eg oil refineries, manufacturing plants

Community awareness– increasing accountability for industry and regulators

Improved efficiency and effectiveness

Page 4: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

A national approach to remediation

Land management and environmental protection– a state responsibility– each State has their own approach to remediation– >30 state regulatory/guidance instruments (6 States)

Assessment of contamination– harmonised national approach

• National Environment Protection Measure [updated 2013]• cannot legally be extended to remediation

Remediation and management of contamination– State regulators suggested

• a national remediation framework• NRF to complement the NEPM• CRC CARE to develop

Page 5: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation Framework

Purpose– establish a nationally consistent approach to contaminated site

remediation and management

Expected outcomes – facilitation of– protection of human health and the environment– effective and efficient remediation– net community benefit– seamless linkages with the NEPM

across jurisdictions– transfer of best practice– workforce - mutual recognition of skills– common ‘remediation language’

Page 6: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkDevelopment

Guidance

– practical outcomes based – “how to …, when to…”– modular/flexible - individual elements may be updated over time– compatibility

• NRF principles• related requirements in the NEPM• will not impinge on the policy and decision-making prerogatives of

jurisdictions

Harmonisation– build on current guidance and practice

– develop new guidance where appropriate

NRF Steering Group

– strategic direction and oversight

Page 7: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkNRF Steering Group - membership

Site owners

– petroleum

– mining

– Defence

Industry (remediation)

– Australasian Land and Groundwater Association (ALGA)

– Australian Contaminated Land Consultants Association (ACLCA)

Government

– States and Territories

– Commonwealth (Finance, Environment)

– planning, health

Community

Related sectors

– construction

Page 8: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSchematic

PHILOSOPHY

CONTEXT

BackgroundJurisdictional arrangements

Legislative powers

Purpose of framework

Intended audience

PRINCIPLES

Precautionary Prevention Risk management

Options hierarchy SustainabilityNational / international

obligations

PRACTICE

GUIDANCE

Remediation (action) plan Development

Remediation (action) plan Implementation

Post–remediation

Regulatory requirements Health and safety Remediation validation and closure

Site specific remediation objectives Stakeholder engagement Long-term monitoring

Identifying remedial options Documentation and record-keeping Auditing/third party review

Selection of remedial technologies

 

Institutional controls

Treatability studies  

Cost-benefit analysis  

Page 9: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkBackground/context - completed

– Frameworks review [www.crccare.com]

– Context and philosophy [www.crccare.com]

– Guidance mapping [www.crccare.com]

http://www.crccare.com/knowledge-sharing/national-remediation-framework

Page 10: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkPrinciples

Precautionary– careful evaluation to avoid, wherever practicable, serious or irreversible

damage to the environment – an assessment of the risk-weighted consequences of various options

Prevention– avoid future contamination

Risk based– human health and/or environmental risks commensurate with site use– underpins Australian environmental management

Options hierarchy– treatment on-site, then off-site– containment on-site, then off-site (landfill)

Page 11: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

Sustainable development and sustainability

Sustainability– IGAE/NSESD– state environmental protection legislation - objects clauses– 2013 NEPM update

Integration/balancing environmental, economic and social aspects– application at the project scale– optimise footprint [environmental, economic, social]

Approaches– sustainable remediation [SuRF] /green [USEPA] /sustainability [NRF]– NRF

“... an integrated assessment of the environmental, economic, and social impacts of remedial activities, which meets the needs of the present without compromising the ability of future generations to meet their own needs”

Page 12: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSchematic

PHILOSOPHY

CONTEXT

BackgroundJurisdictional arrangements

Legislative powers

Purpose of framework

Intended audience

PRINCIPLES

Precautionary Prevention Risk management

Options hierarchy SustainabilityNational / international

obligations

PRACTICE

GUIDANCE

Remediation (action) plan Development

Remediation (action) plan Implementation

Post–remediation

Regulatory considerations Health and safety Remediation validation and closure

Site specific remediation objectives Stakeholder engagement Long-term monitoring

Identifying remedial options Documentation and record-keeping Auditing/third party review

Selection of remedial technologies

 

Institutional controls

Treatability studies  

Cost-benefit and sustainability analysis  

Page 13: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSpecific guidelines

Site-specific remediation objectives

Conceptual site model (from site assessment)

Risk based approach– environmental values/beneficial uses– proposed land use– residual contamination

• intergenerational equity• institutional controls• liability/financial assurance

Small sites– default values (health investigation levels??)

Page 14: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSpecific guidelines

Identifying remedial options

Selection of remedial technologies

Treatability studies

Soils Groundwater Vapour• Cover and cap• Containment• Stabilisation/solidification/

fixation• Bio-remediation/ORC

/phyto-remediation• Washing/physical

separation• Thermal desorption

• Air sparging/injection/vapour extraction

• ISCO/CISCO• Skimmers• Monitored natural attenuation• Barrier systems/ permeable

reactive barriers/cut-off wall• Funnel gate• Pump and treat

• Soil vapour [vapour extraction/ carbon canisters/ venting]

Page 15: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSpecific guidelines

Cost-benefit and sustainability analysis– assist decision makers in selecting remediation strategy and technology

– taking into account• existing CBA guidance – Commonwealth, States• magnitude and duration of remediation projects• tiered approach

– sustainability parameters - similarities with SURF-UK indicators• parameters – monetised; quantified; qualitative• choice and weighting of parameters (in conjunction with regulator)• sensitivity analysis

– Excel spreadsheet based tool

Page 16: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSchematic

PHILOSOPHY

CONTEXT

BackgroundJurisdictional arrangements

Legislative powers

Purpose of framework

Intended audience

PRINCIPLES

Precautionary Prevention Risk management

Options hierarchy SustainabilityNational / international

obligations

PRACTICE

GUIDANCE

Remediation (action) plan Development

Remediation (action) plan Implementation

Post–remediation

Regulatory considerations Health and safety Remediation validation and closure

Site specific remediation objectives Stakeholder engagement Long-term monitoring

Identifying remedial options Documentation and record-keeping Auditing/third party review

Selection of remedial technologies

 

Institutional controls

Treatability studies  

Cost-benefit and sustainability analysis  

Page 17: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSpecific draft guidelines

Health and safety– previous NEPM included information on WHS during assessment

– current NEPM does not

– this draft guideline• based on harmonised national model work health and safety laws• utilises information from previous NEPM

Stakeholder engagement– NEPM includes stakeholder engagement during assessment

– this draft guideline: develop a stakeholder engagement plan

Documentation, record keeping and reporting– focuses on the types of information required by jurisdictions, not processes

Page 18: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSchematic

PHILOSOPHY

CONTEXT

BackgroundJurisdictional arrangements

Legislative powers

Purpose of framework

Intended audience

PRINCIPLES

Precautionary Prevention Risk management

Options hierarchy SustainabilityNational / international

obligations

PRACTICE

GUIDANCE

Remediation (action) plan Development

Remediation (action) plan Implementation

Post–remediation

Regulatory considerations Health and safety Remediation validation and closure

Site specific remediation objectives Stakeholder engagement Long-term monitoring

Identifying remedial options Documentation and record-keeping Auditing/third party review

Selection of remedial technologies

 

Institutional controls

Treatability studies  

Cost-benefit and sustainability analysis  

Page 19: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSpecific draft guidelines

Post-remedial validation and closure

Auditing

Institutional controls

Long term monitoring

– harmonise processes and requirements across jurisdictions, where possible

– highlight issues to be considered, if adopting management methods

– in preparation

Page 20: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkConsultation

Draft guidelines– NRFSG endorses release for consultation

Consultation

with Government– with advice from NRFSG government members

with Industry/Practitioners– with advice from NRFSG industry members– from ALGA and ACLCA– Policy Advisory Committee– www.crccare.com [password from ALGA and ACLCA]

with Public– developing community forum– www.crccare.com– Remediation Australasia

Page 21: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkConsultation status

Background/foundation work– frameworks review– context and philosophy [www.crccare.com]– guidance mapping

Draft guideline development as at September 2015– Health and safety – Stakeholder engagement [www.crccare.com ] – Documentation and record keeping

– Identifying remedial options– Selection of remedial technologies– Treatability studies in preparation– Cost benefit and sustainability analysis– Remediation objectives– Post-remedial guidance

http://www.crccare.com/knowledge-sharing/national-remediation-framework

Page 22: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkRefinement

Refinement of draft guidelines through – review in relation to other draft guidelines

• to ensure appropriate links between them• that they provide a complete approach, with no gaps• to determine whether further guidance is required

– review in relation to NEPM

– further consultation on complete package

Update of Framework and constituent guidelines – future updates on an as-needs basis– incorporation of other guidance eg flux

Page 23: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkAdoption

The “path to adoption” of the Framework depends on – credible expertise

– involvement of stakeholders• directly (through Steering Group)• through consultation on draft guidelines

– intersection with Governments• through Steering Group membership• Heads of EPAs

Acceptance and adoption – under the umbrella of Heads of EPAs

Page 24: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkInformation

– information paper for Heads of EPAs

– information paper for industry at www.crccare.com

– Technical Reports at www.crccare.com

– stakeholder representatives on the NRF Steering Group

– conferences – e.g. CleanUp 2015

– webinars

– industry briefings – e.g. Master Builders Assn, ACLCA

– www.crccare.com

Page 25: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkSchematic

PHILOSOPHY

CONTEXT

BackgroundJurisdictional arrangements

Legislative powers

Purpose of framework

Intended audience

PRINCIPLES

Precautionary Prevention Risk management

Options hierarchy SustainabilityNational / international

obligations

PRACTICE

GUIDANCE

Remediation (action) plan Development

Remediation (action) plan Implementation

Post–remediation

Regulatory considerations Health and safety Remediation validation and closure

Site specific remediation objectives Stakeholder engagement Long-term monitoring

Identifying remedial options Documentation and record-keeping Auditing/third party review

Selection of remedial technologies

 

Institutional controls

Treatability studies  

Cost-benefit and sustainability analysis  

Page 26: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

National Remediation FrameworkImplications

The National Remediation Framework is expected to

– provide a structure for thinking through remedial strategies

– systematise practices currently being applied to many sites

– provide more rigorous approach for considering issues

– reduce risk of adoption of poor strategic options

– provide seamless linkages with the NEPM and current state legislation

– provide a more sustainable approach to remediation and management

http://www.crccare.com/knowledge-sharing/national-remediation-framework

Page 27: COOPERATIVE RESEARCH CENTRE FOR CONTAMINATION ASSESSMENT AND REMEDIATION OF THE ENVIRONMENT Kerry Scott CRC CARE ACLCA 201521 October 2015 The National

Thank you

www.crccare.com