Guideline to create a clean up plan for contaminated land

This section outlines what you should include.

1. Site details

Include:

• the name of the person(s) who manage and control the site. If another person is responsible for implementing your clean up plan, include their details too.
• the site address
• figures showing the location of the site
• a site plan that includes key site features (e.g., buildings, roadways etc)
• a brief description of the current activities at the site.
  

2. Contamination, environmental values, and conceptual site models

Contamination information

Include information about:

• the nature, level and extent of contamination and the contaminants of concern. Specify whether the contamination is in land, water and/or air on and from the site
• the source (where known) of contamination
• any known and reasonably foreseeable risks to human health and the environment from the contamination
• findings of completed environmental site assessments. List these reports under References.

Environmental values

Present environmental values and relevant investigation values for:

• the site
• any impacted off-site areas (e.g. nearby waterways)
• any planned change of land use.

List the source of the investigation levels in footnotes and under References.

Conceptual site model

Include a conceptual site model that identifies:

• all onsite and offsite receptors and pathways
• past and current potentially contaminating activities
• neighbouring properties
• key surface water bodies in the vicinity of the site
• site-specific hydrogeological information.

You can present this in text, tables, graphics or flow diagrams in accordance with the National Environment Protection (Assessment of Site Contamination) Measure 1999 (as amended May 2013). If providing a figure, include contaminated land areas, both on and from the site.

More information

• National Environment Protection (Assessment of Site Contamination) Measure 1999.
  

3. Data gaps and further investigations

Include any plans for further investigation or assessments.

This could be, but is not limited to:

• further delineation of level and extent of contamination
• addressing data gaps identified in the conceptual site model
• monitoring to support or verify the effectiveness of the remediation approach.

4. Remediation approach and criteria

Specify the chosen remediation approach and the criteria that define success of the remediation.

Even if you're collecting extra data, you must specify a remediation approach.

You can include diagrams to help explain the remediation approach. For example, maps showing the location of on-site repositories, or other remediation infrastructure.

Include criteria that define the success of the remediation. These should aim to restore environmental values on and from the site as far as practicable.

If you derive criteria specific to your site, ensure they’re risk-based and support the environmental values on and from your site.

If your approach generates waste, outline how it will be managed in line with the waste framework set out in the Act.

More information

• Your duty to manage contaminated land
• Guidance for the cleanup and management of groundwater (Publication 2001.2)

Remedial options assessment and treatment train

Assess potential remediation technologies and their suitability. You can display each remedial option in a summary table that describes its:

• suitability or effectiveness
• cost
• timeframes
• social and environmental benefit.

Outline the reasons why you chose a specific remediation approach, considering:

• your conceptual site model
• the contaminants of concern
• the effectiveness of commonly available technologies to remediate the contamination.

More information

• CRC CARE Remediation Action Plan: Development – Guideline on performing remediation options assessment.

Complex remedial options assessments

• Include the assessment in the appendix and summarise its findings in the clean up plan
• If you do not select commonly available and proven technology, support your decision with data from field-based trials.
• If your assessment is complex, include it in the Appendices.
• If you need more time to confirm your remediation approach (e.g. it will be informed by lab trials), document your methodology.

Your approach may involve several remediation technologies. In this case, specify the goals (or ‘end points’) for each technology.

Pilot testing

Bench or pilot testing may be needed to confirm how effective and feasible a remediation approach is.

Report the results of pilot trials you’re using to:

• inform your remediation approach, its costs and timeframes
• support technical and cost-benefit arguments about what is ‘reasonably practicable’.

List the report under References.

If your approach uses existing technologies, refer to previous empirical data.

5. Risk management and contingency plans

Document the risks of your remediation approach and how you will manage them. This will help you comply with your General Environmental Duty.

Common risks during a clean up include odour, dust or other off-site discharge of waste. Potentially acute risks include fires and explosions.

Contingency plans

Set out how you will respond to unexpected events like:

• the chosen remediation approach is unsuccessful
• disruptions to the remediation process
• increased environmental risk from the contamination
• unexpected exposure to contamination
• creation of dust, noise or vapour risks
• extreme weather events (e.g. flooding).

Risk mitigation measures

Detail any procedures to prevent harm, or risk of further harm during clean up. This could include:

• changing your remediation technologies or processes
• signage or notification to affected parties
• using mobile remediation technologies or additional environmental monitoring,
• additional power supplies in the event of power outages
• fencing and site security
• personal protective equipment
• dust and/or odour suppression systems
• systems to manage contaminated stormwater.

Triggers for activating risk mitigation measures

Specify the triggers. Examples of triggers include:

• performance indicators for the chosen remediation not being met
• exceedances in contaminant concentrations in groundwater
• unexpected vapour release (gas detection alarms)
• odour reports at the boundary or complaints
• equipment malfunction
• power outages
• data from sentinel monitoring locations.

If you activate a contingency plan that results in a revision, you may need to update the clean up plan to document the revision.

6. Unexpected finds

Detail what happens if you discover new contamination or a potential source of contamination during the clean up.

An unexpected discovery should prompt:

• a review of the conceptual site model
• a review of the clean up plan if additional remediation actions are required.
  

7. Environmental monitoring program

Environmental monitoring is site specific and informed by your conceptual site model. It can include land, groundwater, surface water and air monitoring.

Set out how you will assess contamination and track the progress of remediation. Monitoring should respond to seasonal variations in the environment, such as changes in groundwater and surface water levels and flows.

Include offsite monitoring locations where contamination has migrated beyond the site boundary.

Detail key quality assurance criteria to ensure integrity of the data and analysis. For example,

• use a National Association of Testing Authorities (NATA) accredited laboratory
• sample quality control techniques.

More information

• National Environment Protection (Assessment of Site Contamination) Measure 1999.

The monitoring program may evolve:

• as clean-up activities progress
• when contingency measures are triggered
• if the conceptual site model changes.

Monitoring should continue after remediation. This will confirm if any residual risks to human health and environment are acceptably low.

Your environmental monitoring should include information on how you communicate the environmental risks associated with your site to interested and potentially impacted parties.

8. Validation of clean-up activities

Describe how you will demonstrate the end point of a clean up. Include post remediation activities and the methodology for the validation in the clean up plan.

Validation of clean up typically requires:

• longitudinal environmental data
• a risk assessment of any remaining contamination.

9. Timeframes

Specify the stages and timeframes for implementing the clean up plan.

Key milestones and tasks may include:

• procuring a remediation contractor
• engaging an environmental auditor (where required)
• interim risk management such as signage, fencing, surface water diversion
• baseline assessments (including completing a detailed site investigation)
• installing remediation equipment
• starting remediation activities
• post remediation performance monitoring and assessments
• “close out” (risk assessments to support closeout).
  

10. Key roles and responsibilities

Specify the person in management and control of the site.

List the key project personnel, their roles and responsibilities.

Include details of the responsible parties such as the:

• owner (unless already listed at section 1)
• consultant
• contractor
• environmental auditor (where applicable).
  

11. Key contacts and communications planning

Include the name and contact details for queries or concerns from the community, EPA or interested parties.

Create a stakeholder communication and engagement plan. Set out how you will inform stakeholders who may be affected by the contamination. For example, local council, contractors and neighbouring premises.

The implementation of a well-designed stakeholder and communication plan can help you meet your duty to manage contaminated land.

More information

• Schedule B8 (Volume 20) of the National Environment Protection (Assessment of Site Contamination) Measure 1999 - Federal Register of Legislation.

12. Review and updates

You may need to revise your clean up plan due to:

• additional investigations
• outcomes of pilot testing
• a change in the site conditions.

Specify the mechanism and procedure for the plan’s review. Include who will approve the changes, such as by:

• a suitably qualified professional
• an EPA-appointed environmental auditor (contaminated land)
• EPA.

Include how changes will be communicated to interested parties, such as:

• EPA, if we’ve required you to implement your clean up plan
• the environmental auditor, if your plan is auditor-verified
• contractors
• off-site parties.

List the plan’s:

• author
• reviewer
• approver
• distribution list
• version, including the date of the most current version.

For complex contamination and site settings, read about the adaptive site management process.

13. Permits and regulatory approvals

List all the required approvals for implementing your clean up plan. For example:

• an EPA permit for off-site waste disposal
• permits from other regulatory authorities.

14. Reference table and appendices

List all the source documents for the data referred to in the clean up plan. For example,

• environmental site assessments
• risk assessments
• reports of remediation trials.
  

You do not need to include the actual documents in the clean up plan.

List all other documents you will use to implement your clean up plan. For example:

• detailed design documents
• construction environmental management plans
• health and safety plans
• stakeholder management plans.

Attach diagrams and photographs of the site as appendices.