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DEPARTMENT OF DEFENCEENVIRONMENT AND ENGINEERING BRANCH
DIRECTORATE OF CONTAMINATION ASSESSMENT, REMEDIATION ANDMANAGEMENT
Contamination Management Manual
Annex IBurning Grounds
March 2018, Amended August 2019
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© Commonwealth of Australia 2018This work is copyright. Apart from any use as permitted under the Copyright Act1968, no part may be reproduced by any process without prior written permissionfrom the Australian Government Department of Defence.Announcement statement—may be announced to the public.Secondary release—may be released to the Australian Government Department ofDefence, its contractors and their equivalents in United States of America, Canada,New Zealand and Great Britain.All Defence information, whether classified or not, is protected from unauthoriseddisclosure under the Crimes Act 1914. Defence information may only be released inaccordance with the Defence Security Manual as appropriate.First edition 2018
SponsorDirectorate of Contamination Assessment, Remediation and Management
DeveloperEnvironment and Engineering Branch
Issued byAlison Clifton with the authority of Assistant Secretary Environment and EngineeringBranch
Effective DateMarch 2018
Amendment DateAugust 2019
Review DateAugust 2020 or when changes to processes require an update
Amendments to the document can be proposed as required. Proposals foramendment of this document are to be forwarded to:
Director of Contamination Assessment, Remediation and ManagementEmail: [email protected]
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Quick Reference GuideWhy is this an issue for Defence?
Mandatory RequirementsThe following requirements are mandatory when undertaking project works on or in the vicinity of,legacy burning grounds: Review the Garrison Estate Management System, Environmental Factor Management –
Contaminated site Record (GEMS EFM – CSR) for available historical information relating tocurrent and former site practices to understand what wastes may have been burnt at the site,including review of existing documentation and reports.
Conduct a Pre-construction Contamination Assessment (PCA), Stage 1 Preliminary SiteInvestigation (PSI) or Stage 2 Detailed Site Investigation (DSI) to identify potential contaminantsand areas of concern that could affect project work and Defence capability.
Identify existing sensitive receptors (e.g. waterways, abstraction bores) surrounding legacyburning grounds to assist in determining appropriate management and monitoring measures.
Include risk mitigation measures into design considerations for proposed project work in knownlegacy burning grounds.
Undertake routine monitoring of known burning grounds to identify management/control failures(cover/capping and infrastructure) and changes in concentrations of known contaminants overtime.
Document and report any exceedances or issues to the Defence Project Officer and consultwith Assistant Directors Environment and Sustainability (ADES) to initiate further managementactions where necessary.
Document project works and maintain records of investigations, monitoring and remediation thatis conducted. Update the contaminated site record(s) on GEMS – EFM.
More information Defence Contamination Management Manual
Environment and Sustainability Manager (ESM) Draft Defence Unexploded Ordnance Management Manual (DUXOMM)
Human Health RiskHistorical site activities cancause contamination. Healthsafety and ecological risksmay arise from contamination,depending on the nature,extent and concentration of thecontaminant and the exposurepathway.
Commercial RiskSignificant costs may beinvolved with investigations,remediation and monitoring,and these works have thepotential to cause projectdelays.
Environmental RiskThe absence of appropriatemanagement and monitoringof contamination may pose arisk to the surroundingenvironment if it migrates togroundwater or overland tosurrounding waterways.
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Table of contentsQuick Reference Guide ............................................................................................................................2
Abbreviations............................................................................................................................................4
1. Introduction.....................................................................................................................................5
1.1 Background..........................................................................................................................5
1.2 Purpose................................................................................................................................6
1.3 Defence Documentation ......................................................................................................6
2. Regulatory Overview......................................................................................................................8
2.1 Overview ..............................................................................................................................8
3. Contamination Risk ......................................................................................................................12
3.1 Background........................................................................................................................12
3.2 Conceptual Site Model.......................................................................................................12
4. Projects and Contamination Management...................................................................................15
4.1 Background........................................................................................................................15
4.2 Case Studies......................................................................................................................15
4.3 Case Study 1: Decommissioning of burning ground site...................................................16
4.4 Case Study 2: Management of known legacy burning sites..............................................17
4.5 Management ......................................................................................................................18
5. Data and Reporting ......................................................................................................................22
5.1 GEMS EFM – CSR ............................................................................................................22
5.2 Geographic Information Systems ......................................................................................22
6. References...................................................................................................................................23
Table indexTable 1-1 Guide to disposal options ................................................... Error! Bookmark not defined.
Table 3-1 Contaminants of Potential Concern – burning grounds.....................................................13
Table 4-1 Management considerations..............................................................................................20
Figure indexFigure 1-1 Overview of Defence Environmental Documentation and Annex I......................................7
Figure 3-1 Potential Contamination Risks at a legacy open Burning Ground.....................................14
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AbbreviationsAbbreviation Meaning
ASC NEPM National Environment Protection (Assessment of Site Contamination) Measure1999 (Cth) (NEPC 2013)
CSM Conceptual Site Model
CRAT Contamination Risk Assessment Tool
CSR Contaminated Site Record
CoPC Contaminants of Potential Concern
DCARM Directorate of Contamination Assessment, Remediation and Management
DEMP Decommissioning Environmental Management Plan
DEQMS Defence Estate Quality Management System
DRN Defence Restricted Network
DUXOMM Defence UXO Management Manual
ECC Environmental Clearance Certificate
ESTS Explosives Storage and Transport Committee
EPA Environment Protection Agency or Authority
EPBC Act Environment Protection and Biodiversity Conservation Act 1999 (Cth)
EO Exploded Ordnance
ESM Environment and Sustainability Manager
GEMS-EFM Estate Management System Environmental Factor Module
GEMS EFM –CSR
Garrison Estate Management System Environmental Factor Management –Contaminated Site Record
LOCR Legal Obligations and Compliance Register
MFPE Manual of Fire Protection Engineering
NEPC National Environment Protection Council
NEPMs National Environment Protection Measures
NSIMS National Spatial Information Management System
PAH Polycyclic Aromatic Hydrocarbons
PCB Polychlorinated Biphenyls
PFAS Per- and Poly-Fluoroalkyl Substances
RSO Range Standing Order
Stage 1 PSI Stage 1 Preliminary Site Investigation
Stage 2 DSI Stage 2 Detailed Site Investigation
SVHC Semi-Volatile Organic Hydrocarbons
SVOC Semi-Volatile Organic Compounds
TDS Total Dissolved Solids
TRH Total Recoverable Hydrocarbons
UXO Unexploded Ordnance
VHC Volatile Organic Hydrocarbons
VOC Volatile Organic Compounds
WHS Act Work Health and Safety Act 2011 (Cth)
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1. Introduction1.1 Background
A burning ground is an area that has been used for destruction of solid or liquid waste by openburning or incineration. Historically, Defence have used burning grounds for the destruction ofobsolete and/or un-usable munition, ordnances and potentially explosive materials, as well asother wastes.
Burning grounds were commonly used across the Defence estate where other waste reduction/disposal methods are not available due to the hazardous and/ or explosive nature of the waste.Burning grounds are likely to vary in size, age, purpose, and the frequency and extent of theiruse.
Burning grounds typically fall into one of two main categories and their use has depended onthe type of waste being disposed.
An open burning ground usually includes the use of open burn pits, burn boxes, burn pans orbarrels. These types of disposal do not employ any emissions capture or treatment devices.
Confined burn facilities (or incinerators) usually include the use of burn pans, which arelocated inside custom designed burn chambers. The intent of the burn chamber is to isolate andtreat emissions generated during combustion of potentially harmful substances such as smallarms munitions and clinical wastes. The incinerator is generally designed to treat certain typesof waste and associated exhausts.
Present day burning grounds, which are designed and operated in accordance with the DefencePollution Prevention Management Manual and are unlikely to pose a future contamination risk.
Environmental impact to the air quality, land, surface water and groundwater can arise from theoperation of burning grounds if they are not effectively managed and do not include emissioncontrols and long term historical practices may have resulted in legacy contamination at somesites as a result.
This document provides guidance on managing the risks associated with contamination fromcurrent or historical use of burning grounds. Contamination refers to past and existing chemicalcontamination of soil, water and sediment associated with:
Historical/past industrial and military activities and practises that have now ceased.
On-going operational activities where a recent incident (e.g. spill or leak) has resultedin contamination, but operations at the area, or in the facility, is continuing.
The management measures used to address both historical and recent contamination arecommon however; the timeframe by which the measures are implemented may differ dependingon the degree of risk posed by the contamination to human health and the environment.
The following may also be of relevance to any proposed activity at a current or former Defenceburning ground:
Assessment and remediation of UXO or EOW – reference should also be made to theDraft Defence Unexploded Ordnance Management Manual (DUXOMM).
Contamination risks (soil, sediment and water) associated with ‘live firing ranges’ –which are often located near burning grounds – reference should be made to DCMMAnnex G.
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Environmental management guidelines that aim to minimise the creation ofcontamination from firing range activities – Pollution Prevention Management ManualAnnex 1G – Open Burning Grounds and Incineration.
Range Standing Orders (RSO)
1.2 Purpose
This document provides guidance to Defence personnel and contractors to supervise works thatmay encounter contamination associated with burning grounds across the Defence estate.
It should be noted that burning grounds differ from ‘live firing ranges’, which are used for trainingand testing the function of munitions, rather than their disposal and destruction. This guidelinedoes not cover potential contamination risks associated with demolition ranges associated withfiring ranges (refer to the PPMM Annex – K Heavy Metals on Live Firing Ranges for furtherinformation relating to the management of contamination associated with firing ranges).
1.3 Defence Documentation
This guidance document is an Annex to the Defence Contamination Management Manual andsupports compliance with site contamination management policy as detailed in the DefenceEnvironment and Heritage Manual. An overview of where this Annex fits into the Manual ispresented in Figure 1-1.
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Figure 1-1 Overview of Defence Environmental Documentation and Annex I
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2. Regulatory Overview2.1 Overview
Defence and its contractors must operate to comply with all Commonwealth legislation,including the Work Health and Safety Act (WHS Act), Environmental Protection and BiodiversityConservation Act (EPBC Act) and the National Environmental Protection (Assessment of SiteContamination) Measures (NEPM). Reference can be made to the Defence Legal Obligationsand Compliance Register (LOCR) found on Defence Estate Quality Management System(DEQMS).
Defence may not be subject to State and Territory law in all situations. Whether or not Defenceis bound by State and Territory law is a complex issue and legal advice must be obtained toconfirm whether a particular State or Territory law is applicable to Defence. Defence contractorsmust comply with relevant State or Territory laws.
Guidance relating to the assessment of site contamination is outlined in the NationalEnvironment Protection Council (NEPC) 1999 (Cth), National Environment Protection(Assessment of Site Contamination) Measure (NEPM) as amended in May 2013.
2.1.1 NEPM
The National Environment Protection (Assessment of Site Contamination) Measures 1999 (Cth)(the ASC NEPM) was made under the National Environment Protection Council Act 1994 (Cth).The ASC NEPM is the national guidance document for the assessment of site contamination inAustralia. It is given effect by the National Environment Protection Measures (Implementation)Act 1998 (Cth) for the Commonwealth and individual legislation and guidelines in each Stateand Territory.
The National Environment Protection Council (NEPC) agreed to vary the NEPM by approvingan amending instrument to the ASC NEPM in 2013.
All assessments of site contamination on the Defence Estate are to be undertaken inaccordance with the recommended process and guidance provided in the ASC NEPM.
The purpose of the ASC NEPM is to establish a nationally consistent approach for theassessment of site contamination; to ensure sound environmental management practices by thecommunity, including regulators, site assessors, site contamination consultants, environmentalauditors, landowners, developers and industry parties.
The desired outcome of the ASC NEPM is to provide adequate protection of human health andthe environment, where contamination has occurred, through the development of an efficientand effective national approach to the assessment of site contamination.
The ASC NEPM and schedules are available for download through the NEPC website. TheASC NEPM Toolbox contains additional information including calculators, spreadsheets andother supporting documents to assist with application of the amended ASC NEPM.
2.1.2 Commonwealth Work Health and Safety Act 2011
The Work Health and Safety Act 2011 (Cth) (WHS Act) commenced in 2012 and is regulated byComcare, a Commonwealth Government agency that works in partnership with the Safety,Rehabilitation and Compensation Commission. The WHS Act provides for a nationallyconsistent framework to protect workers and other persons against harm to their health andsafety through the elimination or minimisation of the risks so far as reasonably practicable.
Under the WHS Act, employers must take all reasonably practicable steps to ensure the healthand safety of its employees and those who are at or near a workplace under the employer'scontrol. This means that Defence and its contractors have obligations to protect the health and
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safety of workers and others operating within the vicinity of contaminated land that is on or nearto a workplace under Defence control.
Model Codes of Practice administered by Safe Work Australia provide practical guides toeliminate and minimise the risks to health and safety as required under the WHS Act.
Any controls outlined in the Defence Health and Safety Manual (SafetyMan) must beimplemented when managing contaminated materials.
2.1.3 Environment and Heritage Manual
The Environment and Heritage Manual (EHM) (2019) describes the agreed approach toenabling Defence capability through long-term sustainable management of the environment.The EHM provides instruction and policy guidance for all Defence personnel and contractors onDefence’s legislative obligations and stewardship goals in line with the Defence EnvironmentalPolicy and Environmental Strategy 2016-2036.
The Defence Environment and Heritage Manual is an administrative policy framework documentthat applies to all Defence personnel.
The EHM is divided into 13 chapters addressing:
Chapter 1 – Environment and heritage management in Defence
Chapter 2 – Environmental assessment and approval
Chapter 3 – Heritage management
Chapter 4 – Domestic biosecurity
Chapter 5 – Native species and communities
Chapter 6 – Soil management;
Chapter 7 – Bushfire management
Chapter 8 – Pollution prevention
Chapter 9 – Site contamination management
Chapter 10 – Estate water management
Chapter 11 – Estate energy management
Chapter 12 – Waste minimisation and management
Chapter 13 – Estate climate adaptation
Each chapter links back to a Strategic Aim of the Defence Environmental Policy and providessupporting documentation to support the implementation of the policy. Chapter 9 addresses sitecontamination management.
2.1.4 Environment Protection and Biodiversity Conservation Act 1999 (Cth)
The Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act) is theAustralian Government’s central piece of environmental legislation. It provides a legalframework to protect and manage matters of national environmental significance.
The EPBC Act protects:
The environment, where actions proposed are on, or will affect Commonwealth landand the environment; and
The environment, anywhere globally on land and water, where a Commonwealthagency – including the Department of Defence – are proposing to take an action.
The EBPC Act also protects nine matters of national environmental significance:
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World heritage properties
National heritage places
Wetlands of international importance (Ramsar wetlands)
Listed threatened species and communities
Listed migratory species
Commonwealth marine areas
The Great Barrier Reef Marine Park
Nuclear actions (including uranium mining)
A water resource in relation to coal seam gas development and large coal miningdevelopment.
Defence uses a comprehensive environmental impact assessment and approval program tounderstand and manage the impacts of its activities on the environment and heritage, and toensure compliance with the EPBC Act.
Under the Defence Environment and Heritage Manual, the Director of Environmental Planning,Assessment and Compliance (DEPAC) is the Defence technical authority for determiningcompliance with the EPBC Act. All matters that may trigger the EPBC Act are to be referred toDEPAC.
DEPAC undertakes a self-assessment against the Significant Impact Guidelines 1.1 and 1.2published by the Department of the Environment and Energy to determine if a ‘significantimpact’ EPBC Act protected matter is likely. The self-assessment process considers the natureand extent of contamination and if the presence, disturbance, removal or remediation of existingcontamination is likely to have a significant impact on EPBC Act protected matters. Where asignificant impact to the environment is ‘likely’ the action must be referred to the Minister for theEnvironment and Energy to make a determination on whether a proposed action is a ‘controlledaction’.
For more information with regard to the EPBC Act refer to http://www.environment.gov.au/epbc/.
2.1.5 Off-site migration
The Defence Project Manager should obtain professional advice to inform the reporting andmanagement of any contamination that is found to have migrated off-site into a State/Territoryjurisdiction. Delineating the nature and extent of the off-site contamination will assist Defence toimplement appropriate mitigation measures and to manage any legal implications. A link to thevarious State and Territory environmental agencies can be found in the Defence ContaminationManagement Manual. Any interaction with State or Territory environmental regulators must onlyoccur after first consulting the Directorate of Contamination Assessment, Remediation andManagement (DCARM) and if applicable the Environment and Sustainability Manager (ESM).
2.1.6 Defence Legal Obligations and Compliance Register
Defence and its contractors must operate to comply with all Commonwealth legislation,including the WHS Act, EPBC Act and the NEPM. In addition, Defence and its contractorsshould be generally familiar with the legislative and other regulatory requirements associatedwith the site activities undertaken relevant to the State or Territory in which the site is located.Contractors must comply with State and Territory laws where applicable. Reference can bemade to the Defence Legal Obligations and Compliance Register (LOCR) found on DEQMS.
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2.1.7 Operation of burning grounds
Defence and its contractors must understand and comply with relevant Commonwealthlegislative and regulatory requirements associated with their management of burning groundson Defence properties including those requirements that relate to emissions or discharges fromburning grounds. Reference can be made to the Defence LOCR found on DEQMS.
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3. Contamination Risk3.1 Background
The widespread use of open burning grounds has occurred historically across the Defenceestate. These uses can lead to contamination of soils and/ or groundwater with contaminantswhich may remain persistent in the environment over long periods of time.
The list of Contaminants of Potential Concern (CoPC) associated with open burning andincineration practices, ranging from organic matter (wood and leaves) to munitions and plastics,can be significant given the size and diversity of the Defence estate and the range of activitiesundertaken across the estate. The photographs below provide examples of the burning groundstypically encountered.
▲Example burning ground arrangement ▲Evidence of burn trenches
▲Burn pit – confined burn area ▲ Projectiles uncovered from formerburning area
3.2 Conceptual Site Model
As described in the ASC NEPM, a Conceptual Site Model (CSM) describes the contaminationsources, pathways and receptors and the potential linkages between these.
The initial CSM is constructed from the results of a Stage 1 Preliminary Site Investigation(Stage 1 PSI) or Stage 2 Detailed Site Investigation (Stage 2 DSI) and is the basis for definingwhere potential source-pathway-receptor linkages may exist, which require further investigation.The CSM must be continually reviewed and updated throughout the assessment process toinform subsequent decisions on whether further investigation or contamination managementactions are required.
The CSM should identify complete and potential pathways between known or potentialcontamination sources and receptors. Where the pathway between a source and a receptor isincomplete, the exposure to chemical substances via that pathway cannot occur, but thepotential for that pathway to be completed (for example, by abstraction of groundwater or achange in land use) should be considered in all stages of assessment. The CSM can also be
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used to consider where management measures would reduce the likelihood of an exposurepathway becoming complete.
The essential elements of a CSM are:
Known and potential sources of contamination and contaminants of concern including themechanism(s) of contamination (e.g. ‘top down’ spill or sub-surface release from corrodedtank or pipe).
Potentially affected media (e.g. soil, sediment, groundwater, indoor and ambient air).
Human and ecological receptors.
Potential and complete exposure pathways.
For contaminated land site investigation the CSM should be presented as a graphic, a table or aflow chart and adequately described in written text. The risks outlined in the CSM should bereplicated appropriately in the Contamination Risk Assessment Tool (CRAT).
3.2.1 Contaminants of potential concern
Table 3-1 presents a list of Contaminants of Potential Concern (CoPC) in air, land and waterthat should be considered when undertaking works in and around burning grounds. It is notedthat this list is not necessarily exhaustive and the presence or absence of any or all of thesecontaminants will be dependent on the site history and the materials being burnt.
Table 3-1 Contaminants of Potential Concern – burning grounds
Land Water
Heavy metals
Sulphates
Nitrates
Phosphates
Cyanide
PAH
Volatile organic compounds (VOCs)
Semi-volatile organic compounds (SVOCs)
Total recoverable hydrocarbons (TRH)
Dioxins and furans
Polychlorinated biphenyls (PCBs)
Benzene, toluene, ethylbenzene and xylenes(BTEX)
Chlorinated hydrocarbons
Phenols and cresols
Asbestos
Advance composite materials (graphite / epoxy/ carbon fibre)Per- and Poly-Fluoroalkyl Substances (PFAS)
Ammonia
Sulphates
Nitrates
Phosphates
Cyanide
Metals
PAH
VOCs
SVOCs
TRH
Dioxins and furans
PCBs
BTEX
Chlorinated hydrocarbons
Phenols and cresols
pH
Total dissolved solids (TDS)
PFAS
The potential for unexploded ordnance (UXO) or exploded ordnance (EO) should also beconsidered. Where the potential presence of UXO or EO exists, reference should be made tothe Draft DUXOMM for assessment and management processes.
3.2.2 Graphical Conceptual Site Model
A visual representation of a CSM relating to burning grounds, and the potential contaminationsources, pathways and receptors is presented in Figure 3-1.
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Figure 3-1 Potential Contamination Risks at a legacy open Burning Ground
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4. Projects and ContaminationManagement4.1 Background
When conducting works or planning a redevelopment in the area of a current or former burningground, the Defence project manager should consider a number of key features of the facility,including, but not limited to:
Facility age – The age of the facility will influence the extent and magnitude of contaminationpresent. Older burning grounds may have burnt different materials not commonly subject toburning practices today such as plastics, hard drives and other sensitive materials and will nothave used current best practice containment systems. As a result, potential contaminationimpacts associated with older sites may be greater and/or more variable than newer facilities.Sites that have been in operation for an extended period will have greater potential forcontamination.
Frequency of use – The current and historical use of the facility will influence the amount ofwaste that has been burnt and the related level of contamination. It is expected that morefrequently used burning grounds would be more contaminated compared with burning groundsthat have been used sporadically over a similar period.
Location – If the location of the burning ground has varied over time, contaminants may bespread over a greater area, increasing the extent of potential contamination. This scenario ismore typical where open burning has been undertaken on an ‘ad-hoc basis, resulting innumerous burn locations across the broader burning ground area. In some cases, ash resultingfrom burning practices may have been moved from the incineration pit at the burning groundinto designated landfill areas, some of which may not have been labelled.
Depth to groundwater – The depth to the water table and groundwater quality are importantconsiderations. Shallow water tables present a higher risk that groundwater quality will beimpacted by the leaching of contaminants from the soil. Contamination may affect the potentialbeneficial uses of groundwater, both on-site and off-site (e.g. drinking water and irrigation).
4.2 Case Studies
The following case studies highlight the contamination risks related to burning grounds andidentify management measures and sources of further information to address thesecontamination issues. These case studies are hypothetical examples only and are not based onactual events.
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4.3 Case Study 1: Decommissioning of burning ground site
4.3.1 ScenarioDefence plans to decommission a burning ground on a site andredevelop the area for future Defence use. The burning ground washistorically used to dispose of a range of wastes including unspentammunition, projectiles and lead casings. Munitions were only burntonce. The burning ground comprised a single consolidated pit located inan excavated bunker without a gravel layer. Residual unburnt materialswere stockpiled in a single location, directly on the ground surface, forfuture off-site disposal by a contractor. The site has not been subject togroundwater or surface water monitoring as part of routine operations.
4.3.2 RisksHuman Health Risk – Potential health and safety risks associated withmunitions burning only once during operation, as burning munitionstwice reduces the likelihood of blank firing on disposal.
Redevelopment activities may commence in areas that arecontaminated. This presents an exposure hazard to Defence personnelor its contractors where contamination is not delineated and safe workmethods have not been actioned to reduce risk.
Environmental Risk – The risk of contamination of shallow soils fromburning materials directly on the ground surface without the presence ofa removable gravel layer and the potential for leaching of contaminantsof concern to groundwater, could have impacted current or futurebeneficial groundwater uses. A gravel layer would act as a removablelayer and minimise the migration of leachate or smaller solid particulatesinto the underlying soils. Storage of residual waste directly on theground surface for extended periods of time may result in leaching ofcontaminants to the underlying soil and groundwater, impacting surfacewater or beneficial groundwater uses.
Commercial Risk – Significant costs may be involved withinvestigations, remediation and monitoring, and these works have thepotential to cause project delays and result in additional project costs, where they were notplanned and costed.
4.3.3 Key considerations and management measures Review the Garrison Estate Management System Environmental Factor Management –
Contaminated Site Record (GEMS EFM – CSR) to access and review available data andsite history information (current and former land use).
If existing information is not available, the physical setting of the site must be describedand the soils and groundwater characterised through site investigation including thecollection of environmental samples, as required. Site investigations may include a PCAor Stage 1 PSI.
Prepare an environmental management/remediation plan with actions identified toprevent potential ongoing contamination and off-site migration of contamination.
Document works undertaken and maintain records, including investigations, monitoringand remediation that is conducted.
4.3.4 More information Defence Contamination Management Manual
Environment and Sustainability Manager (ESM)
Draft DUXOMM
Why is this an issue?Historical operation of theburning ground, and theabsence of routinemonitoring and managementduring the lifecycle of thefacility, may have resulted incontamination of soils,groundwater and/ or surfacewater in the surroundingarea.
How can I manage it?Understanding the history ofthe site can help to identifykey contaminants ofpotential concern. Athorough desk based reviewof available information mustbe undertaken and intrusivesampling works completed toidentify the risks posed bycontamination
Where can I getinformation/help? GEMS-EFM Defence ADES Defence Contamination
Management Manual
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4.4 Case Study 2: Management of known legacy burning sites
4.4.1 Scenario
A known former burning ground is located on a Defence site. Theburning ground was used for approximately 30 years between 1980 and2010. A number of burn pits were located across the site, typically incleared areas. More recent burn pits may have been established withgravel layers, however a number of older pits may have been usedwithout a gravel layer at the base.
A maintenance contractor undertaking routine vegetation slashing worksreported an area of dead vegetation and surface ponding of oily waterclose to a nearby stream. The maintenance contractor reported theincident to Defence, and following consultation with the Defence ADES,investigations into the source of the liquid were undertaken.
4.4.2 Risks
HSE Risk – Redevelopment activities may commence in areas that arecontaminated. This presents an exposure hazard to Defence personnelor its contractors where contamination is not delineated and safe workmethods have not been actioned to reduce risk.
Environmental Risk – The risk of contamination of shallow soils fromburning materials directly on the ground surface without the presence ofa removable gravel layer and the potential for leaching of contaminantsof concern to groundwater, could have impacted current or futurebeneficial groundwater uses. A gravel layer would act as a removablelayer and minimise the migration of leachate or smaller solid particulatesinto the underlying soils. Storage of residual waste directly on the groundsurface for extended periods of time may result in leaching ofcontaminants to the underlying soil and groundwater.
Commercial Risk – Significant costs may be involved with investigations, remediation andmonitoring, and these works have the potential to present delays to the redevelopment projectwhere they were not planned and costed.
4.4.3 Key considerations and management measures
Review the GEMS EFM – CSR to access and review available data and site historyinformation (current and former land use).
Review available routine water quality monitoring program reports and results. If existing information is not available, the physical setting of the site must be described
and soils and groundwater characterised through site investigation including thecollection of environmental samples (as required). Site investigations may include a PCAor Stage 1 PSI. If existing information is available for the former burning ground, targetedintrusive site investigations must be undertaken to confirm the nature and extent ofcontamination and facilitate the development of longer-term site management options.
Prepare an environmental management/remediation plan with actions identified toprevent potential ongoing contamination and off-site migration of contamination.
Document and record works undertaken including investigations, monitoring andremediation that is conducted in GEMS and Defence ESdat.
4.4.4 More information
Defence Contamination Management Manual Defence ADES Draft DUXOMM
Why is this an issue?Historical operation of theburning ground, may haveresulted in contamination ofsoils, groundwater orsurface water in thesurrounding area. A lack ofroutine monitoring to alertmanagers to contaminationmay have contributed to anincreased liability.How can I manage it?Understanding the historyof the site can help toidentify key contaminantsof concern. A thoroughdesk based review ofavailable information mustbe undertaken and intrusivesampling works completedto assess the potential risksposed by contaminationWhere can I get help? Defence ADES DCMM
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4.5 Management
A staged approach may be required to understand, characterise and to manage the potential forcontamination at legacy burning grounds and surrounding land.
Each stage of works should be considered as a discrete task, and hold points are recommendedat the completion of each stage to consider whether progression to the next stage is required.
A Stage 1 PSI and/or Stage 2 DSI may already have been completed for many burning groundsacross the estate, and pollution prevention or contamination management measures may be inplace. For these sites, a review of existing reports and documentation that may be available onthe GEMS EFM - CSR must be undertaken as a priority before planning of works commence.
In some instances, it may be beneficial to complete multiple stages of works consecutively (e.g.Stage 1 PSI and Stage 2 DSI may run in either consecutively or in parallel where timeframes fordelivery are critical). In these cases, each of the tasks outlined in Table 4-1 must still beaddressed as part of the combined scope of works.
4.5.1 Operational facilities
Further information relating to management of operational burning grounds and incinerators isprovided in the
Defence Manual of Fire Protection Engineering (MFPE). Pollution Prevention Management Manual for Open Burning Grounds (Annex 1G)
For other non-environmental requirements, such as storage and handling requirements,licencing and design criteria, reference should be made to the explosive ordnance ExplosivesStorage and Transport Committee (ESTS).
4.5.2 Decommissioning
All burning grounds that are no longer in use should be decommissioned and any associatedcontamination remediated or managed, so far as reasonably practicable, to prevent it fromposing an unacceptable risk to human health and reduce risk to the environment.Contamination can limit the range of potential future land uses for a site and its surroundingarea. Existing future land use (e.g. industrial or accommodation) for a legacy burning groundarea will determine the extent of remediation necessary to reduce risks to human health and theenvironment.
An appropriately qualified and experienced environmental professional must undertake thedecommissioning of open burning grounds, incinerators and associated facilities in accordancewith a Decommissioning Environmental Management Plan (DEMP). The DEMP should addressthe following key items:
The time frame for implementation of remedial work.
Site access restriction and signage requirements.
Soil contamination assessment requirements, including sampling and analyticalrequirements (Sampling, Analysis and Quality Plan) to:
– Identify the type and distribution of contaminants in soils
– Quantify levels of contaminants in soils
– Classify soils in accordance with relevant state or territory Environment ProtectionAuthority (EPA) guidelines for disposal of contaminated soil
Soil remediation and site clean-up requirements, where relevant.
Waste management, containment, disposal and transportation provisions.
Erosion and sediment control measures.
Noise management provisions, where relevant.
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Dust suppression and control measures.
Equipment decommissioning, isolation, storage and transportation requirements(including provisions for solid and liquid waste containment during works).
Actions in the event of environmental releases/incidents.
General housekeeping requirements during decommissioning works.
Personal safety requirements and references to relevant health and safety plans.
Record keeping and documentation requirements.
Compliance with these requirements will ultimately reduce Defence’s environmental risk.
4.5.3 Management of open burning ground legacy issues
The following steps must be considered for the management of legacy contaminationassociated with burning ground operations:
A site investigation to assess whether any current open burning grounds are causingadverse environmental impacts.
Review of site records and anecdotal evidence from site personnel to identify areaswhere past activities with the potential to cause contamination were conducted, includingthe type and quantities of waste burnt.
If contamination or environmental impacts are identified, the Defence Project Managermust be notified. If the presence of contamination was identified as an unexpected find(i.e. the presence of contamination in the area not already known/listed on the GEMSEFM, an environmental incident should be recorded using the Defence EnvironmentalIncident reporting tool available on DEQMS and the ADES must be informed.
A contamination investigation may be required. If an investigation is undertaken, thefindings must be recorded in the GEMS EFM – CSR.
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Table 4-1 Management considerations
Stage of works Summary of points for consideration Next steps
Pre-constructionContaminationAssessment
Review of the GEMS EFM – CSR. Limited soil sampling in the footprint of the
construction area. If groundwater is shallowand construction will require dewateringconsider collection of groundwater samplesalso.
Analysis of samples for the CoPC, includingthose discussed in Section Error! Referencesource not found..
A PCA is suitable forconstruction projectswhere spoil, and / orwaste water, needs to becharacterised for re-use,temporary stockpiling orfor off-site disposal.Obtain approval fromDefence (reuse) orregulator (off-sitedisposal) based on thedata and any relevantECC conditions.
Stage 1:Preliminary SiteInvestigation
Establish historical use of the area through adesktop review and interviews with personsfamiliar with historic burning grounds use.
Understand the physical setting of the site(including soils, hydrogeology andhydrology).
Document all works undertaken. Risk assessment based on the CRAT.
The findings of the Stage1 PSI should becommunicated to theDefence Project Managerfor the decision toproceed to the Stage 2DSI.An ECC may be required.
Stage 2:Detailed SiteInvestigation
Investigation of potentially contaminatedmedia (including soils, sediments,groundwater, and surface water), withsufficient samples collected to understand thenature and extent of contamination.
Sampling for explosive residues must beconsistent with guidance documentation asdiscussed in Section 2.1.1 and with ASCNEPM and Australian Standards for otherCOPCs.
Geophysical investigation techniques arerecommended in areas where burials orUXO1 may be present.
Develop a CSM to assess the risk toreceptors under the existing land use, andany proposed redevelopment included duringsite works.
Document all works undertaken. Update to CRAT.
The scope of works forsite investigations andfindings of the Stage 2DSI should be discussedwith, and communicatedto the ESM for longerterm management of thesite.An ECC may be required.
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Stage of works Summary of points for consideration Next steps
Stages 3 - 5:
RemediationPlanning,Implementationand SiteManagement
Undertake risk assessment, as required, toestablish further remediation or management.
Establish procedures for the remediation ormanagement of contamination to minimiseany unacceptable risks of potential exposureto contamination. This process must includea stop work procedure.
Allow for uncertainty by developingcontingency procedures.
Implement and manage the works inaccordance with the established procedures.
Document works undertaken, includingvalidation of any remedial works.
Site management options and/or monitoringrequirements to be established postcompletion of necessary assessment.
An ECC may be required.
Decommissioning Consideration must be given tocontamination residues on infrastructure.
Prior to demolition works, an assessment ofthe contamination status of infrastructuresurfaces must be undertaken so that disposalor recycling options for building materials canbe determined.
An ECC may be required.
Note:1 Assessment methods and technologies for UXO are beyond the scope of this document, and reference must be made
to the DUXOMM, where this type of assessment is required.
All spoil material generated from excavated burning grounds must adhere to the Defence Guidancedocument on DCMM Annex C Stockpiles and Re-use of Excavated Material.
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5. Data and Reporting5.1 GEMS EFM – CSR
Data and reports generated as part of the investigation and assessment of burning groundsmust be captured in the GEMS EFM.
The GEMS EFM – CSR is the database used to capture environmental information across theDefence estate, and provides access to historical contamination investigation reports forDefence properties. Contaminated site records are geo-referenced and they can be accessedby Defence personnel or contractors with Defence Restricted Network (DRN) Access.
Contractors/Consultants working on behalf of Defence must provide reports, updated andcompleted GEMS Data Load Tool (GDL) (for new or existing CSR’s), CRAT, ESdat and(Geographic Information System) GIS files relating to contamination to their Defence point ofcontact, Project Manager or ESM who will be responsible for auditing and validatingsubmissions and ensuring the upload of information into the GEMS EFM – CSR.
Refer to the Defence Contamination Management Manual, Annex L - Data Management.
5.2 Geographic Information Systems
All mapping Geographic Information System (GIS) data is required to be provided to Defence inNational Spatial Information Management System (NSIMS) metadata format. The Defence NSIMSmetadata tool is available through an online search and on DEQMS.
Refer to the Defence Contamination Management Manual, Annex L – Data Management.
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6. ReferencesANZECC, 1992, Australian and New Zealand Guidelines for the Assessment and Managementof Contaminated Sites.
NEPC 2013, National Environment Protection (Assessment of Site Contamination) Measure1999 (Cth) (as amended in 2013), NEPC.
NEPC National Environment Protection (National Pollutant Inventory) Measure, 1998.
DCMM Annex C Stockpiles and Re-use of Contaminated Material.
Draft Defence Unexploded Ordnance Management Manual (DUXOMM)
Defence Pollution Prevention Management Manual and Annexes:
Annex 1A - Acid Sulfate Soils Management
Annex 1B - Copper Chrome Arsenate Treated Timber
Annex 1C - Fire Fighting Foam Management
Annex 1D - Fuel and Chemical Storage and Handling
Annex 1E - Liquid Waste Storage and Handling
Annex 1F - Maintenance and Cleaning Activities
Annex 1G - Open Burning Grounds and Incineration
Annex 1H - Solid Waste Storage and Handling
Annex 1I - Stormwater Management
Annex 1J - Wastewater Treatment Plants
Annex 1K - Heavy Metals on Live Firing Ranges
Annex 1L – Routine Water Quality Monitoring
http://www.defence.gov.au/estatemanagement/Governance/Policy/Environment/Pollution/implementation.asp
