Case Study - Rhodes - National University of Singapore · Berger Paints (Orica) ... – Final...
Transcript of Case Study - Rhodes - National University of Singapore · Berger Paints (Orica) ... – Final...
Case StudyRhodes Peninsula
SydneyAustralia
A Case Study on Rhodes• Rhodes Peninsula sites• Why is EPA involved in Rhodes Peninsula?• Regulatory role of EPA • Who is involved in EPA regulatory activities?• Regulatory framework• Site history, regulation and remediation• Regulatory procedures• Regulation time line• ITD vs DHTD• Remediation concept implications• Remediation concept, scope and cost
Key acronyms• CCO – Chemical control order• CLM – Contaminated Land Management Act• CoI – Commission of Inquiry• DEC – Department of Environment &
Conservation• DIPNR – Department of Infrastructure Planning
and Natural Resources• EHC – Environmentally Hazardous Chemicals Act• EIS – Environmental impact statement • EP&A – Environmental Planning and Assessment Act• GTAs – General Terms of Approval• IDA – Integrated development and assessment• POEO – Protection of the Environment Operations Act • RAP – Remedial action plan • SCW – Scheduled Chemical Waste• SPCC – State Pollution Control Commission (precursor to EPA)• SRoH – Significant risk of harm• VRA – Voluntary remediation agreement
Sydney Harbour,
NSW
Why is EPA involved in Rhodes?
• Numerous old contaminated industrial sites• Broad range of contaminants
– Lead, phthalates, hydrocarbons, dioxinbenzenes, phenols, herbicides, pesticides
• Posing risk for current and proposed uses• Sites require remediation• EPA involved in
– assessment of risk posed by sites– regulation of sites– licensing & monitoring of remediation activities
Regulatory Role of the EPA
• Determining if a site poses a SRoH to human health or environment under CLM
• Regulating site under CLM if required• Assessing remediation proposals under EP&A
and IDA• Assessing remediation treatment technologies• Licensing remediation and treatment works
under POEO and EHC• Monitoring and enforcement of licences• Assessing remediation outcomes for suitability
for proposed future uses
Who does the regulation?
EPA Contaminated Sites Technical Officer –responsible for
• Site assessment and determination of SRoH• Preparation of declarations for sites posing
SRoH• Assessment of RAP • Assessment of remediation outcomes and
justification for removal of SRoH• Decision on need for ongoing monitoring or
further remediation
Who assesses the EIS Risk Assessment
EPA Scientific officer – responsible for• Assessing acceptability of ecological and
human health risk assessment, based on either– Relevant recognised remediation levels, or– Site specific risk assessment
• Review of derived site remediation criteria
• Consideration of remediation concept
Who assesses EIS remediation proposal
EPA Scientific officer – responsible for assessing• Acceptability of treatment technology from a
chemical/process engineering perspective including treatment outcomes
• Procedures for handling contaminated materials
• Acceptability of remediation and treatment air emissions, noise levels and waste management procedures
• Management of site ground and surface water, including catchment, treatment, use and disposal
Regulatory Framework Key Legislation
• Contaminated Land Management Act 1997 (CLM Act)
• Protection of the Environment Operations Act 1997 (POEO Act)
• Environmentally Hazardous Chemicals Act 1985 (EHC Act)
• Environmental Planning and Assessment Act 1979 (EP&A Act)
Contaminated Land Management Act 1997 (CLM Act)
• Provides regulatory framework and authority for:– Requiring notification by site owner or
occupier of high risk contaminated sites – Assessing site contamination for SRoH– Regulating sites through voluntary
agreements or proscription to investigate and remediate
Protection of the Environment Operations Act 1997 (POEO Act)• Provides the framework for licensing
many industrial processes (scheduled activities) including contaminated soil treatment works
• Based on type and scale of operation• Provides EPA powers of regulation
and enforcement• POEO licences required for Union
Carbide and Allied Feeds sites remediation works because of nature of work and scale of operations
Environmentally Hazardous Chemicals Act 1985 (EHC Act)
• Sets legislative framework for controlling chemicals and wastes that are hazardous to human health and the environment, eg:– Dioxin – Schedules Chemicals such as Organo-chlorines,
DDT, DDE – PCB
• Chemical Control Orders under CLM are significant tool for control/regulation for PCBs, Dioxin and SCW
Environmental Planning and Assessment Act 1979 (EP&A Act)• Provides framework & guidance to State and
Local government planning and consent bodies on environmental protection issues
• Provides planning approval powers for such consent bodies
• Controls Integrated Development Assessment (IDA) process involving multiple agency approvals for large scale activities often licensed under POEO such as soil treatment works
Key planning policies & guidelines
• State Environmental Planning Policy No 55 (SEPP 55) : Remediation of Land 1998
• Managing land contamination Planning Guidelines – SEPP 55 Remediation of Land
• Sydney Region Environmental Plan 29 for redevelopment of Rhodes Peninsula (SREP 29)
Rhodes Historical UsesHistory, Regulation,
Remediation1. Berger Paint Factory (Orica)2. Bay sediments (Orica)3. CSR Chemicals plant (Orica)4. Union Carbide chemicals plant5. Bay sediments (Union Carbide)6. Allied Feeds flour mill7. Glad retail products factory
1. Berger Paints (Orica)
• History– Lead based paint manufacture– Later water and resin based paints– Closed in 1997
• Regulation– EPA issued notice requiring RAP under
Pollution Control Act– Concord Council approved remediation for
potential re-zoning for residential and commercial
Berger Paints (Orica)
• Remediation – Initially some lead cleaning of
contaminated soil considered but not successful
– Final choice was removal and secure landfill in mono-cells of lead contaminated soil
• Outstanding issues– Un-remediated lead contaminated
sediments remain in Homebush Bay
2. Berger Paints sediments (Orica)
• History– Sediments front along western boundary
of site– Subject to storm water and waste water
impact from paint factory– Sediments now impacted with high lead
levels (up to 90,000ppm)
Berger Paints sediments (Orica)
• Regulation– Site remediation consent, required risk
assessment to be submitted to EPA for approval
– Risk assessment concluded low bio-availability of lead and acceptable risk
– EPA and Health did not accept level of risk– EPA found SRoH due to levels of lead and
declared area an investigation site– Further investigation completed– Remediation now agreed, VRA finalised
3. CSR Chemicals (Orica)
• History– Wide range of hydrocarbon production– High levels of phthalates, other
hydrocarbons and odour issues– Site heavily contaminated– Groundwater contamination
• Regulation– As for Berger site
CSR Chemicals (Orica)
• Remediation– Opportunity for use of bio-remediation– Land farming successful – No work required on sediments as
phthalates present are degrading at an acceptable rate
• Outstanding issues– Seawall not remediated retains significant
levels of phthalates & hydrocarbons– Who will own seawall and manage it
4. Union Carbide
• History– Herbicide, insecticide and other diverse
chemical production– Major portions of land reclaimed using
contaminated wastes– Organo-chlorine contamination
• Chlorinated benzenes and phenols• Herbicides (Agent Orange)• Insecticides DDT, DDE etc• Dioxins
Union Carbide
• Regulation– SPCC notice under s.25 of EHC in 1987
for investigation– Notices issued under EHC in 1988 for
remediation– Site remediated for industrial use
completed 1993– EPA s.35 notice under EHC for long
term monitoring 1994– EPA notice changed to s.28 CLM
monitoring and containment
Union Carbide• Remediation
– 1998-1993 excavation – Some removal to landfill– Containment in on-site cells and capping– Monitoring
• Outstanding issues– Not remediated to residential standards– Large volume of contaminated material
remains on site– Potential for groundwater problems– Not determined as posing SRoH
5. Union Carbide Bay Sediments• History
– Impacted by runoff, leachate and groundwater from land reclamation materials and operations
– Chemical spills from barging activities– Heavily contaminated with dioxin, chlorinated
benzenes, phenols, herbicides and pesticides• Regulation
– Investigated through 1990’s and 2000’s– Determined SRoH under CLM 1998 – Declared remediation site under CLM 1998– Total fishing ban invoked for Homebush Bay
6. Allied Feeds• History
– Former flour mill– Close to half of site reclaimed using
contaminated waste from Union Carbide and elsewhere
• Regulation– SPCC uses s.35 of EHC for no disturbance
notice– 2001 EPA assesses under CLM and finds
SRoH– No declaration by EPA as owner agrees to
remediation controlled under planning process
7. Glad Site• History
– Contaminated in some areas from fill (Union Carbide waste)
– Used for retail products manufacture• Regulation
– Remediation regulated by DIPNR• Remediation
– Excavation and most to secure landfill– Worst material for thermal treatment
Parliamentary intervention for Rhodes• In 2001 NSW Upper House Standing Committee
on State Development calls inquiry into Rhodes• Inquiry proceeds through late 2001 and early
2002• Submissions by Govt Depts, residents,
remediators, conservation groups• Major issues are dioxin and thermal treatment
processes• Report with 33 recommendations published
mid-2002• Government response not published to date
Regulation procedures for Union Carbide and Allied Feeds Site’s Remediation
• Managed under IDA • Consent authority is Planning (DIPNR)• Development Application required with
EIS including Risk assessment & RAP• Planning seeks Director General’s
requirements from EPA and other Depts for EIS
• SREP 29 and SEPP 55 main guidance documents
EIS requirements by EPAAlso known as Director General’s requirements• Site risk assessment based on detailed site data
and development of remediation goals in accordance with National Environmental Protection (Assessment of Site Contamination) Measure 1999 (NEPM)
• Comprehensive RAP with Auditor sign off• For ITD or DHTD - demonstrate conformance to
National Protocol Approval/Licensing of Commercial Scale Facilities for the Treatment/Disposal of Schedule X Wastes (ANZECC 1994)
• Conformance to EPA treatment goals and emission limits for air, water, noise and waste
Regulation procedures for Union Carbide and Allied Feeds
• EIS assessed by Planning, EPA, Health etc• Planning calls for Commission of Inquiry (CoI)• CoI takes submission from
– Proponent– Government Depts– Public– EPA Draft GTAs, Planning consent terms
• CoI reports to Minister on project with recommendations and consent advice
• Planning advises Minister on consent• Consent granted
Approvals and Licences
• Project is given consent by Minister for Infrastructure Planning and Natural Resources
• Consent includes detailed conditions and is issued by Planning
• Applicant applies to EPA for POEO and EHC Licences for– Remediation and soil treatment works– Handling hazardous chemical materials
Remediation Regulation Time line
2nd & 3rd Qtrs 2004
2nd & 3rd Qtrs 2004
EPA Licence negotiations
May 2003 November 2003
March 2003 July 2003
CoI – commenced – reported
20002001Assessing site
December and February 2002/3
July and October 2002
EIS and DA submitted
2nd half 20042nd half 2004Commence work
May 2004October 2003Consent granted
October 2001January 2002EPA issued DG Requirements
Union CarbideAllied Feeds
Thermal Treatment - ITD vs DHTD
Lower – (more soil treated)
Higher - (less soil treated)
Unit cost
Requires tight process control to limit air emissions
Produces condensate for 2nd stage treatmentLess soil treated
Weakness
HigherLowerLevel of treatment
High volume requires very efficient process to limit dioxin etc.
High volume low contaminants due to indirect firing
Air emissions particularly dioxin
DHTDITD + BCD/Plasma Arc
Remediation concept implications
All material treated to 1.4 ppb dioxin
Top 1 metre layer dioxin level 0.084 ppb Lower levels have much higher dioxin levels
Material placement
Smaller contaminated volume, all material treated
Much larger volume, only 27% material treated
Cost implications
All material treated to more stringent level
Treatment level less stringent
Treatment levels
Dioxin emissions to air more contentious
Dioxin emissions lowerEmissions
Treat all with DHTD Treat some with ITD
Remediation concepts, scope and cost
$20-25M$60-65 M$30-40 M$20-30 MCost est.
$5.5-5.9
11
350,000
ITD & BCD
Thermally treat worst
material
Union Carbide
$0.9-1.4
22
60,000
Biological treatment
Land farm hydrocarbon
sRemove lead
Orica
66Area (ha)
Remove & replace 0.5m and treat or bury on land
Thermally treat all impacted
Remediation Concept
27,00077,000Volume (m3)
$3.3-4.2$5-6.7Unit cost ( M/ha)
ITD & BCDDHTDTreatment technology
Bay sediments
Allied Feeds
Further Information
• http://rhodesnsw.org/